Consultation response
Autumn 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response
This response sets out our position in relation to the consultation on the proposed changes to LCCP and Remote Gambling and Software Technical Standards.
Contents
- Executive summary
- Summary of topics
- Customer-led tools - Consultation Response
- Improved transparency on customer funds in the event of insolvency - Consultation Response
- Removing obsolete Gambling Commission requirements due to the government's upcoming statutory levy - Consultation Response
- Evaluating the impact of relevant changes
- Annex
Equalities considerations
At the time of consultation, our initial assessment was that:
'The proposals constitute universal interventions to improve the design, presentation and access to financial limits as a customer-led pre-commitment tool. They are intended to support all consumers who wish to make use of these tools to help them actively manage their gambling in ways that work for them. Implementation of these proposals would be made through updating the Remote Gambling and Software Technical Standards and required changes to the functionality of the remote gambling system.'
We invited views, evidence or information which might assist the Gambling Commission in considering any equalities impacts in the context of the proposals.
We received a small number of responses to help inform our assessment of the equalities impacts of the proposals. These included concerns around neurodivergence and processing and understanding information as well as responses to alerts, and consideration of cognisance of information for non-English speakers. One respondent raised issues of potential vulnerabilities of different groups more generally, in relation to problem gambling and gambling harm.
We received stakeholder feedback that interruptions to game play – such as the proposed alert when approaching a limit - while in a hot state could have a more significant and potentially negative impact for consumers who are neurodiverse.
In considering this potential impact and adjustments to the proposals which could mitigate the risk, we took into account factors such as limits or alerts to approaching limits that would ‘kick in’ during play and create a potentially problematic sense of urgency would more likely be in the form of the less common spend or loss limits than deposit limits, in the form of a mid-play pop-up or other interruption.
In addition, in the context of the overall package of proposals, we are proceeding with the proposal that customers will still be able to opt out of setting limits, so that if the proposed alerts when approaching limits were to be implemented, customers would have the option to not receive those alerts, which would mitigate this risk.
We have decided not to proceed with the proposal for alerts when a customer’s spend approaches financial limits set.
The proposals also include expectations for operators to clearly communicate how limits applied across different products or channels work, as well as limits across multiple time frames.
Respondents gave feedback that non-native English speakers may not easily understand or comprehend sometimes complex information in terms of how different types of limits may operate and how they interact with each other.
The expectation that operators will communicate clearly with customers exists across the regulatory framework, and our expected standards are consistent with this. As a direct result of feedback, we have made revisions to the proposed wording of a number of requirements and implementation guidance, where relevant, to reinforce our expectation that information should be clear and easily understandable.
We will monitor a series of data sources, such as consumer contacts and compliance assessment findings in order to understand the ongoing risks of customers misunderstanding how financial limits work and will take action if the risk appears to increase.
In addition to stakeholder feedback, we have also considered that a number of our licensees are based overseas and we want to ensure that the wording of the provisions is as clear and unambiguous as possible. We have made revisions to the wording of a number of requirements and implementation guidance to provide clarity, including the addition of further implementation guidance where appropriate, as a direct response to feedback from stakeholders, and in particular to help clarify compliance expectations.
We consider that the adjustments made to the package of proposals will mitigate the risks identified. However, we will continue to monitor this position, as noted, and will revisit if the situation changes.
Last updated: 4 February 2025
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