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.
Issue 1e (iii) - Reviewing limits and feedback on gambling activity: activity statements
Proposals
The 2023 White Paper set out the Gambling Commission’s commitment that we would review and consult on requiring gambling licensees to improve player-centric tools such as activity statements.
The policy intent set out in the consultation was to increase the visibility and accessibility of transactional information and gambling history to inform consumers about their gambling activities. We did this through proposals for licensees to send personalised feedback to customers periodically using information currently available under remote gambling and software technical standards (RTS) 1 – Customer account information, on a frequency that could be set by the customer, and for licensees to monitor engagement with activity statements to inform best practice. This would enable customers to reflect on their gambling and provide an opportunity to review existing limits or apply a new limit.
Consultation questions
To what extent do you agree with the new requirement for operators to provide activity statements to customers, including information currently required to be made available under RTS 1 – Customer account information?
To what extent do you agree with the new requirement for this information to be provided every 6 months for accounts with activity within a rolling 12 month period?
To what extent do you agree with the new requirement for operators to provide facilities for customers to set the frequency of reminders?
To what extent do you agree with the new implementation guidance that operators should also provide activity statements to prompt a review of limits at additional appropriate points in the customer journey?
To what extent do you agree with the new implementation guidance that operators should consider ways to share activity statements with customers in order to maximise engagement?
To what extent do you agree with the new implementation guidance that operators should monitor engagement and interaction with activity statements to inform good design and best practice?
Respondents’ views
Support for these proposals was mixed, and analysis revealed that concerns were largely in relation to the generation of material in the form of transaction statements, rather than the principles of increasing and maintaining awareness of and encouraging or facilitating access by customers to information about gambling activity, which was widely supported.
A number of respondents highlighted considerations around the format, frequency, delivery method and content of activity statements, drawing on current practice here and in other jurisdictions. Some respondents who disagreed with the wording of the proposal, agreed with the principle around improving access to customer account activity. A small number of respondents were concerned that activity statements could act as a prompt to start gambling after a period of non-activity or could prompt loss-chasing behaviours.
Our position
In considering stakeholder feedback we have taken into account:
- evidence that consumers sometimes lack accuracy in recalling account activity, and that increasing awareness of gambling history and activity can be helpful to review gambling behaviours and prompt change
- that there is a balance to be struck between informing customers about activity and the volume of information they receive which could have unintended consequences such as disengagement
- concerns around data security regarding the generation, storage and transit of personal financial data, and technical and operational challenges around the creation of these documents on an ad-hoc, possibly frequent cycle (due to customer choice around the frequency of alerts)
- the potential position of and necessity for activity statements within the context of the range of controls that already exist within our regulatory framework
- that at the point of consultation the implementation of activity statements in Australia was relatively new, and it may be likely to be some time before we see evaluation of the effectiveness of these statements in order to inform the GB regulatory context.
Our position is that in the form proposed in the consultation, there is insufficient evidence to outweigh the potential regulatory burden of generating, storing and securely transmitting full statements of account activity, at this point.
Given the broad support for the principle around making account activity information more visible, we have made an amendment to the proposed requirement, to instead require an alert to remind customers that the information is available in their account, rather than a full statement. This would deliver the aim of drawing attention to information about customer account activity to prompt a review of account activity, and review current limits or set a new financial limit.
In meeting this requirement, we encourage innovation in the industry to develop, trial and evaluate different forms and core content of these alerts, as well as different approaches or channels for sending alerts, with the aim of monitoring engagement with the information to identify optimum ways of reaching customers.
We therefore are not proceeding with the proposals as set out in the consultation, and instead have amended the wording of the RTS provisions proposed in the consultation to revise the requirement and replace activity statements with an alert to customers to review account activity.
Final wording
This requirement will come into force on 31 October 2025.
Applies to: All gambling – except subscription lotteries.
RTS requirement 12D
The gambling system must provide a prompt to customers to review their own account and transaction information, as is currently made available under RTS 1 – Customer account information. This must be provided at a minimum of six-month intervals for accounts with activity within a rolling 12-month period. Customers must be provided with facilities to set more frequent reminders to receive this statement and review their limits.
RTS implementation guidance 12D
Operators should monitor engagement with and responses to alerts, in order to inform good design and best practice.
Last updated: 4 February 2025
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