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 1c (ii) - Improving consistency and understanding of the type of limits offered to all customers
Proposals
The current remote gambling and software technical standards (RTS) allows operators to choose the type of financial limit(s) they offer customers. In order to improve consistency across the industry and to simplify the landscape for consumers, we proposed a requirement that customers must all have the opportunity to set deposit limits. To meet consumer choice, we proposed implementation guidance that operators could also continue to offer spend limits and/or loss limits.
For the avoidance of doubt, we also proposed to codify our expectation that the gambling system must prevent a customer from depositing, staking or spending (according to the type of limit set), or incurring further losses from the point at which the customer-set limit is reached, until the limit period ‘restarts’. Customers who wished to continue to deposit and/or gamble once their limit is reached would need to take proactive action to increase their limit, which would continue to be subject to the 24-hour cooling off period.
The Gambling Commission’s view was that offering a common type of financial limit across all operators would be beneficial for consumers in terms of improving understanding of how limits work, and would enable consumers to use the same type of limit across more than one account.
Consultation questions
To what extent do you agree with the proposal that the gambling system must offer deposit limits as a minimum?
To what extent do you agree with the proposal that the gambling licensees should continue to have the option to offer spend and/or loss limits, in order to maximise consumer choice?
To what extent do you agree with the proposed definition of spend limits as a tool “where the amount a customer spends on gambling (or specific gambling products) is restricted for the period/duration of the limit applied”, for the purpose of RTS 12 – Financial limits?
To what extent do you agree with the proposed definition of loss limits as a tool “where the amount lost is restricted, i.e. winnings subtracted from the amount spent for the period/duration of the limit applied”, for the purpose of RTS 12 – Financial limits?
Respondents’ views
The majority of respondents supported the proposals for a requirement for all operators to offer deposit limits and, in order to maximise consumer choice, retaining the implementation guidance that licensees could still offer spend and/or loss limits, in addition to deposit limits.
However, in their comments, a significant number of gambling industry respondents were strongly of the view that they should be able to retain the ability to offer ‘net deposit limits’ as a form of deposit limits for the purposes of compliance with the RTS.
Support for agreeing with the definitions of spend and loss limits was more mixed, and we received feedback related to how calculations of loss would be made in relation to settled bets, treatment of bonus funds in relation to financial limits, and links to definitions of net loss for the purposes of financial risk assessments.
Our position
Through analysis of the responses to this consultation, consumer feedback and engagement with industry, it has become clear that financial limits, in particular deposit limits, are being interpreted by operators in different ways.
Some operators are continuing to offer ‘gross’ or ‘regular’ deposit limits that prevent a customer from depositing further monies into their account for the remainder of the duration of the limit, once their limit is met. This represents how ‘deposit limit’ has been interpreted in common practice since RTS 12 – Financial limits was introduced.
Some operators are now offering what they term ‘net deposit limits’, where any funds withdrawn during the period are automatically offset against the customer-set deposit limit, allowing the customer to deposit in excess of the deposit limit, up to the total value of the limit plus the total value of withdrawals made in the period.
Some operators are offering net deposit limits in addition to gross deposit limits, and some operators have stopped offering ‘gross’ deposit limits in favour of net deposit limits.
We think this may be confusing for customers and we have received a number of complaints from consumers about this practice, in particular from customers who had previously chosen to place a gross deposit limit on their account, but this had been ‘switched’ to a net deposit limit by the operator.
Importantly, the ‘net deposit limits’ offered by some operators are not consistent with the definition of ‘deposit limits’ in the current RTS implementation guidance 12A, or that proposed as a requirement in the consultation.
We are of the view that stakeholders may not have fully considered these different types of ‘deposit limit’ when submitting their original responses. In particular, non-industry respondents may not have considered the distinctions between gross and net deposit limits, and the support for this proposal from industry respondents was largely conditional on ‘net deposit limits’ falling within the deposit limit definition.
It is important that deposit limits are offered to consumers in a transparent way with some consistency between operators. We will publish a supplementary consultation to further consider the different definitions of financial limits with a view to supporting transparency and consistency to consumers.
Last updated: 4 February 2025
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