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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 1d - Increasing visibility and reducing friction in accessing customer-led tools

Proposals

We consulted on the following proposals:

  • a requirement that financial limit setting facilities must be provided via a link on the homepage and clearly visible and accessible. This was a proposed elevation of current implementation guidance to a requirement

  • a requirement that financial limit setting facilities must be provided on or via a link on deposit pages and/or screens and clearly visible and accessible. This was a proposed elevation of current implementation guidance to a requirement.

  • to support ‘clearly visible and accessible’ we proposed additional new wording to the remote gambling and software technical standards (RTS) requirement, regarding minimising the number of clicks and/or pages that must be navigated to reach these facilities

  • new implementation guidance that links to limit-setting facilities from communications should link directly to the facilities unless security settings require an intermediate log in.

Consultation questions

To what extent do you agree with the proposal that financial limit facilities must be provided via link on the homepage and clearly visible and accessible?

To what extent do you agree with the proposal that financial limit facilities must be provided on or via link on deposit pages/screens and clearly visible and accessible?

To what extent do you agree with the proposal that links to limit setting facilities from communications should link directly to the facilities unless security settings require an intermediate log in?

Respondents’ views

In relation to the proposed requirement that financial limit setting facilities must be provided via a link on the homepage and on deposit pages or screens and clearly visible and accessible, the majority of respondents supported these proposals.

Respondents were supportive of reducing friction and the additional wording proposed, and some noted that financial limits should have equal prominence as placing bets and promotional content. Comments also included requesting the Gambling Commission tighten the requirement further, such as stipulating maximum steps or clicks, and noting that increasing the salience of limit-setting tools could reduce stigma associated with their use.

In relation to the proposed implementation guidance, the majority of respondents supported this proposal. Responses largely supported the intent to reduce friction, increase consumer empowerment and make limit-setting a more prominent part of the customer journey. However, a minority of respondents cited technical difficulties and expressed concerns that the proposal would breach information security and data privacy regulations and requirements and suggested linking to safer gambling information pages as an alternative.

Our position

We welcome the support for these proposals and the approach we have taken to reduce friction in the customer journey. It would be possible to define the number of steps, clicks or other design elements on how information is displayed. However, our view is that the final wording makes clear our expectations such as direct links to information and that further definition does not appear necessary at this time.

Where respondents have called for us to go further by not allowing new customers to be exposed to free bets and promotions while setting limits, this is addressed in the Licence Conditions and Codes of Practice (LCCP) ordinary code provision 5.1.10 - Online marketing in proximity to information on responsible gambling.

Regarding the proposal for implementation guidance that links to limit-setting facilities from communications should link directly to those facilities, whilst the majority of respondents have responded positively to this proposal, concerns were raised about technical implementation and information security.

In terms of information security, the proposal included the point ‘unless required by account log in security settings’. We did not propose that links from communications provide a way to access accounts that would circumvent or bypass these security settings. Our intention is, where a hyperlink to limit setting facilities is embedded in an email or other communication, the recipient is able to reach those facilities using the shortest route possible, with the minimum of friction, and not be diverted via intermediate pages or layers of information that may distract the customer from their original intention.

We are proceeding with the introduction of the requirements and implementation guidance.

Final wording

This requirement will come into force on 31 October 2025.

Applies to: All gambling – except subscription lotteries.

RTS requirement 12C

Financial limit facilities must be provided via a direct link on the homepage and be clearly visible and accessible.

Financial limit facilities must be clearly visible and accessible on deposit pages/screens or via a direct link on these pages or screens.

The gambling system must minimise the number of clicks or pages customers make in order to access financial limit facilities.

RTS implementation guidance 12C

Links to limit-setting facilities from communications such as emails or notifications should link directly to the facilities and not via a home page or other intermediate page(s), unless required by account log in security settings.

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