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 (ii) - Reviewing limits and feedback on gambling activity: reminders when approaching limits
Proposal
We consulted on a proposal for implementation guidance that operators should alert customers when they were approaching their limit. As part of the proposal, we sought views on how close the customer’s spend should get to their limit to prompt the alert, as well as evidence to support this.
In setting out the proposal, we acknowledged that there was limited evidence around the optimum time for customers to be alerted to the fact that they are approaching their limits, or whether this differed depending on the type of limit or duration for which the limit is set.
Consultation questions
To what extent do you agree with the proposed implementation guidance that gambling licensees should alert customers when they are approaching their limits?
Do you have any evidence to offer regarding the optimum point when approaching a limit that a customer should receive an alert?
Respondents’ views
Support for this proposal was mixed and there was some commonality in the reasons why respondents either did or did not agree with the proposals, along the following themes:
alerts in advance were preferable to gambling being stopped without warning when a limit is reached, such as during play and/or in a ‘hot state’
advance alerts offer an opportunity to consider actions, slow down or review limits, as they draw awareness to potential risk of harm. This was noted as both a positive and negative issue, as alerts too far in advance could lead to customers increasing their limits ahead of hitting them and negating the benefits of the 24 hour cooling off period
some support and evidence on the benefits of pop-up messages and alerts, although concerns about the content and how alerts would be delivered to avoid creating a sense of urgency or panic about running out of funds
we received evidence that suggested 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
a number of respondents suggested real time information about activity and public health-led messaging would be more effective than alerts when approaching limits
the design of some kinds of limits, such as loss limits or net deposit limits, mean that the amount left before hitting a limit can be dynamic, due to continued staking activity or placed but not settled bets. This presents challenges for calculating the point at which an alert should be sent, and could cause confusion for consumers
a number of respondents noted that more research was needed before being able to reach a position on this issue.
In response to our question seeking evidence on the optimum point at which an alert should be sent, a number did offer views, including a suggestion that earlier alerts would be more likely to lead to a slowing down of activity, while others noted that being alerted when very close to a limit would be more likely to induce ‘panic’ behaviours.
Our position
Our analysis of responses suggests that in some cases, alerts of approaching limits may be useful, but that in others this could have unintended consequences, such as prompting an increase to a limit ahead of hitting it. We received little additional evidence relating to this proposal, and it is likely that alerts when approaching a limit may be more or less effective depending on a number of factors such as the time frame or duration of the limit, type of limit, and type of gambling product.
We received evidence that suggested 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 neurodiverse consumers.
While there is some evidence from other jurisdictions (or could be taken from industries such as banking) that alerts about approaching limits could prevent excessive spending in the future, we consider overall there are too many uncertainties and therefore not enough clear evidence to support implementation at this point.
However, we think this is an area in which there is potential for further work in the form of research, trials and evaluation, and we would welcome this.
We are not proceeding with the proposal for implementation guidance that operators should alert a customer when they were approaching their financial limit at this time.
Last updated: 4 February 2025
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