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 2 – Seeking views on cross-operator deposit limits
Call for views
The overall aim of proposals which were put forward for consultation under issue 1 was to help all consumers to stay in control of their gambling, by creating and maintaining improved awareness of spend and encouraging the use of tools such as financial limits which promote this, and the proposals were designed to improve protections for all gamblers at the gambling account level.
Under issue 2, we also explored the role of the use of deposit limits across operators, as part of the wider context of pre-commitment tools for consumers, and we invited stakeholders’ views on the topic of cross-operator deposit limits, in particular evidence which could help us understand the effectiveness of this approach in preventing harm and the impact on consumers.
Questions
Do you have any evidence of the effectiveness of cross-operator deposit limits in reducing gambling harm?
How do you think cross-operator deposit limits could work in the future, within the context of our regulatory framework?
Do you have anything further you wish to add about cross-operator deposit limits?
Respondents’ views
Respondents suggested that they believed that there is currently no substantial evidence to support the effectiveness of cross-operator deposit limits in mitigating gambling related harm, with the majority of feedback opposing its implementation.
While there has been discussion around the introduction of cross-operator deposit limits in other jurisdictions, respondents felt these initiatives were still in their infancy, leaving their impact unproven. Alternative suggestions included exploring and monitoring the progress of solutions through financial institutions before considering the adoption of cross-operator deposit limits.
Responses to the question of how cross-operator deposit limits could function within the current framework revealed several challenges.
Respondents described the need for better consumer tools to track spending across operators, warning that without them, the system might favour operators over consumers. Suggestions were also made to involve an independent organisation with expertise in gambling harm to oversee account and deposit management, alongside a centralised deposit limit system that balances privacy through limited data sharing. On a related point privacy concerns particularly regarding data protection were highlighted as potential obstacles.
Some respondents cautioned that cross-operator deposit limits could potentially create competitive imbalances favouring larger operators and complicate the customer experience, possibly driving users to unlicensed platforms.
On the whole, respondents commented that successful implementation would require robust consumer education and strong regulatory enforcement to ensure fairness and efficiency.
Our position
The feedback received has not identified material new evidence regarding the effectiveness of cross-operator deposit limits in reducing gambling harm and we note the suggestions made about how cross-operator deposit limits could work in the future, within the context of our regulatory framework.
We are not planning immediate further action following this call for views. However, we will continue to monitor the role of gambling financial limits within the financial sector in the context of any potential future role cross-operator deposit limits could play in helping consumers to stay in control of their gambling.
Last updated: 4 February 2025
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