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.
Contents
- Executive summary
- Summary of topics
- Customer-led tools - Consultation Response
- Improved transparency on customer funds in the event of insolvency - Consultation Response
- Removing obsolete Gambling Commission requirements due to the government's upcoming statutory levy - Consultation Response
- Evaluating the impact of relevant changes
- Annex
Issue 3 – Seeking views on artificial barriers to consumer choice
Call for views
Under issue 3 we asked for examples or evidence of situations where the product architecture and design of gambling facilities could create an imbalance in the gambling licensees’ favour and drive consumer behaviour which may not be in their best interests.
Question
Do you have examples or evidence of situations where the architecture and design of gambling facilities creates an imbalance in the gambling licensees’ favour and drives consumer behaviour which may not be in their best interests?
Respondents’ views
The responses received noted similar concerns to those raised in response to the call for evidence to support the Gambling Act Review. Examples provided by respondents included:
- presentation of information about gambling products (stakes and/or odds, repeat bet functionality, speed of play) can be difficult to access and understand
- account closure information can be unclear and difficult to access
- experience of friction when trying to withdraw account funds. Experiences include withdrawal processes being too lengthy, having to contact customer services to withdraw funds of a certain amount, or imposition of minimum withdrawal amounts
- pre-populated default values on deposit pages that require the customer to override and populate with their own value can be perceived as trying to drive behaviour in a particular direction
- losses disguised as near wins were also highlighted as an area of concern for stakeholders.
Our position
Feedback from stakeholders to this question has confirmed our concerns regarding specific points in the customer journey and the design of facilities where friction is applied which could influence consumer behaviours or actions. In this consultation on customer-led tools we have addressed concerns around ‘anchoring’ when setting financial limits, and shifting or removing friction to make it easier for more customers to set and review limits and to access information about their own gambling activity.
Our corporate strategy 2024 to 2027 sets out our commitment to improve our understanding of issues which pose a risk to the fair and open licensing objective, including understanding consumer concerns, improving information to players and ensuring the fairness of gambling products. We will continue to take into account the feedback provided around fairness and transparency at various points in the customer journey as part of that work, communicate any further action on these issues in due course, and will continue to monitor developments relating to choice architecture and the design of gambling facilities.
Last updated: 4 February 2025
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