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 1a and 1b - Enabling consumers to determine their own limits at registration and/or first deposit and onwards
Proposals
We proposed:
- a requirement that all customers must be prompted to set a financial limit as early as possible and be able to set limits at any point thereafter. This was a combination of an amendment to a current requirement and an elevation of current implementation guidance to a requirement
- a new requirement that financial limits must only be offered using free text
- new implementation guidance that operators could also offer links to tools or resources to support limit-setting.
Consultation questions
To what extent do you agree with the proposal that offering facilities to set limits should be a requirement rather than implementation guidance?
To what extent do you agree with the proposal that for access media (such as interactive TV) limits must only be offered to consumers using free text?
To what extent do you agree with the proposal that implementation guidance states that operators could provide links to tools or resources to support limit setting as part of the process?
Respondents’ views
Regarding the proposed changes to offering financial limits at registration or first deposit and making them available at any point thereafter, the majority of respondents agreed with this proposal. Of respondents who were not in favour, a small number were against financial limits in any form, and others thought the proposals should go further, such as maximum limits being pre-determined by the Gambling Commission.
In relation to using free text as the only format for financial limits to be offered, the majority of respondents agreed with this proposal, although some respondents suggested that operators should have flexibility in how they present limit-setting facilities, such as continuing to offer ‘sliders’ or drop-down lists in addition to or instead of free text. Disagreement with the proposal was largely around avoidance of user error and need for data validation.
In relation to the proposed implementation guidance that operators could also offer links to tools or resources to support limit-setting, the majority of respondents supported the proposal. Respondents cautioned against this information adding friction to the customer journey, which could potentially discourage customers from setting a limit. Others raised questions about whether information would be required to be embedded in operator websites or via external links and commented on the need for research on appropriate messaging and presentation.
Our position
We welcome the support for the proposed requirements, and we note that a number of operators already offer financial limits using free text.
Regarding the use of ‘free text’ only for customer-set financial limits, this is a topic which has had limited gambling-specific research conducted, although there have been a wide range of studies looking at the role of anchoring in nudging consumer decision-making, leading to decisions that can be detrimental to consumer benefit. While we acknowledge that this area would benefit from further gambling-specific research and evaluation to better understand the link between the presentation of financial limits and the resulting levels set, we have drawn on evidence from related fields to inform the position that free text is the current optimum method to ensure that consumers are not influenced by external factors when deciding on the appropriate limit for them.
We do not agree that operators should have the flexibility to offer limits using drop downs, sliders or similar, either instead of or alongside free text. While we acknowledge that this could offer more choice to consumers whether to choose for themselves or from options offered, we consider that:
- the appropriate high and/or low point will vary for each customer
- offering multiple ways to set limits would itself add friction to the customer journey, which could discourage customers from setting limits at all.
We accept that a completely free choice box does carry a small risk that when setting limits customers may make errors or input non-whole numbers, which could be technically difficult to administer. We consider it reasonable for operators to be able to stipulate increments or multiples, for example multiples of £5, or programme the field to only receive integers or ‘whole amounts’, as a mitigation against this, as long as this in itself does not nudge customers or anchor their decisions in any material way. We therefore are introducing new implementation guidance that was not included in the consultation proposals but is a direct response to feedback during the consultation.
We also proposed to introduce implementation guidance that operators could provide links to tools or resources to inform budgeting and aid customers in setting appropriate limits, as part of the limit-setting process, so that consumers who want to access and make use of those tools to help them decide on their limits can do so easily. A number of operators already provide links to such tools or resources.
We agree with the need for this information to sit outside the customer journey and not present further friction, and that customers should not be distracted from the process of limit setting by accessing this type of information.
In finalising the wording for this requirement, we have also made minor amendments to update and clarify some of the language in the remote gambling and software technical standards (RTS).
We are proceeding with introduction of these proposals and additional implementation guidance.
Final wording
This requirement will come into force on 31 October 2025.
Applies to: All gambling – except subscription lotteries.
RTS requirement 12A
The gambling system must provide easily accessible facilities for customers to set their own financial limits at any time from the point of registration.
Customers must be prompted to set a limit as part of the registration process or at the point at which the customer makes the first deposit or payment. The limit must be implemented as soon as practicable after the customer’s request. The customer must be informed when the limit will come into force.
RTS requirement 12B
Customers must be presented with a ‘free text’ box to set a limit, or the equivalent in the case of telephone gambling.
RTS implementation guidance 12B
Operators could provide links to tools or resources to inform budgeting and aid customers in determining appropriate limits for their personal circumstances.
In order to mitigate against user error, the gambling system could permit specific monetary increments for limits, such as whole pounds.
Last updated: 4 February 2025
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