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
Summary of the consultation on customer-led tools
The 2023 White Paper, High stakes: gambling reform for the digital age (opens in new tab)(white paper) set out the Gambling Commission’s commitment that we would review and consult on requiring operators to improve player-centric tools like financial limits and activity statements, such as by making deposit-setting mandatory or opted in by default.
In November 2023, we launched our consultation on proposals to improve player centric tools (opens in new tab). The proposed changes would be delivered through revisions to Remote gambling and software technical standard 12 – Financial limits (RTS 12), in the form of:
- relatively minor changes to the current RTS wording
- ‘elevating’ some parts of the current implementation guidance to requirements
- introducing new requirements and implementation guidance.
The consultation had the following policy intentions:
- to reduce the risk of customers setting meaningless financial limits
- to improve consistency and understanding of the types of limits offered, while maintaining consumer choice
- to reduce friction and increase accessibility and visibility of limit-setting facilities
- to improve awareness of and engagement with information about account activity, and
- changing how limits are presented and offered to increase the number of customers applying financial limits to their accounts.
We have decided to proceed with the majority of the proposals set out in the consultation. However, we have considered the feedback and not all of the proposals will proceed to implementation as set out in the consultation
The following provisions will be implemented as set out in the consultation, subject to some minor amendments to the wording of the provisions following consultation feedback:
RTS requirements 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
- financial limits must only be offered using free text
- financial limits must be applied at the account level
- financial limit setting facilities must be provided via a link on the homepage and deposit pages and/or screen and clearly visible and accessible, and the number of clicks and/or pages that must be navigated to reach these facilities must be minimised
- all customer requests to decrease a financial limit must be actioned immediately
- strengthen the wording of the current requirements around actioning customer requests to increase limits.
RTS implementation guidance that:
- operators could also offer links to tools or resources to support limit-setting
- operators could also continue to offer financial limits at the product or channel level
- operators should clearly communicate to customers how product and channel limits work
- operators should inform customers about how limits set across multiple timeframes work, if chosen by the customer
- links to limit-setting facilities from communications to customers should link directly to the facilities unless security settings require an intermediate log in
- operators should inform customers when limits will take effect, if that is not already automated or is delayed due to technical issues.
The following are new or revised provisions as a result of stakeholder feedback during the consultation:
- a new requirement that customers must receive a prompt to review their account and transaction information
- a new requirement that this prompt must be provided at a minimum of 6-monthly intervals
- a new requirement that customers should be able to set more frequent reminders to review their account information
- new implementation guidance that operators should monitor engagement with prompts and/or alerts to customers to review account activity, in order to inform best practice
- new implementation guidance that operators could mitigate against user error by enabling the gambling system to only receive specific monetary increments for free text limits.
In addition, we consulted on 2 options regarding whether all new accounts must have financial limits applied or have limit-setting presented as the default option, with the ability for customers to opt-out. We are implementing option 1 – a new requirement and implementation guidance which allows new customers to opt out of setting a limit, but that limit-setting is to be presented as the default option for customers. We are also introducing additional new implementation guidance to support this requirement.
The following consultation proposals will not be implemented:
- the consultation proposal to introduce implementation guidance that operators should determine whether customers holding multiple accounts wish to apply limits across all accounts held within the parent company
- the consultation proposal for new implementation guidance that operators should alert customers when approaching their limits.
The outcomes of the proposals set out in this response will form part of a revised RTS 12 which will come into effect on 31 October 2025.
The consultation made proposals that customers must all have the opportunity to set deposit limits, and that operators could also continue to offer other types of financial limits such as spend limits or loss limits.
During the consultation it became clear that the way in which operators are interpreting 'deposit limits' has recently changed, and a number of operators had recently introduced ‘net deposit limits’. Our view is that net deposit limits do not meet the definition of ‘deposit limit’ in the current RTS implementation guidance or proposed as requirements in this consultation. We are also of the view that stakeholders may not have fully considered these different types of ‘deposit limit’ when submitting their original responses.
We will shortly publish a short supplementary consultation to reiterate and seek views on the definition proposed, that it is ‘gross deposit limits’ that must be offered by all operators, and implementation guidance that other types of financial limit – such as net deposit limits – could also be offered to customers. This would support consistency and transparency to consumers but still offer customer choice.
Last updated: 17 February 2025
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