Consultation response
Definition of deposit limits in the Remote Gambling and Software Technical Standards - Response
This response sets out our position in relation to the consultation on the definition of deposit limits in the Remote Gambling and Software Technical Standards.
Evaluating the impact of relevant changes
The Gambling Commission works to assess progress towards the key commitments set out in our Corporate Strategy. This includes increasing our capacity to evaluate new requirements and policies, with particular focus on the commitments we are responsible for in the Gambling Act Review White Paper (opens in new tab) (white paper) and supporting efforts by government and others to evaluate the impact of the white paper reforms.
The evaluation of the changes set out in the supplementary consultation response will be embedded in the overall evaluation of the customer-led tool changes as detailed in the Autumn 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response - Customer-led tools - Consultation Response.
Equalities impact assessment
We are committed to giving consideration to potential equalities impacts, having regard to the need to eliminate discrimination, advance equality of opportunity and foster good relations between those who share a protected characteristic and those who do not. Our position as a result of the initial assessment was set out in both our initial and supplementary consultation was that the Commission does not currently consider that the proposals set out in this consultation give rise to known negative impacts in the context of the policy objectives.
At the time of our initial and supplementary consultations, our assessment was that the proposals:
- did not impact negatively on the protected characteristics stated within the Equality Act 2010
- did not contribute towards unlawful discrimination, harassment or victimisation and/or other conduct prohibited by the Act
- did not reduce equality of opportunity between those who share a protected characteristic and those who do not share it
- did not foster poor relations between people who share a protected characteristic and people who do not share it.
In our initial consultation we asked respondents for any evidence or information which might assist the Commission in considering any equalities impacts of those proposals. We received a small number of responses to help inform the next stage of our assessment in relation to specific proposals which do not form part of this supplementary consultation.
These included concerns around neurodivergence and processing or understanding information as well as responses to alerts consideration of cognisance of information for non-English speakers and other vulnerable groups more generally.
Through the supplementary consultation we asked again for evidence or information which might assist the Commission in considering any equalities impacts. We received information from one respondent making a general comment that operators must ensure that customers with learning disabilities must be able to access materials to help them understand their chosen limits.
In our initial consultation we proposed a series of amendments to the wording of requirements and implementation guidance, to reinforce our expectation that information should be easily understood and accessible by all customers. As a result of our analysis following the initial consultation and consideration of feedback provided to the supplementary consultation we consider that the changes being made improve the design, presentation and access to financial limits as a customer-led pre-commitment tool. They are intended to support all consumers who wish to make use of these tools to help them actively manage their gambling in ways that work for them.
The Commission monitors data sources, such as complaints and/or consumer contacts and compliance assessment findings to understand issues that might bring risks to consumers and would consider further action in response to increased risk to consumers.
Business impact and implementation
We asked respondents to provide information about implementation and an estimate of the direct costs associated with implementing the proposals. Responses to this question highlighted:
- that switching ‘gross’ deposit limits back on will require substantial technical work involved to either roll back changes developed but not yet released to customers or to build the technical functionality to create ‘gross’ deposit limits where this functionality does not currently exist. Some operators stated that they considered that it would take until approximately Summer 2026 for both changes to be fully completed
- that renaming the definitions will also involve extensive technical work on gambling systems
- the cost and time impacts related to renaming limits and ensuring comprehension amongst customers.
We have taken into account feedback from industry stakeholders about the estimated length of time it may take to implement the requirements. We are aware that the timeframe for implementation will vary and will depend on the extent and the complexity of the changes to be made by each operator. In determining an implementation period for the proposals in this consultation we have also considered the timings of the other implementation dates set out by the Commission. Therefore, we consider it proportionate in this instance for all the changes set out in this document to be implemented no later than 30 June 2026.
For clarity we do not expect existing customers to be changed back to using ‘gross’ deposit limits on the implementation date. We expect:
- new customers from the 30 June 2026 to be offered ‘gross’ deposit limits which must use the term 'deposit limit' alongside any other types of financial limit that operators may offer at sign up and those other limits may not use the term 'deposit limit'
- ‘gross’ deposit limits and any other types of financial limits offered by operators to be made available to existing customers from 30 June 2026 and at the relevant prompted review points required under RTS requirement 12D (from 31 October 2025) – ‘The gambling system must provide a prompt to customers to review their own account and transaction information, as is currently made available under RTS 1 – Customer account information. This must be provided at a minimum of six-month intervals for accounts with activity within a rolling 12-month period. Customers must be provided with facilities to set more frequent reminders to receive this statement and review their limits’.
Definition of deposit limits in the RTS - Summary of responses and our position Next section
Annex 1 - Definition of deposit limits in the Remote Gambling and Software Technical Standards
Last updated: 7 October 2025
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