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.
Proposal 1: As a minimum and default ‘gross’ deposit limits must be offered to the customer
We proposed to revise the Remote Gambling and Software Technical Standards (RTS) relating to financial limits so that, as a minimum and default, ‘gross’ deposit limits must be offered to customers.
The intention behind this proposal was to improve consistency across the industry, to simplify the landscape for consumers. Our view was that offering a common type of financial limit across all gambling licensees would also be beneficial for consumers in terms of improving understanding of how limits work.
Consultation questions relating to offering ‘gross’ deposit limits as a minimum and default
To what extent do you agree with the proposal that as a minimum, the gambling system must offer gross deposit limits?
Respondents’ views
Respondent views were mixed when asked the extent to which they agreed with the proposal that as a minimum and default, the gambling system must offer gross deposit limits. Those who were supportive of the proposal stated that:
- ‘gross’ deposit limits should be offered as the ‘default’ option as it’s an established and easily understood type of financial limit. It would also provide clarity and consistency across operators, potentially making the customer journey simpler and could help customers to understand financial limits better
- ‘net’ deposit limits were perceived by some respondents as harmful and designed so that operators can get back customer winnings, thereby potentially encouraging people to spend more than the limits they had set
- some respondents commented that ‘net’ deposit limits felt misleading to consumers and that they allowed for continued depositing which may undermine the intention behind setting a deposit limit
- some respondents also described feeling that ‘net’ deposit limits were being ‘forced’ on customers by operators.
Respondents who disagreed with the proposal were generally supportive of a limit being offered as a default option but did not think it appropriate for ‘gross’ deposit limits to be mandated over ‘net’ deposit limits.
Respondents also highlighted that offering ‘gross’ deposit limits as a ‘default’ limit could reduce consumer choice and potentially phase out ‘net’ deposit limits from the market. Some respondents stated that ‘gross’ deposit limits may no longer be fit for purpose as they are not agile with ‘real world’ budgeting.
Those who disagreed with the proposal also called for ‘net’ deposit limits to be set as the ‘default’ option, arguing that such limits are:
- easier for users to understand as consumer comprehension of ‘net’ deposit limits is high
- more aligned with actual risk and financial harm and therefore a more accurate representation of a customer's spend and budgeting behaviour
- more dynamic than ‘gross’ deposit limits, with opportunities to include more advanced features such as personalised harm reduction prompts, data-driven alerts when a user’s net losses deviate from typical patterns and smarter use of financial vulnerability checks and safer gambling tools.
It was also argued that the faster withdrawal functionality offered by licensees means that more customers are withdrawing more often. Therefore, if ‘gross’ deposit limits were mandated, an unintended consequence would potentially be that it may discourage customers from withdrawing because they would not be able to redeposit any money if they had already reached their ‘gross’ deposit limit. Some respondents stated that this friction may potentially drive customers to the black market. Respondents stated that there was no evidence to suggest that ‘gross’ deposit limits were more effective than ‘net’ deposit limits in reducing gambling harms. Another respondent stated that the Gambling Commission hadn’t evidenced non-compliance with the RTS.
Our position
The intention behind this proposal was to improve consistency across the industry and simplify the landscape for consumers. We remain of the view that a common type of financial limit being available across all gambling licensees would be beneficial for consumers in terms of improving understanding of how limits work and would enable consumers to use the same type of limit across more than one account.
We therefore want to ensure that the definition of ‘deposit limits’ in the RTS provides clarity and drives consistency for consumers while maintaining customer choice for other forms of limits. As set out in our consultation, our policy intent was that ‘gross’ deposit limits must still be made available to customers as the default option to ensure ‘gross’ deposit limits were still an option for customers when setting a limit and were not phased out of the market or given reduced prominence, which would otherwise reduce consumer choice.
We have considered the responses to the consultation and in support of consumer choice we have decided to use ‘as a minimum, the gambling system must offer gross deposit limits’ and not ‘as a default’ as we do not feel there is adequate evidence to support the use of ‘as a default’ at this time. We also agree with the points made in the responses to the consultation that different types of financial limits may suit individual customers better.
Therefore, we amended the following wording in response to the feedback we received:
- 'as a default, the gambling system must offer gross deposit limits - where the amount a customer deposits into their account is limited over a particular duration’ to:
- 'as a minimum, the gambling system must offer gross deposit limits - where the amount a customer deposits into their account is limited over a particular duration’.
By amending ‘default’ to ‘as a minimum’ we want to ensure that gross limits are not ‘hidden’ or given less prominence than other types of limits that operators may prefer customers to take up.
To support our original policy intention to ensure that ‘gross’ deposit limits must be offered to customers the following wording has been included in the requirement:
- where more than one type of limit is made available in the gambling system, operators must ensure that ‘gross’ deposit limits are offered to customers with at least equal prominence to other limit types.
Final wording
This requirement will come into force on 30 June 2026.
Applies to: All gambling – except subscription lotteries.
RTS requirement 12B
- As a minimum, the gambling system must offer gross deposit limits - where the amount a customer deposits into their account is limited over a particular duration.
- Where more than one type of limit is made available in the gambling system operators must ensure that ‘gross’ deposit limits are offered to customers with at least equal prominence to other limit types.
Questions previously set out in the Autumn 2023 consultation
In the supplementary consultation we asked again for views regarding the proposed wording set out in the Autumn 2023 consultation regarding:
- when a customer has set a deposit limit with simultaneous time frames the lowest limit should apply
- the gambling system must prevent a customer from further depositing funds once a deposit limit is reached, until the defined period of the limit restarts or the customer takes action to increase the limit (subject to standard 24 hour cooling off period).
We asked again for views in the supplementary consultation because these items are linked to how a deposit limit works in the requirements.
Simultaneous time frames
Consultation questions relating to the Autumn 2023 consultation
Do you have any comments on the proposed wording regarding simultaneous time frames?
Respondents’ views
Through this consultation we sought comments from stakeholders on the proposed wording regarding simultaneous time frames. The majority of respondents to this question were either supportive of the proposed wording or did not provide any additional comments. Respondents who were supportive of the proposed wording stated that it was reasonable, clear, consistent with consumer protection goals and avoids inadvertent overspending due to overlapping caps. Those who were supportive also commented on the need for consistency and clarity to be provided by operators when explaining to customers how simultaneous time frames work. Some respondents asked for the Commission to go further with its proposed wording by:
- adding in a caveat that operator enforced limits should also be taken into account where the minimum will always apply
- further refining the wording to ensure users fully understand how simultaneous limits work, and systems should be designed to explain and enforce these rules in a transparent, user-friendly manner
- changing 'lowest limit' to 'most restrictive limit' to remove the risk of combinations of limits inadvertently meaning the lowest value is cumulatively higher (for example: a £10 daily limit met over 7 days is higher than a £50 weekly limit).
Some respondents commented that many operators offer limits on the basis of a calendar time frame, as well as those who offer it on a rolling time frame and proposed wording to include rolling or calendar timeframes for example 'rolling 24 hours OR calendar day’ in the RTS.
Our position
We have considered the comments raised by stakeholders in the consultation responses. In response to the feedback provided to us following the supplementary consultation we will proceed with wording which states that the most restrictive limit must always apply.
We acknowledge the comments made about operator enforced limits and taking the proposed wording of the requirement further to ensure that customers should fully understand how limits set over simultaneous time frames work. The Commission expects all operators to clearly communicate the terms of financial limits to customers so that the impact of simultaneous timeframes on their chosen limit is clearly understood.
We also note the points made by respondents in respect of rolling and calendar timeframes particularly in relation to how time periods may apply when the operator is trying to align when a customer sets a limit with their systems particularly when a limit is set mid-week.
Often a limit that is set mid-week would apply to either the calendar week or a set 7day period. For example, if a customer was to place a ‘7 day’ deposit limit on a Wednesday at 3:30pm, the customer may need to remember how many deposits they had made since the prior Wednesday at 3:30pm. From a customer’s perspective, this could be potentially difficult to calculate and could cause confusion since a limit set midweek do not align to the calendar week. Whereas, if a customer were to set a ‘7 day’ deposit limit on a Wednesday at 3:30pm, then the deposit limit would refresh at the beginning of the next calendar week, on the following Monday, and include all the deposits already made during that calendar week.
The wording in the RTS already allows for this example and we would expect that the operator clearly sets out to the customer how a limit would work when being aligned to a calendar week.
For clarity we do not consider that the wording in the RTS would cover ‘rolling’ time frames in examples where a period or duration continuously moves forward with time, rather than being fixed to a specific date range. This example of a rolling time frame would not be suitable for use with financial limits as it is not a defined period of time and would not meet the proposed requirement that 'the gambling system must prevent a customer from further depositing funds once a deposit limit is reached, until the defined period of the limit restarts or the customer takes action to increase the limit’.
We have decided not to make reference to rolling or calendar timeframes in the RTS at this time. We are of the view that the customer should be made aware of the start and end points by the operator when they set a limit. Providing this transparency upfront makes it clear to the customer how their limits work and negates the need to reference rolling or calendar timeframes as the period or duration applied has been made explicit to the customer.
Final wording
This requirement will come into force on 30 June 2026.
Applies to: All gambling – except subscription lotteries.
RTS requirement 12B
Where a customer sets simultaneous time frames, for example a daily deposit limit and a weekly limit, the most restrictive must always apply. Therefore, if a daily deposit limit of £10 and a weekly limit of £100 are both set then the maximum the system must allow to be deposited is £10 per day and £70 per week.
Consultation questions relating to the Autumn 2023 consultation
Further depositing by customers once a deposit limit is reached
Consultation questions relating the Autumn 2023 consultation
Do you have any comments regarding the proposed wording that “The gambling system must prevent a customer from further depositing funds once a deposit limit is reached, until the defined period of the limit restarts or the customer takes action to increase the limit.”?
Respondents’ views
The majority of respondents were either positive about the proposed wording or had no further comments to raise. Additional comments provided by respondents were in relation to:
- strengthening the provision by introducing a 7-day delay before any request to increase a deposit limit can take effect
- providing further clarity to whether the defined period refers to a rolling period, fixed calendar period or remains the choice of the operator.
Our position
We acknowledge the point made in relation to introducing a 7-day delay before any request to increase a deposit limit can take effect. We consider that a 24 hour period as an adequate delay to request an increase in these circumstances and that increasing this time period may potentially result in discouraging customers from setting a limit on their account.
As discussed under the simultaneous time frames section, we note the points made by respondents in respect of rolling and calendar timeframes particularly in relation to how monthly time periods may apply. However, at this time, we don’t plan to make reference to rolling or calendar timeframes in the RTS and expect that the start and end points of a financial limit should be made explicitly clear to a customer by the operator.
We have considered the comments raised by stakeholders in the consultation responses and will proceed with the wording set out in the supplementary consultation.
Final wording
This requirement will come into force on 30 June 2026.
Applies to: All gambling – except subscription lotteries.
RTS requirement 12B
The gambling system must prevent a customer from further depositing funds once a deposit limit is reached, until the defined period of the limit restarts or the customer takes action to increase the limit (subject to standard 24 hour cooling off period).
Proposal 2: The application of the term and definition of a deposit limit
Last updated: 7 October 2025
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