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 2: The application of the term and definition of a deposit limit
To ensure that the term ‘deposit limit’ was used consistently by operators we proposed that only limits meeting the definition of gross deposit limits can be called ‘deposit limits’ and that gross deposit limits must be called deposit limits.
The intention behind this proposal was to improve clarity for the consumer and consistency across the industry.
Consultation question
To what extent do you agree with the proposal that only limits that meet the definition of gross deposit limits can be referred to as a deposit limit?
Consultation question
To what extent do you agree with the proposal that limits that meet the definition of gross deposit limits must be described to a customer as a deposit limit?
Respondents’ views
Respondents had mixed views when asked to what extent they agreed with the proposal that only limits that meet the definition of gross deposit limits can be referred to as a deposit limit.
Respondents who were in favour of the proposal stated that it would help provide increased consistency and transparency for consumers. Some respondents also raised comments that ‘gross limits’ were more aligned to the objective of setting a ‘maximum’ limit.
Respondents who disagreed with the proposal stated that preventing operators from being able to refer to ‘net’ limits as ‘net deposit limits’ is likely to result in confusion because they considered that customers already have a strong comprehension of what the term ‘net deposit limits’ means. Respondents expressed the view that any shift in language without adequate explanation may be perceived as a reduction in flexibility or may result in misinterpretation of how the limits function in practice.
Other comments included that ‘gross’ deposit limits should not be described to customers simply as ‘deposit limits’ as this could also be confusing to consumers as any reference to deposit limits must be accompanied by clear explanations of what is being limited, whether gross or net. Respondents also highlighted the importance of offering a range of limits to maintain consumer choice and urged the Gambling Commission to retain flexibility in how deposit limits are defined to ensure that consumer choice is maximised.
Some operators and a trade body suggested that in order to provide increased consistency and customer understanding, the Commission should consider renaming ‘net’ deposit limits to spend limits.
Respondents suggested that operators should be required to provide simple language and terminology. Suggestions included that the terms 'gross’ deposit limits and 'net’ deposit limits' or ‘spend limits’ should be used rather than tying one concept to the general term ‘deposit limits’, to remove any potential confusion for consumers and improve clarity for operators.
Our position
We have considered the comments and concerns raised by stakeholders in the consultation responses.
We will proceed with the proposal that only limits that meet the definition set out in RTS 12B can be referred to as a deposit limit, and limits meeting this definition must be described to a customer as a deposit limit.
We maintain the view that deposit limits have been consistently available in the remote gambling system for a considerable length of time, and for most of that period have typically been considered a limit on the amount of deposits into an account, without reference to anything else such as withdrawals. ‘Gross’ deposit limits have historically been most commonly offered by gambling licensees and more evidence of usage and participation in deposit limits is available, compared to other types of limits.
To address concerns about customer comprehension of deposit limits we are of the view that operators must ensure that they provide clear and easy to understand information to customers.
We agree with the points made regarding the importance of providing and maintaining consumer choice in this space and acknowledge that ‘net deposit limits’ have a place in the remote gambling system. Our position on this is set out in proposal 3.
Final wording
This requirement will come into force on 30 June 2026.
Applies to: All gambling – except subscription lotteries.
RTS requirement 12B
Only limits that meet this definition can be referred to as a deposit limit, and limits meeting this definition must be described to a customer as a deposit limit.
Proposal 1: As a minimum and default ‘gross’ deposit limits must be offered to the customer Next section
Proposal 3: Wording of financial limits in the implementation guidance including the introduction of ‘net’ deposit limits
Last updated: 7 October 2025
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