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 3: Wording of financial limits in the implementation guidance including the introduction of ‘net’ deposit limits
We proposed to introduce new implementation guidance to include ‘net’ deposit limits (termed as ‘net’ limits in the consultation) as another option for financial limits and make some minor amendments to the wording of definitions to help enhance customer understanding.
The intention behind this proposal was to provide increased consumer choice by amending the implementation guidance to allow for ‘net’ deposit limits in addition to other types of limits should operators choose to make them available.
Consultation questions
To what extent do you agree with the proposed definition of spend or stake limits for implementation guidance? “Where the amount a customer spends or stakes on gambling (or specific gambling products) is restricted for the period or duration of the limit applied”
Respondents’ views
Respondents’ opinions differed on these proposals. Those that agreed found the definition clear, straightforward and fit for purpose.
Those that disagreed raised questions about the use of the term 'stake' and some were concerned that using the terms 'spend and stake' together could cause confusion. There were comments asking for more clarity if using the term spend. Respondents also called for clarity about how things like unsettled wagers, ante-post bets, and paused or abandoned game rounds would be accounted for.
Suggestions from respondents on how this definition could be clearer included:
- spend limits could be referred to as stake limits because this would be more in line with gambling spending behaviour
- limits based on net deposits should be referred to as spend limits because this would align better with ‘real life’ spending and budgeting
- if this is intended to be a stake limit, they should be called stake or wager limits and the word spend should be removed from the definition
- stake limits are a good option to use as a standard for consumers as it would potentially stop them from staking more and could encourage withdrawals
Respondents were supportive of broader aims of limit setting tools and suggested that further guidance is provided to clarify how spend limits will work in various scenarios.
Consultation questions
To what extent do you agree with the proposed definition of loss limits for implementation guidance? “Where the amount lost is restricted, i.e. winnings subtracted from the amount lost for the period or duration of the limit applied.”
Respondents’ views
The majority of respondents agreed with the proposed definition of a loss limit The definition was described by those that agreed with the proposed wording as clear, understandable and appropriate. Some respondents asked for more clarity around the application of such limits in respect of bonus funds.
Some of the respondents that disagreed described the definition as overcomplicated and unclear, while some offered alternative definitions.
A number of respondents neither agreed nor disagreed, and of those some of them asked for more clarity in the definition.
Feedback provided by respondents included:
- requests for clarification on whether betting incentives such as bonus funds or free bets are included or excluded in the calculation of loss limits, to ensure consistent interpretation across operators
- operators should be required to explain how these limits work to customers
- further clarity is needed on what is meant by ‘the amount lost’, as the definition of what is a loss will be different to individuals
- further consideration of applying ante-post betting
- the definition could be clearer and further aligned to the other definitions.
Consultation questions
To what extent do you agree with the proposed term ‘net limits’ and its proposed definition for implementation guidance “The amount deposited into the account minus any withdrawals made for the period or duration of the limit applied.”?
Respondents’ views
The majority of respondents agreed with the proposal and comments were received about the definition being easy to understand. Respondents commented that ‘net limits’ aligned well with consumer behaviours and are supportive of more responsible gambling behaviour. However, amongst those that agreed, there was concern raised about the term ‘net limits’ being confusing, and alternative suggestions were offered.
Some respondents did not favour the term 'net limits' preferring instead the terms 'spend limits' or 'net deposit limits'. There were some concerns about consumer confusion, highlighting the risk of confusion for consumers by introducing unfamiliar or opaque labels like 'net limit'.
A small number of respondents didn’t agree or disagree with the proposal. Those in this category were supportive of the definition and the intention to bring clarity to this area, but also raised concerns about the potential to cause confusion.
Our position
We welcome the suggestions made to us to help improve customer understanding in this area. Set out below is our view on each of the proposed terms and definitions of a financial limit in the implementation guidance.
Stake and spend limits
We acknowledge the points made by stakeholders about the term ‘stake and spend limits’ being potentially confusing to customers particularly when the terms stake and spend are used together. We also note the suggestions made in the responses to use the term ‘spend limit’ to describe ‘net’ deposit limits and could see how it could potentially help create a distinction between the different limit types. However, we consider that the term ‘spend’ would not be an accurate term to describe this form of limit because it would not take account of winnings that have been spent.
We also note the points raised about clarity on how things like unsettled wagers, ante-post bets, paused or abandoned game rounds and free bets and bonuses could be accounted for. As is currently the case, we would expect operators to fully explain their financial limits and how these types of activity will affect the limit. This is to ensure that the impact of any type of gambling activity on a chosen limit is clearly understood. We would also expect that in circumstances where a stake is returned to a customer (subject to the operator’s terms and conditions) any financial limit that is in place would be amended to reflect the stake has been returned to the customer. For example, if the stake limit was £20 and the customer placed a £5 bet (leaving £15 of the stake limit remaining) and the event is then called off. In circumstances where the £5 stake is returned to the customer the stake limit would return to £20.
We also note the point received more generally from a trade body that the Gambling Commission should not over prescribe how customer journeys are designed by operators.
The Commission monitors data sources, such as complaints 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 in this area.
In response to the feedback received we have changed the term ‘spend’ to ‘stake’. We agree this would provide clarity to customers as the term ‘stake’ is better aligned to consumer gambling behaviour than ‘spend’ because the term ‘spend’ can be interpreted in a number of ways by a customer and therefore reduces clarity of the consumer.
Loss limits
We have considered the comments raised by stakeholders in the consultation responses and will make the following amendments to the wording of the definition of loss in the implementation guidance:
- loss limits: the total value of stakes placed on gambling products minus the total value of any winnings or returns from those stakes is limited for the period or duration of the limit applied.
We note the points made by respondents who sought further clarity on what is meant by ‘the amount lost’ (as per the definition proposed in the consultation) and the application of loss limits when used during ante-post betting. The Commission expects all operators to clearly communicate the terms of financial limits and ante-post bets to customers so that the impact of that type of gambling activity on their chosen limit is clearly understood. Operators may consider that loss limits may not necessarily be the best type of financial limit for betting customers when used in conjunction with ante-post betting and it may be appropriate for operators to signpost customers to other more suitable types of financial limit such as a deposit limit.
Examples of good practice in relation to loss limit and ante-post bets would include that operators should include accessible information about each financial limit that they offer, including how different types of staking activity (such as ante-post bets), winnings and bonus earnings affect the limit (if applicable). We don’t believe there is a current need for this to be included in implementation guidance and we will monitor data sources to understand any issues that might bring risks to consumers.
Net limits
We welcome the feedback and suggestions that we have received in respect of the terminology used to refer to ‘net’ deposit limits. In the consultation we proposed the term ‘net limits’ to ensure that operators could continue to offer net deposit limits but feedback from respondents said that they found ‘net limits’ confusing. Further suggestions were made in the responses to use the term ‘spend limit’ to describe ‘net’ deposit limits. However, we believe that the term ‘spend’ still isn’t clear as ‘net’ deposit limits are and, in our view, not an accurate representation of typical ‘spending’ behaviour because the term ‘spend’ can be interpreted in a number of ways by a customer and therefore reduces clarity of the consumer.
We also note the point made by respondents that customer comprehension rates of ‘net’ deposit limits are high and the term ‘net deposits’ is also used elsewhere in the regulatory framework. Following consideration of the feedback, we intend to proceed with the definition set out in the supplementary consultation and to use the term ‘net deposit limit’ to describe this limit type. After consideration, we are content that this is the most accurate way to describe the term in the implementation guidance. The definition of a net deposit limit will remain the same as set out in the consultation.
Final wording
This guidance will come into force on 30 June 2026.
Applies to: All gambling – except subscription lotteries.
RTS implementation guidance 12B
In order to maximise consumer choice, operators could also offer:
- stake limits: where the amount a customer stakes on gambling (or specific gambling products) is restricted for the period or duration of the limit applied and/or
- loss limits: the total value of stakes placed on gambling products minus the total value of any winnings or returns from those stakes is limited for the period or duration of the limit applied and/or
- net deposit limits: the amount deposited into the account minus any withdrawals made for the period/duration of the limit applied.
Proposal 2: The application of the term and definition of a deposit limit
Last updated: 7 October 2025
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