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Consultation response

Online games design and reverse withdrawals

Consultation response for online games design and reverse withdrawals and proposed changes to the design of online slots.


We license and regulate commercial gambling within Great Britain, including the National Lottery, with the exception of spread betting which is regulated by the Financial Conduct Authority (opens in new tab) (FCA).

Our functions include:

  • licensing operators and individuals
  • monitoring compliance with licence conditions and the law
  • investigation and enforcement, both in relation to licensees and illegal (unlicensed) gambling
  • providing advice to central and local government on the incidence, manner, effects, and regulation of gambling.

We have a duty to aim to permit gambling if it is reasonably consistent with the statutory licensing objectives.

Consultation proposals and background

In October 2019 the Commission brought together industry CEOs and laid the ground for trialling a more collaborative approach to improving player protections.

During the event and through the various working groups that have taken place since, we challenged the industry to develop bold and effective methods to make online slots games safer for consumers.

An industry BGC Code of conduct (PDF opens in new tab) has since been produced and went into effect at the end of September 2020.

We think that the areas covered in the code will help to make online slots safer for consumers, but we do not consider the measures, by themselves, sufficient. Using industry and consumer data, gambling research and input from our Advisory Board on Safer Gambling, Digital Advisory Panel and interim Experts by Experience groups we identified several additional areas that could be implemented to make online slots safer.

The full set of proposed measures was set out in our 8 week consultation (opens in new tab) which closed on 3 September 2020. The consultation also proposed a ban on reverse withdrawals, a topic which was covered in the additional customer interaction guidance which was issued in May 2020. The changes set out in this response will be incorporated within the Remote gambling and software technical standards (RTS), which sets out the specific technical standards that licensed remote gambling operators and gambling software operators need to meet.

Our aim is to take proportionate steps to reduce the intensity of online slots and we have been clear that the onus is on licensees to ensure their games are designed in a way which is consistent with delivering that aim. If we find that game developers are seeking ways to circumvent these controls, we will not hesitate to take further action.

We received 102 written responses to the consultation from the following categories of respondents, details of which can be seen in Annex 3:

  • Members of the public - 46
  • Gambling operators - 39
  • Gambling industry trade bodies - 4
  • Charities - 1
  • Academics - 1
  • Other - 11

The summary of responses provides a qualitative summary of the responses we received to the consultation questions, along with our position. The following figure 1 provides a breakdown of responses to the consultation questions.

Chart - Online slots consultation responses -  The chart shows whether participants agreed or disagreed with the responses within the consultation and the extent to which they agree or disagree.

Data for chart

Consultation proposal Strongly agree Agree Not Answered Disagree Strongly disagree
Slots definition 22 54 3 17 6
Prohibit multiple games being played at same time 33 37 1 16 15
2.5s spin speed 22 42 4 12 22
Prohibit slam-stops and turbo 28 33 4 17 20
Prohibit auto-play 18 11 3 27 43
Prohibit celebration of returns below or equal to stake 34 21 4 23 20
Require display of net position 32 44 3 15 8
Require display of time played 27 45 10 15 5
Permanently ban reverse withdrawals 47 34 3 8 10

Approach to implementation dates

The changes to the RTS outlined in the relevant sections of this document will take effect on 31 October 2021.

In assessing the most appropriate implementation date we considered the following:

  • the number of games in-scope and levels of complexity of some of the required changes, including lead-time for development and change control processes
  • operators of different size and capability have sufficient time to be compliant
  • since we published the consultation there are some increased protections for online slots players because of the BGC Code of conduct (PDF opens in new tab) which was launched in September 2020. Members of the BGC are now bound by this code, which includes limits on spin speed and a voluntary ban on features such as slam stops and turbo.

We welcome the commitments made by BGC members to make online slots games safer for consumers. However, we do not consider that as a package the measures proposed by industry are, by themselves, sufficient.

This consultation goes further in a number of additional areas to help protect slots players and will mandate requirements across all in-scope licensees, regardless of whether they are a BGC member or not. This means that where licensees fail to apply the new standards they can be subject to regulatory action.

It is our expectation that the additional lead-time will enable all operators to make their games compliant by the implementation date.

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Summary of responses
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