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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.

Display of net position and time spent

We want consumers to be provided with more information upfront in order to make informed choices about their gambling. Whilst we recognise that there are a number of possible data points that may help consumers keep track of their play, expenditure and time spent gambling were identified as the most relevant in minimising the risk of gambling related harm.

In the consultation we therefore proposed to provide consumers with their net position and time spent during slots gaming sessions. Display of these two metrics will maximise the chances that consumers will better understand their play, whilst not ‘crowding’ the screen especially in light of the increasing amount of slots gambling done through restricted display devices (such as mobiles).

Consultation question

Q23. Do you agree with our proposal to require net position to be displayed at all times within a slots gaming session?

Q24. Do you agree with our proposal to require the elapsed time of slots gaming session to be displayed at all times?

Respondents’ views

The majority of respondents agreed that both a net position and elapsed time should be displayed to slot consumers during their gaming session, stating that it would provide transparency and allow consumers to track and consider more easily their spend and time whilst playing. However, there were disagreements about how it should be implemented.

76% for net position and 71% for elapsed time of all consumers responses agreed or strongly agreed that this was a common sense approach which would help all consumers whilst gambling.

A number of operators wanted clarification as to what we defined as a ‘gaming session’ as concerns were raised about consumers transferring between different games over short periods of time, losing connection and whether or not time should start when the game is opened or the first spin has started.

Six operators proposed instead that the gaming session should start from when a consumer first accessed the website or app and only finish once they have left. This would continue regardless of how many different games they accessed.

Six operators also questioned how displaying both sets of data on restricted display devices would be achievable considering the lack of space available. They argued that space is already filled with valuable information and by adding more you would be potentially creating confusion for consumers. They also suggested that it may result in struggling to deal with consumers checking balances and accessing other features at the same time as playing a game.

The idea that requiring this information to be permanently displayed to consumers would in the long run not be beneficial was also raised by a number operators who warned that ‘it will eventually just be another piece of information that blends into the general game’.

One operator and a trade body took this further and wrote that if net position was displayed permanently with differing figures shown for other requirements it would actually have a detrimental effect on consumers. With consumers being able to see if they are up or down on their starting position it may prompt them to chase losses gambling more, and gamble for longer, than initially intended. Information must therefore be presented in a meaningful, digestible way.

A couple of operators proposed that instead of the information being displayed within the game window it should be included as a pop-up or via an in-game hub, which is always accessible via an in-game menu or dedicated button.

The majority of games developers who responded wrote that any development that took place must be done on the website client side and not on the game client side. This was mainly because of the potential for net position and time to be tracked across multiple game sessions at a time and not within a single instance of a game. If we were to require this, it would have to be done on the website due to the amount of development needed for game clients and portals to talk with each other.

Our position

After consideration of our position and the responses to the consultation we will introduce the requirement to display net position and time with one minor update to the proposed text to enhance clarity. We have also removed one part of the proposed guidance as we are confident that the requirement provides sufficient clarity as per the updated draft.

We agree with the views of most respondents that requiring the information to be permanently displayed on the game screen will give consumers greater transparency along with further tools to monitor their spend and time.

Although many respondents asked for us to provide greater clarity to be included within the requirement, we consider the proposed drafting to be sufficient in terms of outlining the outcomes we expect to see. It would be neither appropriate nor practical to impose an overly descriptive and ultimately restrictive set of rules – especially around points such a text size, placement etc.

It is important that the overall requirement will be kept high level and principles based allowing operator’s greater freedom in implementing the rules in a way which balances the need to be clear for consumers and their own individual set-up and suite of games. We also agree with the respondents who indicated that it is important that these are presented in a meaningful, digestible way.

Noting the responses keen to see the display of the proposed metrics across all online gambling activity, we are only consulting in this section on changes to one of the most intensive products – online slots. It is therefore our intention to proceed as set out in the consultation. We have updated the display of time requirement to make it clear that the elapsed time should be displayed over one gaming session and not multiple sessions.

We have previously taken steps to ensure that operators provide information to consumers across their whole account such as net deposits and account history. These existing requirements at an account level will remain in place. We want to raise standards above this threshold for slots play to implement an additional safeguard.

We do not view the lack of space on restricted display devices as sufficient reason to not include net display and time on them. By ensuring that the wording of the requirement is high-level, operators will be able to design a process by which this information is always viewable along with other information already required in a way which suits their particular games.

This requirement will come into force on 31 October 2021.

RTS requirement 2E

All gaming sessions must clearly display a customer’s net position, in the currency of their account or product (e.g. pounds sterling, dollar, Euro) since the session started.

RTS Implementation guidance 2E

Net position is defined as the total of all winnings minus the sum of all losses since the start of the session

RTS Requirement 13C

The elapsed time should be displayed for the duration of the gaming session.

RTS implementation guidance 13C

a. Time displayed should begin either when the game is opened or once play commences.
b. Elapsed time should be displayed in seconds, minutes and hours.

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Prohibiting effects that give the illusion of “false wins”
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