Online games design and reverse withdrawals
Prohibiting multiple slot games
Due to the risks of functionality deliberately designed to encourage consumers to play two slots games simultaneously, we proposed an update to RTS to require operators to ensure that consumers are only permitted to play one slot game at a time per account across multiple tabs/windows, browsers, applications (apps) or devices.
Q6. Do you agree with the proposal to limit the number of slot games that can be played to one per account at a time?
The majority of respondents that answered the question (69%) agreed with the proposal to limit the number of slot games that can be played to one per account at a time. This included 32 operators that agreed or strongly agreed with the proposal, with seven either disagreeing or strongly disagreeing. Operators overwhelmingly agreed with the aim of the proposal but there were some concerns with the wording.
Support from members of the public was more mixed with 26 responding positively and 19 disagreeing.
There were a number of concerns raised with the proposal which can be broadly grouped into the following areas:
- Technical challenges
- Responsibility (customer facing operator vs game supplier)
- Playing on multiple accounts
- Bonus wagering.
Operators informed us they would be reliant on the customer facing operator (B2C) to implement this proposal as suppliers (B2Bs) only have visibility over their own games or platform. Suppliers are therefore unable to see if a consumer is playing on another supplier’s game and as such do not have sufficient ability to prevent customers playing on games provided by other suppliers. Respondents felt we should be clear where the responsibility for compliance lies, although one game supplier informed us that they already prevented customers from loading multiple games that they supply.
While B2C operators broadly agreed with the aim of the proposal, they expressed concerns that to prevent multiple slot play in all cases across multiple devices would require a significant amount of development work as the functionality doesn’t currently exist. An operator was concerned that the wording of the proposal could lead to a position where avoiding compliance breaches is out of their control. They also highlighted the potential for players to seek refunds if they were able to find a way to circumvent their controls. A trade body stated that the prevalence of playing on multiple slots was low and urged for, what it termed, a more proportionate approach.
The possibility for easy circumvention of the controls was raised by operators (and shared by other respondents), specifically that consumers could easily play on multiple accounts, which would negate the potential benefits of this proposal. As well as raising this risk, they highlighted that perversely the proposal might encourage consumers to switch between accounts or open additional accounts, resulting in increased deposits and lower visibility of consumer play for each individual operator.
Several operators asked how we would differentiate between games that featured multiple reels compared with the playing of multiple games. Operators mentioned that products featuring multiple reels were popular in other jurisdictions, an example was provided that featured four slots which could be configured individually, another mentioned Belgian skill slots. They were concerned that prohibiting such content would deter innovation.
An operator felt we should focus the requirement on the features that are deliberately designed to promote the ability to play multiple slots at once.
Some consumers told us that they may play on multiple slots when playing through bonus wagering requirements, either to reduce the variance or to reduce the time that would be otherwise required playing on a single game. There were concerns that as bonuses may have a time limit attached to requirements, they would be harder to complete. One consumer informed us that they would increase stake to compensate.
One respondent suggested that playing four games at once should be restricted but that preventing the concurrent play of two could increase the risk to the consumer if they chose to circumvent the restriction by playing on a second account. Another respondent echoed calls for the requirement to permit playing up to two games at the same time.
The reason for consulting on this proposal was due to the introduction of functionality deliberately designed to encourage play simultaneously via a split screen. Advice from our Advisory Board for Safer Gambling1 indicated that “this facility cannot be justified in the context of a reasonable approach to safer gambling and protecting players from suffering harm”.
We will introduce a new requirement which prohibits operator-led functionality specifically designed to facilitate the playing of multiple slot games at the same time, which includes prohibiting split-screen or multi-screen functionality. We have amended the requirement and subsequent guidance accordingly to reflect this and provide further clarity.
We also proposed a requirement which went further than a prohibition of such features on individual websites to explore the feasibility of preventing multiple slot play across browsers/apps.
We have considered the responses to this proposal and acknowledge that the requirement to prevent multiple slots play across browsers or devices in all circumstances is likely to be technically challenging and are either easy to circumvent or could lead to unintended consequences.
However, we are aware that some developers have implemented measures which would prevent more than one of their games being played by a consumer on the same operator’s website and we welcome the initiative shown by an operator who informed us they were planning to implement measures to actively prevent multiple slots play in some cases.
Given the feedback on complexity, we tested these responses with our Digital Advisory Panel (DAP) who agree that implementing the proposal at an account/brand level would be complex and challenging and advised that mitigating the risk of play on multiple slots should be explored as part of the ongoing Single Customer View (SCV) project.
Structurally we expect that the prohibition on auto-play facility for slots games contained within this suite of measures will help to minimise the ability of players to gamble on multiple products, especially as each slots spin will now require individual user action to initiate the spin. This effectively stops the ability to set the reels spinning on auto-play and then switch to other forms of gambling while the reels are spinning.
While we are mindful of mandating a requirement which would be very complex to implement, we would be prepared to do so providing there are tangible benefits in terms of protecting consumers and where the proposed solution can mitigate against the risks of circumvention by consumers.
On balance, we agree that the proposed solution on stopping multiple slots games being played at the same time will at best only partially mitigate the risk identified, and without other suitable controls in place could potentially encourage other (riskier) behaviours. This may encourage some players to open additional accounts in order to circumvent the proposals.
We are alert to the unintended consequences of well-intentioned regulatory interventions and consider that such a risk exists with this proposal in the absence of a further developed SCV solution.
As such we will put this part of the requirement on hold until further progress is made with the SCV project.
We are, however, still concerned about the risks to consumers from intensive play across multiple slots games at the same time. We welcome the efforts from a handful of suppliers and operators who have already taken some action to stop consumers playing more than one of their games at once.
We recognise that operators may not currently be able to stop consumers from playing multiple slots games at the same time, but we are clear that operator led functionality specifically designed to encourage or allow customers to play multiple slot games at the same time is not consistent with our expectations of responsible product design.
A few existing games feature more than one set of reels within the individual game. Although we have seen limited evidence of such games in the GB market to date, it is possible such games increase the intensity of play and as such this is an area that we will keep under review.
Whilst there are some examples of good work in addressing this risk, we are concerned that some licensees may consider combining multiple separate slots into a single game or linking the wager of multiple slots to give the impression that it is a single game. We are adding guidance to make clear that developments aimed at circumventing the requirement are also prohibited.
We have taken action in the past on game features which are inconsistent with the aim of the RTS 14 and are prepared to do so in future. Licensees must take account of the aim of RTS 142 when designing new features or products.
This requirement will come into force on 31 October 2021.
RTS requirement 14C
The gambling system must not offer functionality which facilitates playing multiple slots games at the same time.
RTS implementation guidance 14C
a. Operators are not permitted to offer functionality designed to allow players to play multiple slots at the same time. This includes, but is not limited to, split screen or multi-screen functionality.
b. Combining multiple slots titles in a way which facilitates simultaneous play is not permitted.
2 To ensure that products are designed responsibly and to minimise the likelihood that they exploit or encourage problem gambling behaviour.
Defining online slots within the Remote Technical Standards Next section
Introducing speed of play limits