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Consultation response

Summer 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response

This response sets out our position in relation to the consultation on the proposed changes to LCCP and Remote Gambling and Software Technical Standards.

RTS 4 – Time-critical events

Applies to:

Gaming (including bingo), lotteries and betting on virtual events

RTS aim 4

To reduce the risk that customers are unfairly disadvantaged by technical factors that may affect speed of response, and to ensure customers are made aware of the risk.

RTS requirement 4A

Where speed of interaction has a significant effect on the customer’s chance of winning, operators must assess the level of risk and demonstrate to the Commission that they are taking reasonable steps to reduce the risk to customers.

RTS implementation guidance 4A

Examples of possible approaches include:

  1. estimating the degree of network latency (delay) a customer is experiencing and displaying regularly updated information to the customer about any disadvantage that they may be operating under (for example high, medium, low)
  2. applying a handicapping system based on estimated performance and/or system latency
  3. treating winning responses that arrive within a period of time as simultaneous and implementing a policy on how simultaneous wins are to be dealt with.

RTS requirement 4B

For time-critical events, the customer should be informed that they might be at a disadvantage because of technical issues such as slower network speeds, or slower end user device performance.

RTS implementation guidance 4B

  1. Information should be included in game descriptions, rules, ‘help’ or ‘how to play’ pages.
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