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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.

Proposal 3: Autoplay


We proposed extending the prohibition of autoplay that currently applies to slots to all online products.

Consultation question

To what extent do you agree with the proposal to prohibit autoplay for all online products? Please give your reasons for your answer.

Respondents’ view

The majority of respondents agreed with the proposal. Gambling operators raised some concerns about the impact on live casino games due to their limited window to place a bet, ‘auto dabbing’ for bingo and the auto-posting of blinds in peer-to-peer poker games.

Respondents commented as follows:

  • autoplay could be further limited for live dealer games rather than being removed
  • clarity sought on whether this includes purchasing tickets for scheduled bingo games
  • autoplay can be used as a tool to control gambling or play a set amount. Conversely gambling without autoplay may lead to consumers gambling more than they wanted to as they lose count
  • autoplay allows consumers to continue playing when they are not watching the product
  • autoplay diminishes consumer responsibility, bets should require a conscious decision each time
  • there is a need for increased friction to reduce the dissociative state that some people experience when gambling
  • general comments around a lack of evidence that removing autoplay will help consumers
  • removing autoplay is damaging to the customer experience
  • some references to customer circumvention which would not have the controls that autoplay currently does
  • several mentions of autoplay contributing to a dissociative state
  • it appears overly strict to remove autoplay from products, “which the GC (Gambling Commission) itself recognises as lower-risk”
  • autoplay can be helpful for people with disabilities and/or RSI.

Our position

Autoplay is widely regarded to be a source of increased risk for gambling consumers according to gambling research such as Parke, Parke and Blaszczynski (2016) that found the lack of (physical) interaction facilitated by autoplay, such as even pressing a button, reduces likelihood of mental engagement.

We prioritised new requirements for slots as they are considered a relatively high-risk product, responsible for the bulk of consumer losses (around 77 percent of remote casino Gross Gambling Yield (GGY) according to our industry statistics) and played faster and more repetitively than other game types. However, in doing so we did not delineate other casino products as ‘lower risk’ nor does available evidence suggest such products are. The Patterns of Play research estimated that non-slots casino products had the fastest loss rate of all products, despite the gameplay being generally slower (£1.12 per minute).

We are mindful that features which improve the quality of user experience and do not pose an obvious risk should not be restricted. This is why features such as ‘re-bet’ were not in scope of our proposals. Such a feature enables a customer to place the same bet as the previous game cycle without individually placing the same chips (bets) but still requires an active choice by a consumer on each game cycle. Such a feature enables games with shorter betting windows, such as live casino games, to function smoothly without the need for autoplay. As a result, we see no convincing reason to exclude live casino games from scope.

Auto-dabbing in bingo games was not caught by the proposal. The wording of the proposed provision requires that each game cycle is committed to individually which is not relevant to the marking of numbers drawn during a bingo game that a customer has already committed to by purchasing an entry. The proposal did not seek to restrict the purchase of individual bingo tickets for scheduled games.

The wording of the proposal also did not capture the auto-posting of blinds in peer-to-peer poker tournaments for a similar reason. However, we are mindful that it could be interpreted as excluding the functionality from cash table poker games which we received calls for clarity on. The posting of blinds does not occur every hand and so does not incur a cost to the consumer until play rotates to their position, unlike other games.. We have therefore provided implementation guidance within the Remote Gambling and Software Technical Standards (RTS) to reiterate our intention that this is not caught.

As was the case for slots, removing auto-play actively inserts friction and provides less opportunity for simultaneous play across multiple products. This is of particular importance given the introduction of a 5 second minimum speed for casino products which could be circumvented by using auto-play across multiple games.

We are committed to giving consideration to potential equalities impacts, having regard to the need to eliminate discrimination, advance equality of opportunity and foster good relations between those who share a protected characteristic and those who do not. As part of the consultation, we acknowledged the response to our earlier consultation on removing autoplay from slots games, and the potential impact that removing the autoplay function may have on consumers with disabilities or specific health conditions, and invited further views and evidence linked to extending the ban to other online casino games. A small number of respondents raised this issue.

While we recognise that our proposals may present a challenge for those players, they would also be exposed to the risks associated with autoplay, and having carefully considered the evidence we have, we have proceeded with the change.

We have introduced the requirement to prohibit autoplay for all online gaming products. A line of guidance has been included in the RTS which makes clear that the auto-posting of blinds in peer-to-peer poker is not caught by this requirement.

Final wording

This requirement will come into force on 17 January 2025.

Applies to: Gaming (including bingo).

RTS aim 8A

To make clear that auto-play cannot be offered for online gaming.

RTS guidance 8A

This requirement does not prohibit offering functionality to automatically post blinds in peer-to-peer poker.

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