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.
Contents
- Executive summary
- Summary of topics
- Topic 1 - Improving customer choice on direct marketing: Consultation Response
- Topic 2 - Strengthening age verification in premises: Consultation Response
- Topic 3 - Game design: Consultation Response
- Topic 4 - Financial vulnerability checks: Consultation Response and Financial risk assessments pilot: Consultation Response
- Topic 5 - Personal Management Licence: Consultation Response
- Topic 6 - Changes to Regulatory Panels: Consultation Response
- Evaluating the impact of relevant changes
- Annex
Proposal 4: Effects that give the illusion of 'false wins'
Proposals
We proposed to extend the prohibition of celebrating wins less than or equal to stake to all casino products.
Consultation question
To what extent do you agree with the proposal to prohibit celebrating wins that are less than or equal to stake for all casino products? Please give your reasons for your answer.
Respondents' views
The majority of respondents agreed with the proposal. Gambling operators raised a concern about the potential impact on live casino games due to croupiers talking to customers which may include celebratory language. They also sought clarity on the audio element of the existing remote gambling and software technical standards (RTS) requirement and how this may impact non-slots games.
Respondents commented as follows:
- gambling operators were concerned that the wording of the guidance requires an additional sound to be added to games that only currently utilise a single sound. As one stated, “provided this sound is not celebratory in nature, there should be no requirement to differentiate"
- only big wins should be celebrated
- winning less than the stake is still a loss and should not be reason for a celebration. Celebrations seem to be a strong stimulus to keep playing
- clarity was sought on the advertisement of previous winners on a website and whether this was in scope
- clarification was sought over the use of the word ‘win’
- the word loss should be used for returns less than stake
- the Gambling Commission should mandate sounds for returns less than stake.
Our position
In our response to the slots consultation, we provided clarity on the word 'win' and removed explicit reference to it in the requirement. This is stated here to provide clarity that the word 'win' is not itself the issue that this proposal was seeking to address.
Operators should consider the purpose of the messages and ensure they meet the aims. For example, it seems clear that win messages are designed to inform the customer about the result of a bet and to do so in a positive way to improve the mood of the consumer. Positive reinforcement of returns below stake is the core concept of what this proposal was seeking to remove. Operators could do more to ensure the messages that customers receive are informative and accurate by specifying the overall amount that a customer has won, or as some respondents suggested, by making it clear when a customer has lost. This is particularly relevant for new games being developed.
It was of some concern to read responses from industry explaining that in some live casino games the croupier does not know whether the amount won by a customer is above their initial stake and so may inadvertently celebrate a win that was not above their stake. This does not indicate a good customer experience and appears as though it could be improved with technology easily. We encourage operators to consider improvements to ensure transparent and accurate information is provided to customers. Equally, if a croupier is celebrating wins at a table played by multiple people and it is not clear to customers who the dealer is referring to, we consider this to be something that can be easily resolved with better communication.
The wording of the proposal required the ‘gambling system’ not to celebrate a return which is less than or equal to the total stake gambled using audio or visual effects. While a croupier is an integral part of the delivery of live casino games, they were not in scope of the proposal.
The Commission will continue to monitor casino games including live dealer games and consider further action if necessary.
Our guidance 14F part (a) states that ‘the use of auditory or visual effects that are associated with a win are not permitted for returns which are less than or equal to last total amount staked’. The addition of part b iii was meant to aid understanding that a sound which is used to celebrate wins should not be used for returns below or equal to stake. However, this does not mean that a game which only has one sound needs to be redeveloped.
As this line of proposed guidance appeared to be causing unnecessary concern, we have decided to remove it from the final guidance.
We have extended requirement 14F from slots only to all casino, and this will apply from the commencement date.
Final wording
This requirement will come into force on 17 January 2025.
Applies to: Casino.
RTS requirement 14F
The gambling system must not celebrate a return which is less than or equal to the total stake gambled.
RTS implementation guidance 14F
- By ‘celebrate’ we mean the use of auditory or visual effects that are associated with a win are not permitted for returns which are less than or equal to last total amount staked.
- The following items provide guidelines for reasonable steps to inform the customer of the result of their game cycle:
- Display of total amount awarded.
- Winning lines displayed for a short period of time that will be considered sufficient to inform the customer of the result. This implementation should not override any of the display requirements (as set out in RTS 7E1).
- Brief sound to indicate the result of the game and transfer to player balance.
Last updated: 13 June 2024
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