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
Equalities considerations
We received very few responses presenting considerations that were relevant to the consultation proposals. A licensee who responded suggested that asking for proof of age in this context would not amount to unlawful discrimination. One member of the public thought that it would discriminate against those aged 18 to 25 years old. Another suggested that an ID check could only be justified if staff thought an individual was under 18 and using a higher age check seemed unreasonable and therefore illegal.
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. We do not currently consider that the proposals set out in issues 1 and 2 of this section of the consultation give rise to known negative impacts in the context of the above objectives.
We are aware that age is a protected characteristic. In challenging someone who appears to be underage for identification, a licensee is discriminating on the basis of age. However, this is necessary because it is illegal for someone to gamble (on certain products) under the age of 18, and a licensee would be committing an offence if they permitted them to do so.
Last updated: 1 May 2024
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