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

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.

Published
1 May 2024

Last updated
1 May 2024 - Changes

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Contents

Question regarding premises that do not have direct staff supervision

Some licensees operate premises that may not be directly supervised, such as those in motorway service areas. We sought views on how these licensees make sure they have effective age verification procedures.

Consultation question

Considering particularly premises that do not have direct staff supervision, please provide any views, along with supporting evidence, on the controls deployed by licensees (and their effectiveness) to meet our requirements on the prevention of underage gambling.

Background

Our Licence Conditions and Codes of Practice (LCCP) requires licensees to have and put into effect policies and procedures designed to prevent underage gambling and monitor the effectiveness of these. In particular, this includes procedures for checking the age of apparently underage customers, removing anyone who appears to be underage and is unable to produce acceptable ID, and taking action where there are attempts by under 18s to enter the premises. Those policies and procedures must take account of the structure and layout of the premises.

These requirements, and other relevant provisions of the LCCP, apply regardless of where the premises are situated. The owners of gambling premises in areas such as motorway services typically hold Adult Gaming Centre (AGC) licences. Under 18s are not allowed to enter AGC premises. The permitted mix of gaming machines in an AGC in a motorway service area is the same as that for high street premises – unlimited category C and D gaming machines, with up to 20 percent of the total number of machines being of category B3 or B4 (with higher permitted stakes and prizes).

Responses

We received a relatively low number of responses to this question: less than 40 percent of those who responded to this section of the consultation.

Three main themes came out in the consultation responses:

  • most respondents from all categories supported the use of CCTV and other forms of technology, such as facial recognition, to monitor and control access to premises
  • a similarly high proportion of respondents thought that AGCs should be staffed at all times
  • ID checking was important to make sure nobody underage was allowed to play, including keeping premises locked until suitable ID had been provided.

Our position

We know that many operators of premises within areas such as motorway services already use CCTV, combined with a remotely controlled access gate, to monitor access to those premises. It would be up to licensees to decide whether the kinds of facial recognition technology mentioned in the responses would help them do that. Some also have staff within premises at busier times or locations.

We are not considering any measures specific to premises that may not be directly supervised at this time. The requirements in our LCCP apply equally wherever premises are located and licensees should take any measures necessary to comply with them. Our main tool to gauge the risk of underage gambling in these premises, and others, is the mandatory age verification test purchasing. This tool also assists licensees in making sure they are complying with what is, first and foremost, a legal requirement to prevent children from gambling.

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