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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.

Summary - Game design

During the summer we consulted on proposed changes to the design of online games (other than slots) to make them fairer and safer for consumers while improving transparency. This follows on from our work in 2020 to 2021 where we introduced changes for online slots as well as fulfilling the aim from the government’s White Paper (opens in new tab).

As highlighted in the consultation document, speed of play, as well as features which reduce thinking time or contribute to dissociation from the gambling activity can increase the risk of addiction and harm. When we consulted on changes to online slots (opens in new tab), we were clear that these proposals were just the first step in reducing the risk of harm from the design of games.

A number of respondents recommended stake limits on casino products in response to this consultation. The White Paper was clear that in the government’s view, the evidence does not currently support stake limits on non-slot gaming or betting products as stake size can have a more direct functional role in non-slot gameplay compared to slots, for instance in roulette where a higher stakes bet can be divided between different areas, modifying the rate of return to the player and the risk of losses. More information has been published and is available in the government response to the consultation on proposals for the introduction of a maximum stake limit for online slots (opens in new tab).

We received a number of comments and suggestions for additional measures the Gambling Commission should consider outside the scope of what was proposed. We have retained these recommendations and may consider them in future work.

We have decided to proceed with most of the proposed changes as set out in the consultation document. However, we have acted upon feedback from stakeholders and have amended several of the standards to be less onerous in scope or more suitably worded, without impacting the core objective of the White Paper and consultation: making games safer across the sector.

We have set out our position on each proposal in the relevant section of this consultation response and in addition we have detailed the new remote gambling and software technical standards (RTS) on our website.

The new game design requirements will form part of a revised RTS and will come into effect on 17 January 2025.

The updated requirements for security audits will come into effect 31 October 2024. This means any annual security audit conducted after 1 November 2024 must be to the updated 2022 standard.

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