Guidance

Guidance to licensing authorities

The Gambling Commission's guidance for licensing authorities.

Published
1 April 2021

Last updated
1 May 2024 - Changes

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Guidance to licensing authorities

Proposal 2: Speed of play

Proposals

We proposed introducing a minimum spin speed for casino games (excluding slots which is already subject to a minimum speed of 2.5 seconds and poker) of 5 seconds to reduce the risk and intensity of non-slots casino titles, particularly those games that currently play faster than slots.

Consultation question

To what extent do you agree with the proposal to introduce a minimum speed of 5 seconds for non-slots casino games (excluding poker)? Please give your reasons for your answer.

Respondents’ views

The majority of respondents agreed with the proposal. However, some of the written respondents, particularly academics, felt that while introducing a minimum speed was positive, the proposed minimum of 5 seconds is not slow enough.

The key points raised by respondents were:

for respondents who stated 5 seconds was insufficient, alternative suggestions included:
- at at least 60 seconds
- 72 seconds
- 144 seconds.
online table games should play at the same speed as their land-based variant
references to the 20 second speed on category B2 machines being problematic (5 seconds is too fast)
games should be assessed for risk and a ‘safe speed’ established
hundreds of games may need retesting by independent labs
‘instant win’ or ‘tap’ games should align with the Slots requirements and be permitted to play at 2.5 seconds
unlikely to have much impact on current speed of games (especially winning games)
consumers may increase stake in response
consumers may play longer sessions due to increased game speeds
the rationale for 5 seconds is unclear or unevidenced
slots should be a minimum of 5 seconds
the 2.5 second minimum speed for slots has not been thoroughly evaluated
the Gambling Commission has not demonstrated a need for casino games to be twice as slow as slot games
clarity was sought on whether a game can play quicker than 5 seconds providing the next game cycle cannot be started.

Our position

Our consultation proposal was to introduce a minimum speed of 5 seconds to reduce the risk and intensity of non-slots casino titles, particularly the fastest variants of these games.

The biggest challenge raised in response to this proposal was that it does not go far enough, and that games should be made much slower. Views for increasing minimum game speed much further do not appear to factor in the actions of gambling consumers and whether they would continue to play the game at a much slower speed. Research such as Harris and Griffiths (2017) reports, “a consistent finding across studies that games with faster speeds of play were preferred and rated as more exciting for all gamblers, ranging from non-problem to problem gamblers”. This means that slowing games down may reduce the desire for those experiencing problems to continue gambling, but it could also reduce enjoyment for all gamblers which may lead to displacement to other gambling activities. If this reduction is slight, the effect on enjoyment will be minimal while also impacting the ability to play games at speeds that may be harmful to some.

We reported in our consultation that a sample of data showed that the average length of time for play on casino products is in excess of 5 seconds. We have now conducted our own survey of online casino gamblers, with results published in February 2024, which found that the majority (not lower than 70 percent) of respondents report across 7 categories of game that the average spin speed or length of time a hand is played is ‘just right’. Amongst the remaining respondents, they were more likely to report that the games are ‘too slow’ rather than ‘too fast’; details are available in the data tables in the survey of online casino gamblers. This adds to the evidence that current game speeds are satisfactory for most consumers and suggests reducing game speed too much may affect consumer enjoyment and potentially increase displacement to other products.

We do not think it would be useful or desirable at this point in time to define multiple game types with multiple game speeds. Such prescription would be unwieldy and quickly lead to innovation at the edges to blur or create new game variants. We have already seen that introducing a definition for a single product (slots) can lead to complexity in categorisation. Such complexity requires additional resource to establish whether a game is compliant, for example.

We know from our evidence that casino table games typically play slower than slots but have a higher loss rate, with the Patterns of Play research reporting that the loss per minute for casino games (£1.12) is higher than slots (31.8p). Given that most casino games already take longer to play, this means the introduction of a minimum speed which would reduce intensity for casino games needs to be higher than the minimum 2.5 seconds for slots. We saw from our assessment of the introduction of the minimum speed for slots some evidence of reduced intensity without causing unintended consequences to the games and we are aiming for a similar outcome for other casino products. We will continue to monitor the situation for casino games.

It is important to note that the introduction of a minimum speed for other casino products is not made in isolation but as part of a package of measures aimed at reducing risk from online gambling. This includes the proposals for financial risk checks which were consulted on at the same time as these changes. We are mindful that there may be displacement of gambling activity caused by the introduction of the Department for Culture, Media and Sport’s (DCMS) stake cap for slots, or from changes introduced by these game design requirements. It is important to understand the cumulative effect of all these changes in order to assess the impact on casino games.

Games such as peer-to-peer poker and bingo last much longer on average compared with other casino games and last longer than the 5 seconds proposed. As such, we do not see the benefit of including these games in scope as some suggested. For clarity, poker games played against the house such as three card poker are included in scope.

We have decided to proceed with the introduction of a 5 second speed for non-slots titles. Therefore, we are introducing new requirement 14G to RTS 14 Responsible product design.

Games that are in scope for this requirement are permitted to finish faster than 5 seconds providing the next game cycle cannot be commenced until the full time has elapsed. This is to allow developers more flexibility in how the requirement is implemented and mirrors the existing requirement on slots.

Final wording

This requirement will come into force on 17 January 2025.

Applies to: Requirement 14G - Casino (excluding peer-to-peer poker and Slots).

RTS requirement 14G

It must be a minimum of 5 seconds from the time a game is started until the next game cycle can be commenced. It must always be necessary to release and then depress the 'start button’ or take equivalent action to commence a game cycle.

RTS implementation guidance 14G

A game cycle starts when a player depresses the ‘start button’ or takes equivalent action to initiate the game and ends when all money or money’s worth staked or won during the game has been either lost or delivered to, or made available for collection by the player and the start button or equivalent becomes available to initiate the next game.

A player should commit to each game cycle individually, continued contact with a button, key or screen should not initiate a new game cycle.

Last updated: 1 May 2024

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