Game design and product characteristics
More work is needed to understand how game design and game mechanics can cause, or reduce, harmful gambling. We understand that work is underway, via the Remote Gambling Association, to understand this better. We recommend that the Gambling Commission monitor this closely to ensure that it provides useful and credible insights into steps which could be taken to reduce harm.
Gambling products are becoming increasingly complex.13 Consumers are therefore very likely to find it hard to understand the products they are using or their likelihood of winning or losing, for example when placing ‘live odds’ bets, which tend to be skewed towards more complex events and have a higher profit margin for the operator.14 The Gambling Commission should take steps to help equip consumers with more useful and accessible information. This may require considering a shift in approach. Innovative work is being carried out by the Food and Drug Administration in the USA, who, rather than stipulating what information should be provided, use ‘consumer confusion audits’ to test the extent consumers understand key facts about the products they are buying.15 This approach is intended to better harness the creative capabilities of the industry to communicate key messages to players, rather than the regulator attempting to mandate what it thinks will work.
Outside of game design and mechanics, there are also a number of useful steps with could be taken to change the way products are provided to consumers. We welcome the Gambling Commission’s consultation on banning the use of credit cards for online gambling.As noted in previous advice,16 gambling with borrowed money is a risk-factor for harmful gambling and therefore the use of credit cards is a concern. We are conscious that unintended consequences, such as players resorting instead to the use of payday loans, or even illegal money lenders, need to be considered and implementation should be carefully monitored. Being able to gamble with credit cards, however, makes it very easy to spend more than you can afford. Although some consumers could circumvent such a ban, the added ‘friction’ it would create may, nonetheless, be helpful for many consumers.
We welcome the commitment made in the Gambling Commission’s Business Plan 2019/20 to look at the issue of reverse withdrawals (i.e. the facility to cancel a withdrawal and continue gambling). In our past advice on online gambling, we set out our view that it should be just as easy for a consumer to take their money out of a gambling account as it is to deposit it.17 When withdrawals take too long, or consumers receive marketing offers encouraging them to reverse their withdrawal, this can impede consumers’ decisions about when to stop gambling. Although changes have been made to processes for identification verification checks, more could still be done to make withdrawing money easier for consumers. We do not believe that reverse withdrawals are an optimal solution for consumers because this service is only required because it often takes a long period of time for consumers to access their funds. We recommend banning this facility. This would create competitive pressure on operators to make withdrawal processes faster and remove a point in the consumer journey where they are vulnerable to harm.
We suggest that the culture of the on-line gambling industry needs to change in terms of how it approaches the products it offers. To give one recent example, two online operators announced a new ‘innovation’ which allows customers to play two online gambling products simultaneously via a split screen function.18 This facility cannot be justified in the context of a reasonable approach to safer gambling and protecting players from suffering harm. We recommend the Gambling Commission investigates this case, but to also consider how it can change a culture where operators believe introducing such services is acceptable. Further strong enforcement action and enhanced ‘duty of care’ requirement could make operators take their customers welfare more seriously.
Previous pageEffective interventions Next page
Marketing and advertising
Last updated: 25 March 2021
Show updates to this content
No changes to show.