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Consultation response

Online games design and reverse withdrawals

Consultation response for online games design and reverse withdrawals and proposed changes to the design of online slots.

Defining online slots within the Remote Technical Standards

There is not a separate licence type for remote slots as they are a casino product and caught under the Gambling Act 2005 (opens in new tab) (the Act) as gaming. Therefore, in order to increase controls on these products we proposed defining online slots within the Remote Technical Standards.

Term: Slots
Definition: Casino games of a reel-based type (includes games that have non-traditional reels).


Consultation question

Q5. Is the wording of the slots definition sufficiently clear?


Respondents’ views

The majority of respondents that answered the question (76%) agreed that that the definition of slots was clear, including 25 operators. Several respondents commented that they agreed with the definition or found it sufficiently workable.

Some respondents raised concerns that the definition was vague, and further clarity was needed for terms such as non-traditional reels. It was mentioned that some gambling products have similar underlying mechanics to online slots but differed in terms of their overall presentation. It was therefore suggested that the definition draw a clearer distinction between game logic and user interface presentation. One operator suggested the definition was too specific.

Some respondents questioned whether game types other than slots were in scope of the definition, such as instant win games, video poker, virtual sports or video bingo. A small number of respondents asked for examples of game types that did or did not meet the definition of slots. One respondent stated that developers may need to seek confirmation from us on whether or not a product was in scope.

A concern was raised that different stakeholders (operators, test labs and the Commission) may have different interpretations of a product.

Suggestions for improving the definition included the addition of:

  • ‘grid based’
  • awards prizes based on the outcomes displayed on the reels
  • result cannot be materially affected by customer interaction
  • …but are based on the same combinatorial mechanics
  • the outcome of such games is determined by RNG
  • regulated under the Online Casino Games sections of the 2005 Act
  • 100% random and luck based.

One operator was concerned that developers may seek to circumvent any new regulations and another stated that developers would be incentivised to obscure the game logic.

A trade body suggested that online bingo operators offer slot games without reference to casino games and that the definition could be made clearer by including additional text that slots are caught as casino games under the Act.

It was further suggested that an additional definition should be considered to include National Lottery instant win games.

Our position

In order to increase controls on slots in the absence of a separate licence type, we proposed defining online slots within the Remote Technical Standards.

We are aiming for a definition that will be understood by developers, operators, test houses and which fits with our wider regulatory approach. That is why we proposed a high-level approach to the definition.

Our focus is on online slots, because of a particular concern about the accelerating intensity of these games being driven by technology and designs that aim to increase the time and spend of players. The definition is not seeking to bring into scope games that have some similar characteristics but are distinct from slots. Online slots are a remote casino product, so products which are caught by a different licence type, such as bingo, are not in scope of the definition. Other well-established games such as poker that have their own widely understood rules are not in scope of this definition.

Gambling operators are already required to determine whether the games they make available to consumers are slots for the purposes of correctly reporting financial data in their regulatory return submissions. Further, operators must ensure that the games they offer to consumers are sufficiently understood so that customers can make an informed decision before gambling. Our view is that the proposed definition should provide enough information to ensure games continue to be classified appropriately. We will monitor the implementation of the definition.

Based on our assessment of slots games and considering the feedback we have received throughout the consultation we expect that all slots games will be caught within the proposed definition. For any products where an operator is unsure, they should consult the supplier/developer of the product to ensure the product is consistently categorised across the industry. This should be no different from what currently happens, for operators to fulfil their existing obligations.

We note the suggestion to include text which makes clear that slots consumers cannot ‘materially’ affect the outcome of the game. Our view is that, introducing such text may require further explanation or guidance for the term materially and could mean that certain types of slots games (such as those featuring a skill based element) were not caught by the definition.

In general, we consider ‘grid based’ to fall under the definition of non-traditional reels. We cannot be definitive in every instance, especially as grid based is not defined and products will continue to develop.

One of most commonly suggested additions to this definition was ‘awards prizes based on the outcomes displayed on the reels’. However, the addition would not serve a specific purpose (such as moving a game into or out of scope) and would not appear to strengthen the definition while at the same time may increase the risk of circumvention.

The National Lottery is governed by a separate regulatory framework to the online casino sector and was therefore not in scope of this consultation.

This definition will come into force on 31 October 2021.

New definition

Term: Slots
Definition: Casino games of a reel-based type (includes games that have non-traditional reels).

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Prohibiting multiple slot games
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