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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.

Introducing speed of play limits

Currently, remote gambling is not subject to a minimum game cycle speed meaning there is a potential for faster, more intensive products to be available online than in other sectors or environments.

We proposed a minimum spin speed for online slots, which will mirror category B3 (mostly slots) gaming machines at a minimum of 2.5 seconds.

Consultation question

Q9. Do you agree with the proposal to introduce a minimum spin speed of 2.5 seconds for slots?

Respondents’ views

65% of respondents agreed with the proposal to introduce a minimum spin speed to online slots.

A number of responses stated that 2.5 seconds was insufficient, and a longer spin time should be considered. This included a response from academia that stated 2.5 seconds is insufficient for the emotional and physiological arousal outcomes of the previous bet to have subsided. Suggestions of 3 seconds and 5 seconds were offered. Several operators suggested a tiered approach where the spin speed was dependent on the stake size and was slower for higher stakes.

Consumers were split on the length of time for a game cycle. Some respondents raised concerns that the proposed speed limit could result in longer play (sessions), especially to complete bonus wagering requirements with some respondents suggesting it would spoil the player experience or that they may increase stakes to compensate. Others suggested that players may seek out unlicensed gambling opportunities.

There was concern that the wording of the proposed requirement appeared to prohibit auto-play as it made reference to the need to release and depress the start button and for players to commit to each game cycle individually. Along similar lines, some consumers told us that being required to take action to commence each game cycle would be annoying or inconvenient.

Several responses questioned the definition of ‘game cycle’ and offered opinions on how the start and end of one should be defined. These included:

  • perhaps using international standards (such as those established by test labs)
  • a game cycle is defined as “wager to wager”
  • should be 'bet to result' time and shouldn't include wording around pressing of buttons/interacting with game.

Our position

After consideration of our position and the responses to the consultation, we will introduce a minimum game cycle speed of 2.5 seconds for online slots. We acknowledge the concerns expressed by some stakeholders that 2.5 seconds may not be long enough to introduce sufficient friction but it is important to consider the requirement as part of a wider package of measures designed to reduce the overall intensity of gameplay and protect consumers from harm.

The introduction of a minimum spin speed which mirrors B3 gaming machine content in the retail sector, should not be seen as an indication that 2.5 seconds is perceived as a ‘safe’ or ‘unsafe’ game cycle speed. It will create parity between the online slots and offline B3 machine spin speed (mostly slots). This will provide a baseline for evaluation and any future action.

The wording of the requirement has been updated slightly so it further aligns with game cycle definition in the machine technical standards. This definition is well established and understood by the industry.

A game cycle is initiated by player action such as depressing the start button and the next game cycle cannot be started until the previous one has been completed. The wording of the proposal was not an attempt to remove auto-play, as the consultation also contained a separate section for this feature. The inclusion is to mitigate one of the simpler circumvention methods.

Feature/bonus rounds which are awarded from the ‘base’ game are part of the same game cycle, providing no additional funds have been wagered. As the minimum spin speed is only applicable to slots, well known game elements such as splitting or doubling in blackjack are not relevant to this proposal.

Any game played with funds made available to a customer in lieu of stake, such as bonus funds, are treated as a game funded by a customer’s own funds and are subject to the minimum 2.5 seconds spin speed.

Implementing this proposal is a key part of our effort to reduce the risk of harm from online slots. The risk of consumers choosing to avoid the minimum spin speed by playing on illegal websites will be subject to close monitoring. Our approach is to continue to tackle unlicensed operators targeting British consumers alongside improving standards in the legal market.

This requirement will come into force on 31 October 2021.

New requirement

RTS requirement 14D

It must be a minimum of 2.5 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 14D

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.

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Prohibiting multiple slot games
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Prohibiting player-led “spin stop” features
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