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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.

Prohibiting effects that give the illusion of “false wins”

We proposed changes to ensure that returns equal to or below stake must not be celebrated in the same way as a “true win”. This is because we are concerned with the fairness of these celebratory effects, as we consider it important that consumers are empowered to use information about their play to make informed decisions.

We are also aware of the potential psychological effects of indicating wins more frequently than is actually the case, as this could induce a hot state which has been associated with gambling related harm.

Consultation question

Q20. Do you agree with the proposal to require returns below or equal to total stake, to have no sounds or visual effects that are associated with a win?

Respondents’ views

61% of public respondents either agreed or strongly agreed that audio and visual events representative of a win above total stake should not be associated with wins below or equal to stake. A lower figure of 15 (32%) members of the public were not in favour of the proposal to restrict the celebratory aspects of a losing game cycle either disagreeing or strongly disagreeing with the proposal.

22 operators disagreed or strongly disagreed with our proposal to restrict celebratory events for wins below and equal to total stake, whilst 17 operators were in favour of the introduction by either agreeing or strongly agreeing.

Multiple operators mentioned that games will need a significant amount of reworking including and not limited to redesign, development, internal and independent testing. Concerns were raised about delays due to test house demand. Several operators stated that all games may require third party test certification.

Seven operators estimated an implementation timeframe in excess of 12 months to make these changes. For operators that have an extensive suite of games, anticipated implementation time for games to adhere to the proposed requirement would be longer. Inclusion of back catalogued games will potentially increase the estimated turnaround times and it was noted from the responses that implementation time was difficult to predict due to uncertainty of the inclusion of back catalogue games.

An operator stated that additional staff will need to be hired to deliver this requirement as their roadmap is fully committed for 2021. The respondent pointed out that there is ongoing business to consider in addition to existing market commitments.

One respondent pointed out that for smaller suppliers this requirement could and will likely mean they are unable to bear the financial burden of operating in the UK market.

Various members of the BGC led game design working group suggested that we should introduce the celebratory restrictions within the BGC game design code of conduct (opens in new tab). Game code modifications will apply to returns below total stake, although the commitments exclude returns that are equal to the total stake value.

A small number of respondents raised concerns about accessibility. It was mentioned that ‘audio prompts and large win text are mechanisms used to present information clearly’.

Several respondents stated clarity for the celebration level is required, examples such as font size for messaging and length of audio were raised. One operator mentioned that the ‘nature of enforcing this requirement in their development as a slot supplier will be very subjective as the line between information and celebration is vague’.

A few respondents referred to a losses disguised as wins (LDW) as a sub-stake win. One operator mentioned that ‘almost all slots in the market contain this kind of win, and without it, games would be extremely volatile, and extremely harmful to players’.

Our position

After consideration of the responses, we will introduce the requirement as proposed in the consultation. This requirement will help to make games safer for players by helping increase their understanding of their play experience, particularly by balancing the following risks against the potential cost and complexity of implementation:


We are concerned with the fairness of these celebratory effects, as we consider it important that consumers are empowered to use information about their play to make informed decisions. This includes whether the outcome was a true ‘win’ in the sense that it returned more than their ‘total’ stake and is a relevant consideration for all online slots players.

Potential impact on gambling behaviour

We are also aware of the potential psychological effects of indicating wins more frequently than is actually the case, as this could induce a hot state which has been associated with gambling related harm.

Several pieces of research have emphasised the psychological and physical changes that occur with consumer experience of losses disguised as wins.

The combination of these risks makes it important in our view to take this action, understanding that this could have sizable implication for some licensees. This requirement spans two licensing objectives and given the size of the risks we view this as proportionate to help make online slots games safer by design for consumers.

We did not consult on prohibiting slots games from returning amounts below (or equal to) stake, as seems to be the interpretation by some respondents. Instead the consultation was about limiting the celebratory effects to clearly distinguish a net losing spin from a net winning spin.

Whilst clarity has been sought about the type of audio and style of graphics, the requirement will remain high level and principles based. Extensive sound libraries and graphics that can be utilised within a game means we do not propose to be overly prescriptive, consistent with our wider approach to regulation. That said we have enhanced the proposed guidance to include guidelines for reasonable steps to inform the customer of the result of their game cycle.

We have also updated the proposed guidance to remove the previous explicit reference to “win”, as we are content that the guidance at 14F(a) provides sufficient cover in this regard and is high-level enough to incorporate future innovation in this area.

Licensees must assess if the audio and visual events that are implemented within their games satisfy the requirement, however they also need to ensure that the outcome of a game cycle is transparent and can be sufficiently understood by a consumer (as per RTS 7E8).

Several operators suggested utilising celebration levels that the BGC led game design working groups have included in their code. Whilst we welcome the introduction of this code, our proposal goes further as it includes prohibition of celebrating a financial return which is of equal value to the amount staked. From a fair and open perspective, we want consumers to be able to understand the differences between a spin where they have made a net gain and others, including where they may be losing money.

We also noted requests to exclude all back-catalogue games and we have considered the views provided, including some of the challenges around implementation. We have concluded that if the requirement were to be applied to newly developed games only, a large proportion of slot games would still contain the celebratory aspects for returns below and equal to total stake and that the risk to consumers would not fully be addressed.

The requirement will therefore apply to all slot games regardless of release date. We have considered estimated timeframes which have been projected to re-design, re-develop and test games, although timescales were not provided by some respondents as clarity was being sought about historical game inclusion.

The new requirement comes into force on 31 October 2021.

Any games not compliant by this date must be removed from the market until such time as they are updated.

We have slightly updated the wording and expanded the guidance to provide clarity. The new requirement is:

RTS requirement 14F

The gambling system must not celebrate a return which is less than or equal to the total stake gambled.

RTS implementation guidance 14F

a. By ‘celebrate’ we mean the use of auditory or visual effects that are associated with a win are not permitted for returns which are less than or equal to last total amount staked.
b. The following items provide guidelines for reasonable steps to inform the customer of the result of their game cycle.
i. Display of total amount awarded.
ii. Winning lines displayed for a short period of time that will be considered sufficient to inform the customer of the result. This implementation should not override any of the display requirements (as set out in RTS 7E).
iii. Brief sound to indicate the result of the game and transfer to player balance. The sound should be distinguishable to that utilised with a win above total stake.


8 The result must be displayed for a length of time that may reasonably be expected to be sufficient for the customer to understand the result of the game or event in the context of their gamble.

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