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  3. Summer 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response

Consultation response

Summer 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response

This response sets out our position in relation to the consultation on the proposed changes to LCCP and Remote Gambling and Software Technical Standards.

Published
1 May 2024

Last updated
1 May 2024 - Changes

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Contents

Costs, timings and testing of games

Some operators cited large numbers of games that may require retesting if the proposals from our consultation became requirements. As a reminder of our testing strategy, an update that does not impact game fairness is referred to as a minor update and can be released without the need for external retesting.

Removing features which are added on top of games can likely be achieved without updates to critical game files and are unlikely to need external testing. Some of the quotes for costs associated with these proposals appear to be based on creating new titles rather than updates and as a result appear high. The costs also depend on how an operator chooses to implement the new requirements. As pointed out in the ‘speed of play’ section, games that are in scope for that 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.

Industry respondents typically asked for between 6 to 12 months to implement the proposals. The Gambling Commission has responded to stakeholder feedback to ensure the final requirements can be implemented smoothly. We are mindful that with multiple consultations impacting industry, including the Department for Culture, Media and Sport (DCMS) stake cap for slots there may be competing priorities for a development team. In order to account for these pressures, the implementation date for the updated ISO standards is 31 October 2024 and all other requirements has been set as 17 January 2025.

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