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.
Contents
- Executive summary
- Summary of topics
- Topic 1 - Improving customer choice on direct marketing: Consultation Response
- Topic 2 - Strengthening age verification in premises: Consultation Response
- Topic 3 - Game design: Consultation Response
- Topic 4 - Financial vulnerability checks: Consultation Response and Financial risk assessments pilot: Consultation Response
- Topic 5 - Personal Management Licence: Consultation Response
- Topic 6 - Changes to Regulatory Panels: Consultation Response
- Evaluating the impact of relevant changes
- Annex
Proposal 5: Operator-led simultaneous products
Proposals
We proposed to widen the restriction on operator-led functionality to play multiple simultaneous games to all gaming (including bingo) and betting on virtual events.
Consultation question
To what extent do you agree with extending the proposal to prohibit operator-led functionality which enables playing multiple simultaneous games to all gaming products? Please give your reasons for your answer.
Respondents’ views
The majority of respondents agreed with the proposal. Gambling operators raised key concerns with the impact on bingo and peer-to-peer poker games.
Respondents commented as follows:
- bingo is not played simultaneously as tickets are bought ahead of time
- clarity was sought on whether further gambling should be blocked if a customer had an open bet
- an operator provided data on the proportion of customers found to be at risk across slots, bingo and combined slots and bingo
- games like bingo and peer-to-peer poker have breaks in play or the customer may be waiting for a good hand and may play other casinos games in the gaps
- bingo is a slower game compared to others
- the proposal does not align with the retail sector where it is common for bingo customers to play other games alongside bingo, such as slots
- a suggestion that prohibiting operator-led functionality which enables playing multiple simultaneous games will be very difficult to implement
- some questioned the evidence which supports the proposal
- several supportive comments mention that simultaneous play can increase immersion which may lead to losing track of time or spend. Others note that playing simultaneous games increases the speed of play.
Our position
Our consultations on game design have focused on features which can speed up play or increase the intensity of gambling products.
This proposal was not seeking to prevent customers who have an open bet from gambling on another product until that bet was settled. It was focused on operator-led functionality which facilitates playing multiple games simultaneously.
Playing multiple games of roulette, blackjack or other similar casino games increases the gambling intensity of the customer and functionality which makes it easier to gamble on multiple products simultaneously could also be seen as a way to circumvent restrictions on speed of play. Given the high loss rate associated with even short sessions of casino games it seems entirely inappropriate to permit such functionality.
From a recent survey the Gambling Commission conducted, respondents with a Problem Gambling Severity Index (PGSI) score of 8 or more were more likely to report playing online casino games on multiple tabs and/or accounts (51 percent) than respondents that scored 3 to 7 (24 percent), 1 to 2 (14 percent) or 0 (12 percent) on the PGSI.
We agree that bingo games which do not allow further entries are not played simultaneously along with other products. Betting products are not played simultaneously either and as noted this proposal was not looking to prevent customers with open bets from other gambling. We have considered views on the impact of including bingo and peer-to-peer poker in scope for this proposal. We are mindful that restricting functionality for bingo games may lead to an increase in complaints due to the removal of expected functionality.
Similar arguments apply to the inclusion of peer-to-peer poker. Poker is a slower game where consumers may be waiting a while before they bet on a hand. This means where secondary games are played, they are unlikely to be simultaneous. As the Patterns of Play research (opens in new tab) found, ‘Poker also stands out as a time-intensive rather than money-intensive activity, with a rate of spending of 18.9 pence per minute’.
We are also aware that restricting operator-led functionality which facilitates playing a second game type would not remove this risk as determined online consumers would still be able to play multiple products at the same time using multiple accounts.
For these reasons we have removed bingo, virtual betting and peer-to-peer poker from the scope of this requirement following consultation.
The final requirement will apply to casino only (excluding peer-to-peer poker).
Final wording
This requirement will come into force on 17 January 2025.
Applies to: Casino (excluding peer-to-peer poker).
Remote gambling and software technical standards (RTS) requirement 14C
The gambling system must not offer functionality which facilitates playing multiple games at the same time.
RTS implementation guidance 14C
- Operators are not permitted to offer functionality designed to allow players to play multiple games at the same time. This includes, but is not limited to, split screen or multi-screen functionality.
- Combining multiple games in a way which facilitates simultaneous play is not permitted.
Last updated: 1 May 2024
Show updates to this content
No changes to show.