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October 2019: Industry Challenges

Phase one of the Gambling Commission’s Industry Challenge initiative, set at our industry briefing in October 2019.

  1. Contents
  2. Game design
  3. Commission Assessment

Commission Assessment

We are concerned that as technology and digital approaches evolve rapidly, the techniques that the industry plans to use when designing products and apps, and online games in particular, must be designed with consumer safety at the heart.

Questions around game design can be complex but we think there are opportunities around intensity, stake and time, which a pro-active industry should be keen to grasp, especially in light of the current reliance on slots and on line with the advice we have received from the ABSG and DAP referenced at the start of this report.

Industry has produced a draft code which includes some positive suggestions around removing game cycle intensity, particularly by implementing a minimum game speed and removing features designed to make play faster such as turbo or slam-stop. In addition, the code will remove split-screen slots games, which have been associated with intensive play and highlighted as a potential risk.

In our view, these changes represent some initial tangible actions which are likely to move the debate on at least partially. If delivered within a quick timeframe, these changes would make slots games partially safer for consumers.

We do however feel that it falls significantly short in the following areas.

No firm commitment to immediately start using demographic or behavioural proxies to identify those at greater risk of gambling harm and setting differential limits (such as stake, time or spend) for those groups as a result.

This should include the following in the shorter term:

  • no action on adopting a maximum stake per spin, which can be adjusted upwards on the satisfactory completion of enhanced due diligence
  • no action on adopting a differential approach to slow down lengthy sessions of play, for example less than 60 minutes, which may include slower spin speed after 60 minutes play
  • no action on other areas such as celebration of wins below stake level which were considered in the working group but did not make the final list of commitments
  • the proposed timetable of actions (September 2020) does not seem fit for purpose, especially against the backdrop of a shift to online gaming or slots as a result of the Covid-19 crisis.
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