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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. Conclusions


Speed of play was identified as one of the most important factors in making a gambling product addictive and dangerous. As a precautionary measure, there should be a reduction in speed of play across all products.

There should be strict limits on both stake sizes and prize sizes participants talked about a negative intensity driven by both these factors, along with speed of play.

Participants advised that mandatory limits should also apply to the amount of time gamblers were allowed to spend within games, as well as the speed of play.

While there should be strict limits in terms of time and affordability, these should not be different for those “more” or “less” at risk as ultimately, anyone can become at risk.

Original products should be designed from the beginning to be safe and that a proactive and precautionary approach should be taken, including on limit setting, with markers of harm acknowledged in the public domain

Independent research needs to be commissioned immediately to establish the relative importance of different factors in the addictiveness and danger of any gambling product. Meanwhile a precautionary approach must be adopted since we know that there are addictive products already on the market.

It is not appropriate for any ‘testing lab’ to be run by the BGC or industry body. There must be independent input into any ‘Sustainable Product and Game Design working Group’ and a ‘Testing Lab’ needs to be run independent from the industry.

No new product should be allowed onto the market without having been approved as safe by an independent authority. All existing games should be subject to similar approvals and licensing.

All gambling products should be classified according to their addictiveness – similar to class A, B or C drugs or green, amber or red labelling on food.

Analysis of the responses to the GamCare Forum Survey showed that the following were associated with excessive play:

  • speed of play
  • stake levels per spin
  • bonus features
  • large jackpot
  • game modes such as 'turbo' or autoplay.

There was a broad support for a maximum stake limit per spin, with the modal number given at £1 (£2 and £5 also figures given by a number of respondents) and also support for different stake or loss limits or different approaches set for consumers subject to their personal circumstances. In terms of support for tools to limit harm, the most popular options were being required by the design to take a break and a maximum stake per spin and ease of withdrawal.

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Expert Groups input to Commission thinking
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Commission Assessment
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