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Industry respondents expressed concerns about the impact of a stake limit on innovation within games. A similar number of respondents focused on the cost to the gambling industry and raised concerns about the displacement of customers to the illegal online market as a result of the introduction of stake limits. A few respondents argued that young people should not be allowed to access online slots games.
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Most advocated for a minimum implementation period of 6 months and suggested that a longer period would be required for age-based stake limits. However, we acknowledge that the implementation of a separate stake limit adds a layer of complexity for businesses in making the necessary changes to software. We believe the evidence justifies increased protections for this cohort, including a separate lower stake limit. Some suggested the existing safeguards for this cohort are sufficient (and will be further strengthened via financial risk checks) and that separate stake limits would be disproportionate and largely ineffective.
While the experience isn’t as interactive or seamless as on mobile or desktop, slot games and live dealer streams are enjoyable on a large screen. We can expect future casino platforms to offer dedicated smart TV apps, enabling fully optimized gameplay from the comfort of your couch. You can navigate to your favorite online casino site just as you would on a computer. To the extent that some gambling harms are more prevalent within young adults, our specific protections for that cohort including the lower proposed maximum stake limit will have a positive equalities impact.
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Some noted that many gambling operators already offer additional protections for customers aged 18 to 24 such as restrictions on high-value customer schemes, lower deposit limits, and bespoke social media advertising requirements. Others felt that a two-tier approach to stake limits would only serve to generate further disparity with the land-based sector where the same limits are consistent across all adults. 34% of consultation respondents were in favour of a universal limit of £2 across all adult age groups as the lowest limit within the consultation range. There were a number of views on whether additional protections are needed for young adults and whether a separate lower stake limit should be implemented.
We acknowledge both the calls for further action to prevent gambling-related harm and the risk of unintended consequences. The impact assessment contains a cost benefit analysis and includes further consideration of the information that was not possible for the consultation stage impact analysis. Similar arguments were made for other groups with protected characteristics who may be more vulnerable to gambling-related harms. However, the majority of these respondents felt that younger people needed to be protected because of their increased risk of harm. More than half (52%) of respondents answered ‘Yes’ to the question ‘Are there any additional impact considerations, including on the assumptions in the accompanying impact assessment or on the risk of unintended consequences? 7) Please indicate if you believe any of the proposals in this consultation are likely to impact persons who share such protected characteristics and, if so, please explain which group(s) of persons, what the impact on any such group might be and if you have any views.
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The majority of these respondents had selected the same general limit in the previous question. While online gambling, particularly via smartphone, is by far the most accessible form of gambling, it does afford meaningful protections which cannot easily be replicated offline. We believe that a £5 limit will achieve the government’s stated objectives in a proportionate way, with a lower risk of unintended consequences such as displacement to the illegal online market. In deciding which option to pursue, we have been led by the best available evidence and guided by the overarching objectives of the Gambling Act 2005 Review of ensuring an equitable approach to the regulation of online and land-based gambling. 24 of the 96 responses to this question were from gambling industry representatives, and nearly all argued for a £10 limit to ‘strike a balance’ between protection and freedom. Many of those in support of a £2 limit (Option 1) felt that it was the option most likely to reduce average best casinos not on gamstop losses or to help minimise the risk of runaway losses and therefore have a significant effect in reducing gambling-related harm.
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- This staking data was included in the consultation to assist respondents in forming their own views.
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- Some respondents called for additional measures not in scope of the consultation, including further action on advertising and game design.
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In the Gambling Commission’s participation survey, reporting on data in the year to March 2023, the problem gambling rate for 16 to 24 year olds (1%) was higher than the headline problem gambling rate (0.3%). Respondents who were not in favour of a separate limit raised concerns about some adults being treated differently based only on their age. Respondents also mentioned that younger adults may be less informed on the risks of gambling or may have lower incomes than older adults. It is unclear how many of those who supported consistency in limits for all adults would support a lower limit for young adults if the general limit is to be higher than £2. Our intention is that there will be future opportunities to review and if necessary adjust the limits. The Gambling Commission is also exploring improvements to online harm detection algorithms which will mean other markers of harm are more effectively identified and acted on.
We acknowledge the concerns that this wider description has the potential to unintentionally capture games outside of scope of the stake limit and the intention of the white paper. 65% of respondents who answered this question agreed with the description of ‘online slots’ proposed in the consultation. Online slots are ‘Remote casino games of a reel-based type (including games that have non-traditional reels or which combine elements of other games within a slot game mechanic).’ DCMS has continued to work closely with the regulator in considering the appropriate stake level for online slots, and considering how any new limits will overlap with other measures being consulted on by the Gambling Commission.
Such account-based protections will be further strengthened by proposals for new obligations on operators to conduct checks to understand if a customer’s gambling is likely to be unaffordable and harmful, in the form of frictionless financial risk checks. Around 20% of customers currently choose to stake over £5 on a spin at least once a year (so will be impacted by this measure), but only 0.6% of all spins are over £5. In addition to the formal consultation responses, we also received survey results from 3,898 members of the campaigning organisation 38 Degrees and a petition set up by GWL signed by 12,775 people.
Playing online casino games on a smart TV is possible, particularly through web browsers or casting. Playing online casino games on a smart TV depends on how advanced the TV’s operating system is, the browser or app capabilities, and how you control the interface. A few respondents pointed to the blanket EUR 1 stake limit on online slots introduced in Germany in 2020 and expressed concerns about its impact on the German market. However, the intention is that boundary-pushing products (such as those which combine fundamentally slots-type gameplay elements with other games like bingo – for instance the popular ‘slingo’ game) are captured under the definition of slots and subject to the stake limit.
All online play is account-based, and recent years have seen significant strides in the development of harm detection algorithms which monitor every aspect of a customer’s gambling to spot signs of risk and trigger interventions without human input. Moreover, it takes consideration of the structural differences between land-based in-person gambling and online play. We think that a £5 maximum stake for adults aged 25 and over will help to reduce harm because of the constraint on a player’s ability to place very large stakes quickly. Some respondents called for additional measures not in scope of the consultation, including further action on advertising and game design.
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These games typically include online slots, table games such as blackjack and roulette, and live dealer casino games streamed in real time. An online casino is a digital platform where players can access casino games. A few respondents highlighted the need for appropriate monitoring and evaluation of stake limits for online slots games and called for further evidence in this area. We have committed to introducing a maximum stake limit for online slots games to minimise the risk of runaway or rapid losses which can contribute significantly to gambling-related harm. Many of the 16,000 call for evidence respondents addressed this issue, and specifically supported the introduction of a maximum stake limit for online slots games. As set out in the white paper and the July 2023 consultation, there is strong evidence of product-driven risk from online slots games, which is likely to be exacerbated by the ability for operators to offer theoretically limitless stakes.
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Online casino games are delivered through RNG software, where a random number generator will determine the outcome of a spin or a hand. Online casino games work either through RNG software or live-streaming video equipment with a dealer in a live studio. With the right hardware and setup, smart TVs offer a viable, albeit limited, way to enjoy online gambling.
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Developers are already exploring simplified versions of games tailored to TV interfaces, such as one-click slots or roulette with basic navigation. Technologies like Google Chromecast, Apple AirPlay, and Samsung Smart View allow you to stream your casino session to your TV in real time. Not all games display correctly, and filling out forms can be inconvenient. Platforms offering access to top non-GamStop casino options are increasingly exploring compatibility with smart TVs as part of their user experience strategy. Some respondents felt that this discrimination would be unfair and put young adults at a disadvantage when gambling online.
We are grateful for the time and effort stakeholders committed to help inform and strengthen our policy position. Industry data submitted in response to the consultation highlighted that 38% of people stake over £2 at least once a year, and 20% over £5, but our new data suggests very few of these people stake at higher levels routinely. Following publication of the consultation document, we received further information from operators on how staking patterns vary for young adults aged 18 to 24 and the frequency at which all adults stake over a certain level.
Daily coverage and expert analysis help you stay up to date with key developments in the gambling world. Online gambling is regulated in Malta by the Malta Gaming Authority. The outcome of each round of any game or slot is decided independently through either the RNG software or the dealer. This information can also be used to measure effectiveness in our marketing campaigns or to curate a personalized site experience for you.
High-definition video and real-time gameplay create an immersive experience. A more fluid way to play casino games on a smart TV is by casting or mirroring your screen from a smartphone, tablet, or laptop. Several industry respondents provided suggestions for the length of time required to implement stake limits. Many respondents cited evidence showing that young adults may be particularly vulnerable to gambling-related harm and felt that this justified greater protections either in the form of a separate stake limit or otherwise.
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