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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.
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The imposed limit should serve as a maximum stake which customers can choose to stake up to, rather than as a new default which operators drive customers towards, or which is otherwise seen as objectively ‘safe’. We believe these limits will achieve the government’s stated objectives of reducing the risk of gambling-related harm, with a lower risk of unintended consequences and less disruption to the majority of gamblers who do not suffer harm. This extensive selection ensures an engaging and high-quality gaming experience for your audience. Our support team is ready to address any technical issues promptly, including incident management support, system error resolution, and troubleshooting gameplay problems.
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However, some industry respondents felt that a two-tier limit was still preferable to a universally low limit for all adults, despite the additional implementation challenges. However, some industry respondents were much more supportive of a separate age limit for young adults which recognises the particular risks for that cohort, and aligns with the broader aims of the white paper in protecting vulnerable groups. These respondents argued that a separate limit could be unfairly discriminatory and provide a precedent for discrimination based on other protected characteristics.
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We have considered feedback from respondents, including the concerns raised by operators in relation to the proposed description of ‘online slots’ where the proposed wording extended the definition established by the Gambling Commission in 2021. Many of these respondents considered that the proposed description was unclear or open to loopholes and may result in inconsistent application of the stake limit, but did not give specific examples of how it might be circumvented. A few respondents suggested that independent and accredited test houses should be responsible for classifying games rather than operators who may subjectively interpret whether a game meets the slots definition or not. ‘Maximum stake per spin’ means the maximum amount a player can pay or risk per spin or game cycle. While stakeholders broadly recognise online slot-type products as a distinct class of remote casino game and have an intuitive understanding of the key terminology such as stake and game cycle, these terms are not all defined in legislation.
These were considered separately to the case for a lower limit for young adults, which is discussed in Part 3 below. In line with the white paper commitment, the consultation outlined 4 options for consideration. If any of these descriptions prove too narrow to effectively deliver the policy intent, then both the government and the Gambling Commission will look to revise it. These respondents disagreed for different reasons, with some saying it was unclear, others arguing it was too restrictive, and others saying it was not restrictive enough and might contain loopholes. A frequently expressed opinion amongst industry respondents was to keep the description exactly aligned with the already established and widely understood Gambling Commission definition. Some operators responding to the consultation raised technical concerns about the description, where the proposed wording extended the definition established by the Gambling Commission in 2021 in an effort to ensure boundary pushing products are captured.
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Some respondents also referenced evidence that some ethnic minority groups have a higher risk of problem gambling or being an affected other. A few respondents cited evidence that people with learning disabilities / on the spectrum of learning needs are at a greater risk of suffering gambling-related harms. Several respondents highlighted the difference in problem gambling rates between men and women. A separate limit for young adults aligns with the wider government approach to gambling of targeted and evidence-based interventions for those at risk, while not unduly restricting others.
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This highlighted the overrepresentation of customers identified as high risk among high stakers, although this data could not explore the cause of such overrepresentation. In addition to the views and evidence provided through the consultation, DCMS has considered a wider body of background information to guide decision making. Parts 1 to 4 of this document sets out respondent views and evidence on each section of the consultation before outlining the government response and intended action in each area. During this time, 98 submissions were received, including 4 by email and 94 via our survey platform. In April 2023, DCMS published the white paper on gambling setting out the government’s plans for bringing the regulation of the gambling sector into the digital age.
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- 30% of respondents selected Option A (a £2 stake limit for young adults 18 to 24) and 3% of respondents selected Option B (a £4 stake limit for young adults aged 18 to 24).
- Following this transition period, if operators are unable to develop solutions to adequately distinguish between customers who are 25 and over and those who are under 25, the expectation is that they will not be able to offer any customers stakes exceeding £2 per spin.
- Remote controls are limited in function, and typing can be slow.
- There is clear evidence of an increased risk of gambling-related harm among young adults, which can reasonably be concluded to be exacerbated by access to high stakes, rapid, and repetitive play on online slots.
- The primary difference is at staking levels over £10, which take up a lower proportion of overall stakes for young adults aged 18 to 24 than those 25 and over.
Respondents also highlighted the importance of retaining consumer choice and the risk of consumers moving to the illegal online market if they are no longer able to stake at their preferred levels. We received 98 responses to the consultation, including 46 individual respondents and 52 from organisations. Operators currently offer stakes from as little as one penny per spin, and we would expect a range of staking options far below the maximum to remain available.