Consultation outcome

Consultation on proposals for a maximum stake limit for online slots games

Updated 23 February 2024

Executive summary

Following the review of the Gambling Act 2005, the gambling white paper published in April 2023 set out the government’s plans for modernising the regulation of the gambling sector. It outlined a comprehensive package of measures to introduce robust new protections against gambling-related harm, targeted to minimise disruption for the millions of gamblers who participate with no ill effects.

One of the key proposals in the white paper was the introduction of a stake limit for online slots games. This is in line with one of the Review’s overarching objectives, of ensuring an equitable approach to the regulation of online and land-based gambling, and responds to the evidence of specific risks associated with the availability of high stakes play on online slots games.

The white paper committed to consulting on a stake limit of between £2 and £15 per spin to structurally limit the risks of harmful play including large losses, binge play, and loss chasing. This document sets out four options for consideration and consultation:

• a maximum online slots stake limit of £2 per spin
• a maximum online slots stake limit of £5 per spin
• a maximum online slots stake limit of £10 per spin
• a maximum online slots stake limit of £15 per spin

In addition, the white paper committed to consult on slot-specific measures to give greater protections for 18 to 24 year olds who the evidence suggests may be a particularly vulnerable cohort. In regard to that cohort specifically, this document sets out three further options:

• a maximum online slots stake limit of £2 per spin for 18 to 24 year olds
• a maximum online slots stake limit of £4 per spin for 18 to 24 year olds
• not introducing a specific statutory stake limit for 18 to 24 years olds (meaning they could access the general maximum limits above), but instead introducing specific requirements on operators to consider age as a risk factor for gambling-related harm which could justify a range of mitigations, including limiting access to higher staking opportunities on a case-by-case basis

Alongside consideration of the options above, this document also consults on details to support the effective implementation of the policy, including the meaning of ‘online slots games,’ ‘maximum stake’ and ‘spin/ game cycle’.

The purpose of this consultation is to ensure that the government is able to consider the best available evidence, including on the impact of each option, when finalising policy decisions. A consultation stage impact assessment including a cost/benefit analysis is being published alongside this document. The consultation will be open for 8 weeks, closing at 11:55 pm on 20 September 2023. We encourage all of those with views or evidence on the options above to make submissions via the online survey by that point. The government will then publish a formal response to set out our decision and reasoning before implementing the changes. Any changes to the law will be made by secondary legislation to create a new licence condition on remote gambling firms.

Chapter 1: Introduction

In Great Britain, there are currently no statutory limits on the amount people can stake on any online gambling products. This is in contrast to the land-based sector, where electronic gaming machines (offering games which are otherwise similar to online slots games) are subject to stake and prize limits in legislation. There are no statutory limits on in person betting or other gambling products such as games in land-based casinos.

As set out in the white paper, 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. In line with the formal advice from the Gambling Commission and the general weight of evidence, government has committed to introducing a maximum stake limit for these games to minimise the risk of runaway or rapid losses which can contribute significantly to gambling-related harm. This measure is designed to work in concert with the wider package of policies in the white paper, including financial risk checks, data sharing on high risk customers, and making online games safer by design.

Context and the case for a stake limit

Online slots games contribute a significant proportion of operator profits. According to Gambling Commission industry statistics, in the 2021/2022 financial year online slots contributed over £3 billion to the industry’s Gross Gambling Yield (GGY), which totalled £9.9 billion across the whole online and land-based sector in Great Britain excluding lotteries. This made online slots games a bigger driver of GGY than all online sports betting and online bingo combined.

While participation data is difficult to obtain because many surveys group  online slots with other online casino products and sometimes even bingo and National Lottery instant win games, we know commercial slots have relatively low (albeit growing) participation rates. For the year to March 2023, the Gambling Commission’s quarterly participation and prevalence data found less than 1% of all adults had played any online casino games (including slots) in the month prior to being surveyed. Figure 1 below shows data gathered since the start of the COVID-19 pandemic from major remote operators representing around 80% of the licensed sector on how many accounts actively played slots games, and the GGY their gambling raised.

Figure 1: Online Slots monthly GGY and active accounts from leading operators (c. 80% of the online market) - March 2020 to March 2023

Source: Gambling Commission, Gambling business data on gambling to March 2023 (published June 2023). Note that individuals can be represented more than once if they hold accounts with multiple operators, and the GGY data may include free spins.

This combination of relatively low participation but high GGY means that online slots games are associated with one of the highest average losses per customer of any gambling product. Even within this the losses are relatively concentrated, with 1% of accounts providing over 40% of slots GGY according to the data considered in NatCen’s Patterns of Play research.

While concentrated or high spend does not necessarily equate to harm, there were a number of other signs (explored in full in the white paper) that online slots as currently available involve a number of factors which have been shown to elevate the risk of gambling-related harm to consumers. For example, they are associated with:

Long sessions - over 70% of gaming sessions on a single product type that lasted over 3 hours were on slots, and slots had the highest proportion of players (5.5%) who ever played for longer than three hours.

Binge activity - the Gambling Commission’s research into why consumers gamble found that of the 14% of past month gamblers who reported binge gambling, 24% had done so on online slots - more than any other gambling activity.

Engagement by those who went on to seek support - online slots were the most commonly used product by National Gambling Treatment Service patients in 2021/22; 38.1% had engaged in online slots compared to 11.7% for remote casino games and 16.3% for gaming machines in bookmakers.

Taken together, the general weight of evidence justifies government action which addresses a key structural characteristic (potential for high losses in a short period of time) which is likely a key driver of gambling-related harm among online slots users. We acknowledge, however, that further evidence would be useful to inform precisely what the limit should be to achieve the government’s objectives of effective harm prevention with minimal disruption to those not being harmed.

Current protections

The Gambling Commission introduced new rules in October 2021 to address some of the potentially harmful characteristics of online slots, including to some degree the potential for large and rapid losses. These included imposing a maximum speed of play of 2.5 seconds per spin (in line with land-based equivalents), banning losses disguised as wins, and prohibiting features which increase the intensity of play or give an illusion of control, such as ‘slam stops’, ‘turbo modes’, and functionality which allows auto-play or enables concurrent play on multiple slot games. Slots must also display the money and time spent during a session. The Gambling Commission recently published an assessment of the impact of these changes. It found that the changes have resulted in reduced play intensity with no increase in staking activity in response to the limit on spin speeds, and no significant negative impact on the enjoyment of the games on gamblers.

Some online operators have also already voluntarily introduced a maximum stake limit for online slots, either in response to certain risk triggers or as a universal preventative measure. For example, Flutter introduced a maximum stake limit for slots games of £10 per spin across all of its brands in 2021, in response to its data that showed £10 was an inflection point where customer risk levels started to increase sharply. According to data provided by Flutter ahead of this consultation, the measure impacted the 4% of customers who had staked over £10 on at least one spin in the year prior to implementation.

Online slots are also offered within the wider context of licensed online gambling. This means there are a range of protections at all stages of the user journey, from controls on how online slots can be advertised, robust age and identity verification requirements before accounts can be created and slots accessed, and requirements on gambling operators to monitor a variety of player and play data to identify signs of harm and intervene accordingly. As outlined in the white paper, many of the broader safeguards are being strengthened alongside the introduction of a maximum stake limit for slots games to ensure our regulation is fit for the smartphone era.

Next steps

This 8-week consultation on options will ensure that the government is able to consider the best available evidence in deciding which of the options outlined below to pursue.

Gambling policy is substantially reserved in Scotland and Wales but devolved in Northern Ireland. This consultation relates to online slots games provided and/ or advertised to customers in Great Britain, by operators who are consequently required to hold the appropriate licence from the Gambling Commission.

Responses to this consultation will be reviewed and the draft regulations will be revised appropriately before they are laid before Parliament. The government plans to formally respond to this consultation to announce our decision later this year. We expect any new licence condition to come into force in early 2024. Given the relative ease with which operators can adjust slot stakes and the clear notice of our intention to introduce such a change, we will give a minimum of 6 weeks transition period for operators to become compliant with the new rules.

Chapter 2: The scope of limits

Under Section 78 of the Gambling Act 2005, the Secretary of State may provide for a specified condition to be attached to gambling operating licences through secondary legislation. We intend to use this power to attach new conditions to remote casino operating licences, specifying the maximum stake per spin permitted for online slot games.

However, there is no statutory definition for most subtypes of gaming in the Gambling Act 2005, such as ‘slots’ or ‘roulette’. While there are product categories for gaming machines in the land-based sector, these are agnostic to game type and instead defined in terms of the limits on structural characteristics, such as on speed of play and the maximum prize value. Slot-type game variants are found across all gaming machine categories, with maximum stakes varying from £5 on B1 machines to 10 pence on category D machines.

Therefore, while stakeholders broadly recognise online slot-type products as a distinct class of remote casino game, this will need to be formally set out in the statutory instrument to determine the scope of the limit on stake size. We are seeking a precise description which catches the intended game types and does not create loopholes or incentivise the development of products which are functionally similar but might be argued to be technically exempt (such as those which combine fundamentally slots type gameplay elements with other games like bingo). Similarly, the description should provide clarity to stakeholders as to the regulatory status of certain gambling activities.

In 2021, the Gambling Commission introduced rules which apply specifically to online slots in its Remote Technical Standards. For these purposes, slots are defined as: “casino games of a reel-based type (includes games that have non-traditional reels)”. The Gambling Commission consulted on this definition before introducing the new rules, and considered a number of amendments and / or alternatives suggested by stakeholders. It ultimately concluded that this definition was well-understood across the different types of stakeholders, and was sufficiently specific to prevent catching non-slot games (particularly if applied to remote casino licensees) while minimising the risk of circumvention. We agree with this assessment, and our aligning with the Gambling Commission will avoid unnecessary complexity in the regulatory framework and reduce the risk that some products fall within scope of one definition of slots and not the other.

For the purposes of this consultation, we therefore consider online slots to be:

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).

We are aware that some operators have subsequently sought to challenge the Gambling Commission’s definition, with a view to exempting some of their products from the game design requirements specific to slots games and the government’s intended stake limit. Our view is that the description above is clear on the types of game in scope, but if necessary the Gambling Commission has powers to update the remote technical standards definitions to respond to emerging risks or boundary pushing products.

Consultation question 1:

For the purposes of introducing a maximum stake limit, the government intends to align with the definition of online slots used by the Gambling Commission. We therefore intend for the limit to apply to:

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).

1a) Does this description of online slots adequately describe the products intended for inclusion in the maximum stake limit’s scope? (Mandatory response)

[Yes / No / I don’t know]

1b) Please explain your answer. (Optional response)

[Open text box]

The legislation must also define what is meant by a “maximum stake.” “Stake” is defined in section 353(1) of the Gambling Act 2005 as follows:

“stake” means an amount paid or risked in connection with gambling and which either-

• i. is used in calculating the amount of the winnings or the value of the prize that the person making the stake receives if successful, or
• ii. is used in calculating the total amount of winnings or value of prizes in respect of the gambling in which the person making the stake participates

However, it may be simpler to think of a stake from a customer rather than operator perspective. Therefore, we consider the description of stake below to be the most suitable for the purposes of this consultation. Sometimes operators add a bonus to the stake as a promotional device, but here the stake is taken to refer only to the customer’s own money put at risk.

‘Maximum stake per spin’ means the maximum amount a player can pay or risk per spin or game cycle.

To note, our intention is that 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’. Operators currently offer stakes from as little as 1 penny per spin, and we would expect a range of staking options below the maximum to remain available.

Consultation question 2:

The government is developing a description of a maximum stake. This description will be adapted in legislation to introduce a maximum stake limit. The proposed description of a maximum stake is:

‘Maximum stake per spin’ means the maximum amount a player can pay or risk per spin or game cycle

2a) Is this description of stake suitable for the purpose of the introduction of a maximum stake limit for online slots games? (Mandatory response)

[Yes/No/I don’t know]

2b) Please explain your answer. (Optional response)

[Open text box]

Again, the concept of a slots ‘spin’ is well understood among stakeholders, but for clarity we use the term in a way consistent with the Gambling Commission’s Remote Technical Standards which defines a game cycle as:

A game cycle starts when a player depresses the ‘start button’ or takes equivalent action to initiate the game and ends when all money or money’s worth staked or won during the game has been either lost or delivered to, or made available for collection by the player and the start button or equivalent becomes available to initiate the next game.

Consultation question 3:

For the purposes of introducing a maximum stake limit per spin or game cycle, the government intends to align with the definition of game cycle used by the Gambling Commission’s Remote Technical Standards. Game cycle is defined as:

A game cycle starts when a player depresses the ‘start button’ or takes equivalent action to initiate the game and ends when all money or money’s worth staked or won during the game has been either lost or delivered to, or made available for collection by the player and the start button or equivalent becomes available to initiate the next game.

3a) Is this description of game cycle suitable for the purpose of the introduction of a maximum stake limit for online slots games? (Mandatory response)

[Yes / No / I don’t know]

3b) Please explain your answer. (Optional response)

[Open text box]

As outlined in the white paper, we do not intend to introduce a maximum stake limit for online games other than online slots. This is due to the typically slower spin speeds, a range of other controls on structural characteristics which are being consulted on by the Gambling Commission, the functional role of stake variation in non-slots gameplay (including to mitigate risk), and the less clear-cut evidence of a product-driven association with harm. In our view, the descriptions above are clear on which products fall within or out of scope.

We also do not intend to introduce maximum prize limits for online slots games as exist for land-based gaming machines. Submissions to the review call for evidence focused on the risks posed by high stakes, especially in the context of high speed games like slots, rather than the potential for high maximum prizes to cause harm. With the imposition of a stake limit, we expect maximum prizes will also shrink as operators adjust their commercial exposure. Following the white paper commitment, some operators have told us they expect that game development is likely to trend towards less volatile slots products which are designed to keep customers engaged without the pull of high stakes and prizes.

Chapter 3: Data and considerations for a maximum stake limit for online slots games

In line with the overarching objectives of the Review of the Gambling Act 2005, our aim is to strike an appropriate balance between preventing harm and preserving consumer freedoms. In setting out the options below, we are seeking to understand the various impacts across industry, society and on individuals. Further consideration is given to these issues in the impact assessment being published alongside this document.

A further overarching goal from the review was to level the playing field between offline and online gambling, and the terms of reference highlighted the need for an equitable rather than necessarily identical approach between the two sectors. The Gambling Commission’s formal advice to our Review was that a starting point for determining the appropriate maximum online slots stake levels could be considering the current limits on electronic gaming machines, and then the structural differences between those and online play. This could include:

Accessibility: There are no supply-side restrictions on the accessibility of online slot products, which are available to consumers 24 hours a day and often with the immediacy of a readily accessible smartphone. In contrast, a player’s access to electronic gaming machines is subject to factors such as the location and opening times of gambling premises, as well as limits on the number of machines that may be operated in each venue.

The wider package of protections in place: Online gambling is account-based, giving operators a detailed understanding of the person playing and whether they are at risk of suffering harm. This underpins a range of protections applied at an account level and across products. These background safeguards are being continually strengthened including through the Gambling Commission’s new customer interaction requirements and guidance, and the introduction of financial risk checks for high spending customers. In contrast, play on land-based gaming machines is often anonymous, although staff are on site and able to intervene.

Game design: While the Gambling Commission’s remote technical standards and machine technical standards apply similar controls with regard to online and offline slot games including on speed of play, the remote sector offers a wider and more rapidly evolving product mix. A single digital gaming machine cabinet might typically offer in the region of 100 to 200 variations of slots games, whereas online there are thousands of functionally similar but visually varied games available.

Box 1: International approaches

Several governments and regulators in other jurisdictions have mandated stake limits for online slots games in recent years, often in line with longstanding limits on land-based gaming machines in those jurisdictions. Other jurisdictions have opted for different approaches such as not licensing the provision of higher risk online casino games like slots, or introducing cross-product deposit/ loss limits to minimise the risk of gambling-related financial harm. The experience of other jurisdictions is being considered as part of this consultation process, but each jurisdiction has a unique historical and socio-economic relationship with gambling, and measures which are effective or ineffective in one jurisdiction may not have a similar impact elsewhere. Measures adopted worldwide include:

• Germany: Overhauled its regulatory framework for gambling in 2021,and introduced a €1 maximum stake limit for online slots (to bring it in line with its land-based sector). Spins cannot be quicker than every 5 seconds.
• Greece: Introduced a €2 maximum stake limit for both online slots and other online casino games in 2020. However, this was increased from €2 to €20 per spin in 2022 following a review.
• Spain: Spanish law has no limits on stake per spin for any online product — however, operators must establish daily, weekly and monthly deposit limits for player accounts. The Spanish regulator is proposing new rules, including session-based loss limits for online casino gaming where players would have to set a time limit and net spend limit at the start of every session.
• Italy: Similarly, Italy does not have slot specific limits, but players are required to set account level (monetary) limits of their own choice which apply across products.
• Czech Republic: Introduced stake and prize limits across land-based and remote gaming to reduce the risk of harmful gambling. For internet games, the bet on one game must not exceed CZK 1000 (approx £35) and the winnings from one game must not exceed CZK 500000 (approx £18000).
• France: Online slot games and most other remote casino games cannot be offered by licensed operators.

Factual information and data

To help inform responses, this section sets out some of the best available descriptive statistics on online slots and how they are currently offered and used. The Gambling Commission has made a formal data request to industry using its regulatory powers, in order to provide more detailed advice to the government ahead of our making a final decision and preparing a final impact assessment. That data will where appropriate be published with the government response to this consultation, however we do not expect it to vary significantly from the currently available information outlined below.

Since March 2020, the Gambling Commission has been collecting and publishing detailed information from online gambling operators. This includes a detailed breakdown of staking patterns with leading operators who represent approximately 80% of the online gambling market (but given size and product mix they may not be fully representative of all online slots providers). The data for the 2022/23 financial year covers some 76 billion individual staking events (spins), and shows that high stakes are very rare, with stakes over £20 comprising just 0.02% of all spins. To note, the collected data did not distinguish between stakes above and below £15 within the £10.01 to £20 bracket, however based on the best available data we estimate half of those stakes were above £15, and half below. We have also estimated the importance for revenue of different staking bands within the current framework.

Figure 2: Staking behaviour on online slots in 2022/23 financial year and estimated importance for GGY of different staking bands

Stake size	Individual spins at given stake	% of all stakes	Estimated % of slots GGY derived from stakes in each band*
£1 and below	69,818,001,655	90.96%	69.39%
£1.01 to £2	4,683,732,773	6.10%	12.55%
£2.01 to £5	1,832,226,925	2.39%	10.65%
£5.01 to £10	356,699,701	0.46%	4.78%
£10.01 to £15	24,882,820 (estimated)	0.03% (estimated)	0.59%
£15.01 to £20	24,882,820 (estimated)	0.03% (estimated)	0.85%
£20.01 to £50	18,217,617	0.02%	1.06%
£50.01 to £100	687,791	0.00%	0.09%
>£100	108,758	0.00%	0.04%
Total	76,759,440,860	100%	100%

*This assumes all slots games have a 95% return to player, and the distribution of spend within each bucket is modelled as non-linear. Source: Gambling Commission, market impact data

While high stakes are rare in the context of all spins, it is clear that individual players often vary their stakes over the course of a year, for instance just after big wins, to meet any rewagering requirements on bonuses (being separately considered by the Gambling Commission), or just to maximise enjoyment at certain times. Flutter told us that in the year before its imposition of a £10 stake limit, 4% of players staked over £10 on at least one spin, and that under the new limits approximately 9% of  players staked over £5 over the course of 2022. However, even among these players most staking is at lower levels, and Flutter reported that prior to its stake cut just 0.1% of slots players staked over £10 for more than half of their total number of spins.

As outlined in the white paper, a data request to industry in April 2021 alongside the review call for evidence provided important insight into how stake sizes are associated with harm, as measured by operator-assigned risk scores as the best available proxy. This highlighted the overrepresentation of customers identified as high risk among high stakers, although this data could not explore the cause of such overrepresentation. However, it also found that even high risk players play mainly at low stakes. The white paper gave fuller consideration to the data, including its limitations. We note that distributions may have changed as operators’ algorithms and approaches (including voluntary slots stake limits) have continued to evolve.

Figure 3: % of spins by stake size and operator assessed harm detection score

Stake size	Not flagged	Low	Medium	High	Total
≤ £1	63%	22%	12%	2%	100%
£1.01 - £2	53%	26%	17%	4%	100%
£2.01 - £5	48%	26%	19%	7%	100%
£5.01 - £10	41%	25%	22%	11%	100%
£10.01 - £20	38%	24%	23%	15%	100%
£20.01 - £50	42%	23%	23%	13%	100%
£50.01 - £100	35%	18%	29%	19%	100%
> £100	36%	20%	21%	23%	100%

Source: Gambling Commission Data request April 2021

Box 2: Summary of best available statistics about current slots play

The below is based on Gambling Commission market impact data for 2022/23 which covers approximately 80% of the online gambling market by GGY.

• The mean stake size is 60 pence
• The average online slots session length is 17 minutes, but about 15% of slots sessions last over an hour
• The average number of spins per session is 145
• The average loss per session is £4.26
• The quickest slots game cycles can happen is every 2.5 seconds, but, we estimate the average spin takes approximately 7 seconds
• While there are currently no statutory limits on stakes, most operators offer minimum stakes of between 1 penny and 10 pence per spin, up to maximum stakes of between between £10 and £50 per spin. We have heard reports of (but been unable to confirm) some licensed operators offer spins of up to £500 for certain individuals on certain games.

Any of the options under consideration will result in a significant change in the maximum stakes which operators offer. Customers who would have staked above limits will broadly respond in one or a combination of the ways below. This depends on a number of factors, including the level at which the stake limit is set, and each of the possible responses comes with different potential risks or benefits.

Slots play adjustment. When customers are unable to stake at the level they wish per spin, some customers may simply play more spins at a lower stake level, potentially by extending session length or playing more intensely.

Displacement to other products. The appeal of slots play may diminish for some customers if they are unable to stake to a certain level, and they may move to other products in the licensed land-based or online sectors, such as roulette.

Displacement to the black market. While the risk is not a reason to forgo changes to make licensed products safer and we are taking wider action to improve the regulator’s ability to disrupt illegal operators, a proportion of slots players who cannot access their desired stakes in the licensed sector may turn to unlicensed providers. These providers are easy to access online and do not offer the wider player protections which are required with a Gambling Commission licence. We expect the overall black market risk to be higher for the lower limit options considered below (which are likely to have a greater impact on player behaviour and spend in the licensed sector).

Spend less overall. Some customers will moderate their gambling behaviour in response to new limits, and spend less. Our intention is that particularly those customers who are at risk of incurring harmful losses could have this prevented or substantially mitigated by playing at lower levels. However, we recognise those already in the grips of an addiction are the most likely to respond to the stake limit in other ways than reducing spend.

The information provided to DCMS by Flutter helps illustrate these potential customer responses. It found that following the implementation of the £10 limit, the number of stakes between £5 and £10 increased, suggesting many players simply reduced the stakes they played with, but may have moderately increased their number of spins to stake the same amount overall. In Flutter’s experience there was no evidence of displacement to other products, but they estimate approximately a quarter of the revenue derived from stakes over £10 was lost, with customers going either to other licensed operators offering higher stakes slot play or to the black market. A range of other safer gambling measures such as account level controls and the online slots game design rules were introduced over this period, making it difficult to measure the impact of stake limits in isolation.

Chapter 4: Policy options for a maximum stake limit for online slots games to apply to all adults

The options below relate to the maximum stake limit which would be available to any adult playing online slots with a licensed operator. Specific controls for young adults are considered in the next section.

The limit would apply to all slots games offered by licensed operators, and operators would under no circumstances be allowed to offer higher stakes, even if customers can provide evidence of lack of harm or their ability to afford them. As outlined in the white paper, we considered the case for a tiered limit, but decided on a universal limit given the benefits for speed of implementation, clarity for businesses and consumers, and lower dependence on wider harm detection algorithms which we do not yet consider to be sufficiently established safeguards across all remote operators.

Our intention is that no matter what option is chosen, there will be future opportunities to review and if necessary adjust the limits. For instance, on several occasions in previous years, the limits on land-based gaming machines have been adjusted to reflect the impact of inflation.

Options

Option 1 - A maximum online slots stake limit of £2 per spin

As the most restrictive option under consideration, a £2 stake limit on online slots would have the greatest impact on consumers and businesses. It would align online slots limits with those on widely available B3 gaming machines in high street gambling premises such as bookmakers, bingo halls and arcades, although they have different wider requirements on monitoring and intervening with players.

While 97% of all individual online slot stakes are below £2, operators have reported to us that as many as 35% of online slot players stake over £2 on at least one spin in a given year. They would not be able to do so within the licensed sector if this option is chosen. Stakes over £2 currently contribute an estimated 18% of slots GGY.

Option 2 - A maximum online slots stake limit of £5 per spin

A £5 limit for online slots stakes would align them with the limits on B1 gaming machines in casinos. This is the highest limit permitted on any land-based gaming machine at present.

Stakes over £5 make up just over 0.5% of all staking events on online slots, but contribute an estimated 7.4% of slots GGY. Operators have provided different figures of between 8% and 23% of players currently staking over £5 on at least one spin per year. These customers would therefore be unable to maintain their exact current staking pattern in the licensed sector.

Option 3 - A maximum online slots stake limit of £10 per spin

A £10 limit on online slot stakes is higher than that permitted on any land-based gaming machine. These higher limits are under consideration due to the account based play online and the associated protections which are not required or easily replicable in land based products.

While one large operator reported to us that around 12% of its slots players ever stake at £10 or above in a year, the vast majority will do so only very occasionally, so the disruption to them is unlikely to be severe. According to the April 2021 data request, around 37% of all stakes placed above £10 were made by high and medium risk players. Our data suggests around 2.6% of slots GGY came from stakes over £10.

Option 4 - A maximum online slots stake limit of £15 per spin

A £15 limit on slot stakes would result in the smallest change from how consumers currently play on online slots, impacting only a small minority of habitually or occasionally high-staking players. While playing with high stakes does not necessarily cause harm, the data in figure 3 above does highlight the overrepresentation of customers identified as at high risk among high stakers.

A £15 limit would also have the smallest effect on operator GGY of all the options being considered. Stakes over £15 make up just 0.05% of all staking events on online slots and contribute an estimated 2% of GGY.

Consultation question 4:

The government is aiming to introduce a maximum stake limit that strikes an appropriate balance between preventing harm and preserving consumer freedoms.

4a) What maximum stake limit for online slot games would you support, if any? (Mandatory response)

[£2 / £5 / £10 / £15 / None of the above / I don’t know]

4b) Please explain your answer, providing evidence where possible. (Optional response)

[Open text]

Chapter 5: Considerations and policy options for protecting young adults using online slots

The age of 18 is widely recognised as the age at which one becomes an adult, and gains full citizenship rights and responsibilities. It is the age from which age-restricted products such as alcohol, tobacco and the full range of gambling activities are permitted. However, in light of the evidence that young adults (specifically those aged 18 to 24) may be a particularly vulnerable cohort, the white paper committed to consult on extra slot-specific protections for this group, as well as lower thresholds for financial risk checks. This builds on the extra protections for young adults which some operators have already introduced, but are not consistent across the sector.

According to the Public Health England Gambling-related harms evidence review, the problem gambling rate in the 16 to 24 age group is 0.8%. This age group also has the highest average Problem Gambling Severity Index (PGSI) score (0.26) of any age group. The white paper also considered the evidence on the importance of young adulthood in forming gambling behaviours, and the concerning links between suicide and problem gambling in young adults.

As set out in the Gambling Commission’s formal advice to the review, there are a number of potential factors at play including continuing cognitive development (up to the age of 25), and common life-stage changes such as changing support networks and managing money for the first time. Other evidence considered during the Act Review highlighted that adolescents have a greater risk tolerance compared to older adults and this may be reflected in their attitudes towards gambling. Data included in the Gambling Commission’s remote customer interaction consultation also shows that those aged 18 to 24 have the lowest average discretionary income of any adult age bracket, so may be more likely to suffer financial harm from relatively modest losses.

Allied to the evidence considered above on the product specific risks on online slots, there is a strong case for slot specific measures for this cohort. However, evidence is limited on precisely how young adults (as opposed to all adults) currently engage with slots. The Patterns of Play data in figure 4 below indicates that the typical stake size for online slots for those aged 18 to 24 is lower than for other age groups (with the mean in this July 2018 to June 2019 data set being £1.05 compared to £1.30 across all adults aged 25+), but we lack other important information. We are hoping to address this through a data request to industry which is being made alongside this consultation and will inform the government’s response.

Figure 4: £ average stake size by age group

Age group	Mean stake size (£)	Median stake size (£)
Under 21	£1.11	£0.51
21-24	£0.99	£0.53
25-34	£1.12	£0.57
35-44	£1.08	£0.55
45-54	£1.44	£0.54
55-64	£1.46	£0.50
65-74	£1.21	£0.51
75+	£1.53	£0.50

Source: NatCen Patterns of Play Technical Report 2- Account Data File: Table 16

Alongside the options for slot specific protections outlined below, the white paper proposed other protections for young adults gambling online. Specifically, the thresholds for financial risk checks, where operators will be obliged to consider a gambler’s spending in the context of their financial circumstances for signs that their spending is out of control or harmful, are proposed to be lower for younger adults. The Gambling Commission will shortly be publishing updated guidance on remote customer interaction which includes specific provisions that operators should ‘have regard to a customer’s age when considering potential vulnerabilities’. These measures are intended to provide extra protections for a potentially vulnerable group, without unnecessarily restricting their ability (as adults) to participate.

Options:

The options considered below are intended to work as an additional targeted protection beyond the limits considered above. The appropriate limit for all adults is being considered alongside the case for extra protections for younger adults, and the stake limit for young adults will be the same as or lower than the limit for all adults, whatever level is chosen.

Option A - a maximum online slots stake limit of £2 per spin for 18 to 24 year olds

The best available evidence shows that 18 to 24 year olds typically stake lower amounts than other age groups, with an average stake 20% lower than the average for all adults according to Patterns of Play. A £2 limit for this cohort specifically would therefore be less disruptive than it might be as a general limit, but is still the most disruptive option being considered.

Option B - a maximum online slots stake limit of £4 per spin for 18 to 24 year olds

A young adult-specific £4 limit on online slot stakes would be less restrictive than the £2 limit on B2/B3 gaming machines. The potential argument for this is that even while the young adult cohort is potentially vulnerable, the extra protections around online play including the lower financial risk check thresholds, could still give greater protection than largely anonymous land-based play. The limit would still be lower than the £5 stake limit on land-based casino machines, which is available to all adults.

Option C - Applying the same maximum stake limit to all adults, but building on wider requirements for operators to consider age as a risk factor for gambling-related harm

Some respondents to the call for evidence argued that young adults should not be prevented by default from accessing the gambling products and staking options available to other adults. Instead, they argued that the default should be to treat all adults in the same way, and that any targeted protections for young adults instead come ‘behind the scenes’, through operators’ existing obligations to identify risk.

As outlined above, the Commission’s customer interaction guidance already suggests operators should have regard to a customer’s age when considering vulnerabilities.

Rather than introduce a specific lower stake limit in statute for this cohort, we could reiterate to industry that limiting customers to only lower stakes play on certain products is already part of the toolkit of responses at their disposal when responding to risk on a case-by-case basis. In line with the current outcome based regime, the Commission could continue to take enforcement action when an operator’s approach to identified vulnerabilities or risk was not proportionate.

Consultation question 5:

The government is seeking a balanced approach to the protection of young adults. We recognise the evidence of risks which can accompany potentially vulnerable young adults gambling on high risk online slots at high stakes, but also that as adults we must treat those aged 18 to 24 fairly and proportionately.

5a) What maximum stake, if any, do you support for young adults aged 18-24? (Mandatory response)

[£2 / £4 / consistent with the limit for all adults but with extra operator vigilance / I don’t know]

5b) Please explain your answer and reference any relevant supporting evidence if appropriate. (Optional response)

[Open text]

Chapter 6: Impact

To help inform our consideration of this issue, we have published a consultation stage impact assessment alongside this consultation. The IA contains a cost/benefit analysis and consideration of wider impacts of the options explored in this consultation to help inform responses, and explores how the chosen measure will be monitored and evaluated following implementation. A summary of the cost/benefit analysis is provided below.

Figure 5: summary of estimated GGY impact of options for general online slots stake limits

Option	GGY reduction in £m (central estimate)	GGY reduction as a % of online slots GGY in 2021/22	GGY reduction as a % of all remote GGY in 2021/22
Option 1 - A maximum online slots stake limit of £2 per spin	£310m	10.3%	4.8%
Option 2 - A maximum online slots stake limit of £5 per spin	£124m	4.1%	1.9%
Option 3 - A maximum online slots stake limit of £10 per spin	£39m	1.3%	0.6%
Option 4 - A maximum online slots stake limit of £15 per spin	£31m	1.0%	0.5%

Figure 6: summary of estimated GGY impact of options for slots specific protections for young adults

Option	GGY reduction in £m (central estimate)	GGY reduction as a % of online slots GGY in 2021/22	GGY reduction as a % of all remote GGY in 2021/22
Option A - a maximum online slots stake limit of £2 per spin for 18 to 24 year olds	£18m	0.6%	0.3%
Option B - a maximum online slots stake limit of £4 per spin for 18 to 24 year olds	£10m	0.4%	0.2%
Option C - Applying the same maximum stake limit to all adults in statute, but building on wider requirements for operators to consider age as a risk factor for gambling-related harm	TBC - but likely minimal in addition to impact of the general limit	TBC - but likely minimal in addition to impact of the general limit	TBC - but likely minimal in addition to impact of the general limit

Our economic assessment of the impact of potential changes is limited in some ways by the lack of available data from the industry, but the Gambling Commission has issued a formal data request to inform advice to government which will help improve our estimates. Further, there are difficulties in estimating the precise behavioural responses to new limits. Alongside the GGY reduction, there may be some other costs to operators, such as the implementation costs of game development teams needing to adjust the stake levels on live games. These are explored fully in the IA, and we will include any new information on impacts in a final stage impact assessment which will be published alongside the consultation response later this year.

Given the complexity of gambling-related harms and the role of many different factors in creating or exacerbating it, we are also unable to accurately estimate how limiting the maximum stake on online products will in isolation impact the population rates of gambling-related harm. However, as explored in the impact assessment, we have evidence that any of the options above will limit the potential for harmful losses from those gambling at elevated levels of risk or experiencing problem gambling compared to the status quo of theoretically unlimited stakes.

Consultation question 6:

The options considered throughout this consultation are likely to have significant impacts on both gambling customers (including those being harmed by gambling) and businesses. Our impact estimates for each option under consideration are considered in full in the consultation stage impact assessment.

6a) Are there any additional impact considerations, including on the assumptions in the accompanying impact assessment, or on the risk of unintended consequences? (Mandatory response) [Yes / No / I don’t know]

6b) Please explain your answer and provide relevant evidence. We would particularly welcome input on transition costs, and on the impacts for small and micro businesses. (Optional response) [Open text]

Consultation question 7:

The Department for Culture, Media and Sport will have due regard to the public sector equality duty, including considering the impact of these proposals on those who share protected characteristics, as provided by the Equality Act 2010.

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. (Optional response)

[Open text]

Consultation question 8:

8) Are there any other factors or points you wish to highlight that have not been considered above? (Optional response)

[Open text]

Consultation question 9:

9) Please upload any further supporting evidence that you wish to share. (Optional response)**

[Upload attachment(s)]

Chapter 7: Summary of questions

Pre consultation demographic questions

Are you responding on behalf of an organisation or as an individual? (Individual / Organisation / Other [please specify])

If individual

What is your age? (0 to 17 / 18 to 24 / 25 to 44 / 45 to 64 / 75 to 84 / 85+ / Prefer not to say)

What part of Great Britain do you live in? (England / Scotland / Wales / Prefer not to say / Outside of Great Britain [please specify])

Have you gambled in the past year? (Yes / No/ I don’t know / Prefer not to say)

Which of the following best describes your interest in gambling policy (select up to two options)? (Gambling industry professional, gambling researcher/academic, gambling treatment provider, personally harmed by gambling, affected negatively by another person’s gambling, recreational gambler, government/regulatory professional, other, prefer not to say)

Is any of the information you have provided confidential, commercially sensitive or otherwise unsuitable for publication (including in anonymised)? If so, please indicate what. (Free text box)

If organisation

What is the name of your organisation? (Free text box)

Is the organisation headquartered in Great Britain? (Yes / No / I don’t know)

Which of the following best represents your organisation’s sector? (remote gambling industry, land-based gambling industry, both remote and land-based gambling industry, gambling-related sector (e.g. advertising, sport, or broadcasting), government/regulator, lived experience peer support charity, academic/research, treatment provision, trade association, local authority/ licensing board, other, I don’t know)

How many employees does the organisation you are responding on behalf of have globally? (1-9 / 10-19 / 20-49 / 50- 99 / 100 - 250 / 250 - 499 employees / 500+ employees / I don’t know)

Are you happy for government to attribute responses to your organisation in a published response to this consultation? (Yes / No)

Is any of the information you have provided confidential, commercially sensitive or otherwise unsuitable for publication (including in anonymised)? If so, please indicate what. (Free text box)

Consultation questions

Q1) For the purposes of introducing a maximum stake limit, the government intends to align with the definition of online slots used by the Gambling Commission. We therefore intend for the limit to apply to:

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).

Q1a) Does this description of online slots adequately describe the products intended for inclusion in the maximum stake limit’s scope? (Mandatory response)

[Yes / No / I don’t know]

Q1b) Please explain your answer. (Optional response)

[Open text box]

Q2) The government is developing a description of a maximum stake. This description will be adapted in legislation to introduce a maximum stake limit. The proposed description of a maximum stake is:

‘Maximum stake per spin’ means the maximum amount a player can pay or risk per spin or game cycle.

Q2a) Is this description of stake suitable for the purpose of the introduction of a maximum stake limit for online slots games? (Mandatory response)

[Yes/No/I don’t know]

Q2b) Please explain your answer. (Optional response)

[Open text box]

Q3) For the purposes of introducing a maximum stake limit per spin or game cycle, the government intends to align with the definition of game cycle used by the Gambling Commission’s Remote Technical Standards. Game cycle is defined as:

A game cycle starts when a player depresses the ‘start button’ or takes equivalent action to initiate the game and ends when all money or money’s worth staked or won during the game has been either lost or delivered to, or made available for collection by the player and the start button or equivalent becomes available to initiate the next game.

Q3a) Is this description of game cycle suitable for the purpose of the introduction of a maximum stake limit for online slots games? (Mandatory response)

[Yes/No/I don’t know]

Q3b) Please explain your answer. (Optional response)

[Open text box]

Q4) The government is aiming to introduce a maximum stake limit that strikes an appropriate balance between preventing harm and preserving consumer freedoms.

Q4a) What maximum stake limit for online slot games would you support, if any? (Mandatory response)

[£2 / £5 / £10 / £15 / None of the above / I don’t know]

Q4b) Please explain your answer, providing evidence where possible. (Optional response)

[Open text box]

Q5) The government is seeking a balanced approach to the protection of young adults. We recognise the evidence of risks which can accompany potentially vulnerable young adults gambling on high risk online slots at high stakes, but also that as adults we must treat those aged 18-24 fairly and proportionately.

Q5a) What maximum stake, if any, do you support for young adults aged 18-24? (Mandatory response)

[£2 / £4 / consistent with the limit for all adults but with extra operator vigilance / None of the above / I don’t know]

Q5b) Please explain your answer and reference any relevant supporting evidence if appropriate. (Optional response)

[Open text box]

Q6) The options considered throughout this consultation are likely to have significant impacts on both gambling customers (including those being harmed by gambling) and businesses. Our impact estimates for each option under consideration are considered in full in the consultation stage impact assessment.

Q6a) Are there any additional impact considerations, including on the assumptions in the accompanying impact assessment or on the risk of unintended consequences? (Mandatory response)

[Yes / No / I don’t know]

Q6b) Please explain your answer and provide relevant evidence. We would particularly welcome input on transition costs and on the impacts for small and micro businesses. (Optional response)

[Open text box]

Q7) The Department for Culture, Media and Sport will have due regard to the public sector equality duty, including considering the impact of these proposals on those who share protected characteristics, as provided by the Equality Act 2010. These are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.

Q7) 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. (Optional response)

[Open text box]

Q8) Are there any other factors or points you wish to highlight that have not been considered above? (free text box/ file upload) (Optional response)

[Open text box]

Q9) Please upload any further supporting evidence that you wish to share. (Optional response)

Chapter 8: How to respond

Please respond to this consultation by completing the online response form below:

If you cannot access the link, please send responses to gamblingactreview@dcms.gov.uk in a document format like PDF or Microsoft Word.

By submitting your responses via email you are agreeing to the terms outlined in the privacy notice.

We welcome evidence from all parties with an interest in the way that gambling is regulated in Great Britain. We also welcome international evidence. The consultation will close at 11:55 pm on 10 October 2023.

Chapter 9: Privacy notice

Who is collecting my data?

The Department for Culture, Media & Sport (DCMS). DCMS is consulting on policy options for measures relating to the land-based gambling sector. For the purposes of personal data collected in the course of this consultation, DCMS is the data controller.

Purposes of this privacy notice

This notice is provided to meet the obligations as set out in Articles 13 and 14 of the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018 (“the DPA”). This notice sets out how DCMS will use your personal data as part of our legal obligations with regard to data protection.

What personal data do we collect?

The personal information we collect and process is the data provided to us directly by you in the responses to this consultation. As an individual, this includes: your gender, age bracket and region of residence. As an organisation, this includes: your organisation name and size. All questions requesting an individuals personal information offer a ‘prefer not to say’ option.

How will we use your data?

We will use your data to enable us to carry out our functions as a government department. Your data will be used to inform the development of policy measures to introduce maximum stake limits on online slots.

What is the legal basis for processing my data?

To process this personal data, our legal reason for collecting or processing this data is:

• Article 6(1)(e) of the UK GDPR: to the extent it is necessary to perform a public task (to carry out a public function or exercise powers set out in law, or to perform a specific task in the public interest that is set out in law). In this case, the processing of your personal data is necessary for the performance of a task in the public interest, as the information gathered helps inform future policies; and
• Section 8(d) of the DPA: to the extent it is necessary for the effective performance of a task carried out in the public interest.

What will happen if I do not provide this data?

You have the option to select ‘Prefer not to say’ in response to any of the questions that ask for your personal data.

Who will your data be shared with?

DCMS has commissioned a third party, Qualtrics, to collect your personal data on its behalf. This means we have asked Qualtrics to collect your information via an online survey platform, which we will review as part of the consultation process.

Information provided in response to this consultation (not including personal information) may be shared with other government departments and arm’s length bodies, such as the Department for Health and Social Care and the Gambling Commission. The information provided may be published at an aggregated or anonymised level in the government’s consultation response, or disclosed in accordance with the access to information regimes (primarily under the Freedom of Information Act 2000 and the Environmental Information Regulations 2004) subject to any applicable exemptions.

Please indicate if any information you provide is commercially or otherwise sensitive.

How long will my data be held for?

Your personal data will be kept for one year in line with DCMS retention policy.

Will my data be used for automated decision making or profiling?

We will not use your data for any automated decision making.

Will my data be transferred outside the UK and if it is how will it be protected?

Your data will not be transferred outside the UK.

What are my data protection rights?

You have rights over your personal data under the UK GDPR and the Data Protection Act 2018. The Information Commissioner’s Office is the supervisory authority for data protection legislation, and maintains a full explanation of these rights on their website DCMS will ensure that we uphold your rights when processing your personal data.

How do I complain?

The contact details for the data controller’s Data Protection Officer (DPO) are:

Data Protection Officer
The Department for Culture, Media & Sport
100 Parliament Street
London
SW1A 2BQ

Email: dpo@dcms.gov.uk

If you’re unhappy with the way we have handled your personal data and want to make a complaint, please write to the department’s Data Protection Officer using the details above.

How to contact the Information Commissioner’s Office:

If you believe that your personal data has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator. You may also contact them to seek independent advice about data protection, privacy and data sharing.

Information Commissioner's Office
Wycliffe House Water Lane
Wilmslow
Cheshire
SK9 5AF

Website: www.ico.org.uk

Telephone: 0303 123 1113 Email: casework@ico.org.uk

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.

Changes to our privacy notice

We may make changes to this privacy policy. In that case, the ‘last updated’ date at the bottom of this page will also change. Any changes to this privacy policy will apply to you and your data immediately. If these changes affect how your personal data is processed, DCMS will take reasonable steps to let you know. Last updated: 14 July