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- Stake limits for online slots are only one part of the wider package of regulatory and legislative changes which is intended to create an appropriate balance.
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- 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.
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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). 1% of respondents were in support of a £15 limit (Option 4) and 4% of respondents did not support a stake limit at any level. ‘‘Maximum stake per spin’ means the maximum amount a player can pay or risk per spin or game cycle’ Slots are ‘casino games of a reel-based type (includes games that have non-traditional reels)’
The stake limit proposals outlined in this consultation response are in line with those intentions. Stake limits for online slots are only one part of the wider package of regulatory and legislative changes which is intended to create an appropriate balance. Similarly, some respondents highlighted concerns around the use of gambling-like mechanisms being applied to non-gambling contexts such as video games and cyrptocurrencies. 23% of respondents highlighted that young people will be discriminated against on the basis of age if a separate lower stake limit is implemented. Some industry respondents highlighted that a single stake limit would be easier to implement than 2 separate limits. Many of the comments and supplementary evidence focused on the positive impact of a stake limit on those either directly or indirectly affected by gambling-related harm.
Problem gamblers who have voluntarily excluded themselves from physical casinos are likely to be able to gain access to gambling via the internet if they so wish. On the internet, bets are often smaller and may thus seem far more affordable than gambling at a casino, but the amounts being bet can quickly accumulate. Many online gambling sites also allow people to bet just a few pennies to start with, which can lure them in before they start spending bigger amounts. Many gambling websites offer practice or demo sessions where a person can take part in the gambling activity for free, and practise without staking any money. Your device becomes the casino, and it’s always in your pocket and ready to be played. Some surveys have found that compared to those who visit physical casinos, online problem gamblers are significantly less likely to have sought formal help.
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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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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.
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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.
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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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