Give your two pounds’ worth on the slots consultation

The consultation season in Great Britain truly began on 26 July 2023 when the Department for Culture, Media and Sport (DCMS) published the first two of its promised consultations from the white paper into the Gambling Act 2005 review. In this article, we discuss the DCMS’ proposals and reasoning for a maximum stake limit for online slots games in the UK and strongly encourage the industry to respond.

The DCMS has proposed four options for the maximum stake limit which should apply for online slots. It is seeking opinions on which option “strikes an appropriate balance between preventing harm and preserving consumer freedoms”: either a £2, £5, £10 or £15 spin maximum online slots stake limit.

The DCMS has provided evidence-based reasoning for each option. Notably, it recognises that 97% of all individual online slot stakes are below £2. However, up to 35% of players stake over £2 on a single spin at least once a year, contributing to an estimated 18% of annual slots gross gambling yield (GGY). A £5 maximum stake per spin, as the DCMS notes, is equal to the highest limit currently permitted on any land-based gaming machine.

At the other end of the spectrum, the DCMS is considering whether higher stake limits of £10 or £15 are appropriate online given there are additional protections for players, who must create an account to play and can therefore be more adequately monitored for signs of gambling-related harm. Lastly, the DCMS notes that a £15 stake limit would impact only a small minority of “habitually or occasionally high-staking players”, because stakes over £15 represent 0.05% of all stakes on online slots and 2% of GGY.

The white paper also committed to consulting on additional protections for 18-24 year olds on the basis this age group may be a “particularly vulnerable cohort”. Accordingly, the consultation seeks views on the following options:

• £2 per spin maximum online slots stake limit for 18-24 year olds;

• £4 per spin maximum online slots stake limit for 18-24 year olds;

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

In respect of the first two options, the DCMS does not cite data that specifically indicates either maximum stake limit would be best suited to this age group. The reasoning simply appears to be that as a potentially vulnerable cohort, there should be extra protections in place, ie lower maximum stake limits than those for the general population.

The last option would, of course, be the least intrusive one for operators and their customers, and any action required would likely align with the Gambling Commission’s consultation on new obligations for operators to conduct financial vulnerability checks and financial risk assessments.

Have your say

The slots consultation is open for responses for eight weeks until 20 September. Responses can be submitted through the DCMS’ online survey, or as a Word or PDF document to this email address: gamblingactreview@dcms.gov.uk.

We strongly encourage all stakeholders to consider the impact the proposals would have on their businesses and respond with evidence-based submissions. Now is the opportunity to influence positive change for consumer protection while tempering a potentially damaging blow to the commercial viability of the online slots industry in Great Britain.

Chris Biggs is an Australian qualified solicitor and an associate at Harris Hagan, a UK law firm specialising in online and land-based gambling law. He works with a range of gambling businesses advising on licence applications and changes of corporate control, licence reviews and regulatory investigations, and carrying out transactional due diligence.