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- We welcome stakeholders’ general support for the descriptions proposed in the consultation.
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This figure is lower than that shown in the table above because some respondents selected £2 (Option 1) but explained in the free text response that they were in favour of a limit below £2. Having worked with the Gambling Commission, we are confident that these games can adequately be captured by the Gambling Commission’s existing definition, although this is ultimately subject to due legal process on interpretation. We welcome stakeholders’ general support for the descriptions proposed in the consultation. Further, since March 2020, the Gambling Commission has been collecting and publishing detailed information from online gambling operators.
These respondents raised concerns that lower limits would affect customer enjoyment of online slots and that these customers may migrate to the illegal online market where there are no protections for consumers. Both petition and survey respondents wanted tougher restrictions, with the petition specifically calling for a limit below £2, and changes to slow down games (not in scope of this consultation). Many respondents also felt that £2 was most appropriate as it aligned with the stake limit for B2 gaming machines in bookmakers. When taking into account the content of the free text responses from each of the respondents, 26% of consultation respondents were in favour of a stake limit below £2 and 38% of respondents favoured a limit of £2. By volume, most respondents would support a stake limit at the bottom of, or below, our consultation range for all adults.
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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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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 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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Part 2: Policy options for a maximum stake limit for online slots games to apply to all adults
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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.
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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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The consultation document set out our intention to give a minimum of 6 weeks transition period for operators to become compliant with the new rules. The researchers conclude that young people and young adults experiencing problem gambling should be considered at risk for suicidality. A cross-sectional research study from 2021 found an association between suicide attempts in 16 to 24 year olds and problem gambling, even after adjustment for other factors.
