BGC Game Design Code of Conduct introduces safer gambling changes to online game design

The Betting & Gaming Council has today (25 September 2020) unveiled changes to online game design, involving slower spin speeds, more checks on players and improved access to safer gambling information.

This follows (but takes account of certain matters raised in) the Gambling Commission’s consultation on online slots game design and reverse withdrawals that closed on 3 September 2020.

The new BGC Game Design Code of Conduct (that you can download below), sets out key principles and commitments that the BGC says can be adopted by the industry in the following areas:

  1. Game Characteristics: “Working with academics, regulators, consumers, individuals with lived experience of gambling related harm and other technical experts to identify and agree on features that are correlated to greater player risk”.
  2. Informed Player Choice: “Empowering customers to play more safely through the provision of clearer information on product and game rules, including mathematical properties such as risk, the chances of winning and optimal strategies”.
  3. Enhancing Control Innovation: “Improvements in safer gambling tools that help players both monitor and control their gambling, including spend, loss, win and time-based measures”.
  4. Governance and Continuous Improvements: “Process for reviewing and updating any Code of Conduct, in addition to transparency, disclosure and independent evaluation”.

Commenting on its new Code, the BGC states as follows on its website:

Standards body the Betting and Gaming Council has unveiled a new code of conduct for the design of online games in a bid to improve player safety and tackle problem gambling.

Measures include the slowing down of spin speeds, banning several gaming features which have caused concern and improved access to safer gambling information.

The new Game Design Code of Conduct follows on from the Safer Gambling Commitments published by the BGC in 2019 and is further evidence of the industry body’s commitment to driving up standards.

The code’s aim is to address concerns around player safety by ensuring that safer gambling principles are fully incorporated into the design of online games before they enter the market.

Among the major commitments included in the new code are minimum game cycle speeds of 2.5 seconds, the ending of turbo play, which allows players to speed up games, and the scrapping of multi-slot play, where a player can place multiple stakes on different games at the same time.

All of these measures will be in place by the end of this month.

The code also introduces further mandatory checks on players’ activity in order to introduce breaks in play.

In addition, the industry will, via its game design research lab, explore ways to improve the labelling of games in order to increase players’ understanding of key terms.

The BGC has also committed to working with academics, regulators, consumers and individuals with lived experience of betting-related harm to identify best practice in game design going forward, to ensure the code of conduct keeps up to date with changes in technology.

Michael Dugher, chief executive of the Betting and Gaming Council, said:

“The BGC was set up last year with the aim of leading a race to the top in terms of standards within the regulated betting industry. The new Game Design Code of Conduct is yet another example of our determination to address concerns head on and meet our safer gambling commitments. I’m sure that our members will embrace this approach and commit to its objective of improving player safety. And as we prepare for the forthcoming Gambling Review, it is further evidence of our industry’s commitment to improving standards – unlike the completely unregulated black market.”

The Code Standards apply to online slots products and are split into two phases of delivery, as the following extract from the Code makes clear:


The following standards represent measures BGC members have committed to having in place by 30th September 2020. These commitments have been reflected in the recent Gambling Commission consultation on online slots which seeks to ensure these measures are adopted by the whole industry. BGC members will be amongst the first to commit to these standards as part of BGC’s commitment to driving up standards across the industry.

Minimum game cycle speed of 2.5 seconds

A game cycle starts when a player has paid for an initial wager and depresses the ‘start’ or ‘spin’ 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. Where auto play or auto start is permitted then a game cycle is measured from the point at which the game is initiated by the system (equivalent to the player depressing the start button) to the point at which it is able to automatically start the next game.

Removal of turbo play

Turbo play or equivalent features will be not be allowed. Such features enable the player to speed-up the base game cycle speed of the game.

Removal of base game slam stops

Slam stops or equivalent features will not be allowed within the base game. This is the ability for the customer to interact with the base game to end it before it has naturally concluded e.g., by hitting or pressing a button whether online or on a physical machine. This includes promotional free wagers paid for by the operator.

Removal of multi-slot play within a single gaming client

Functionality that allow players to place multiple, separate stakes on multiple slots games within a single gaming client will not be allowed. 4


In addition to our Phase 1 standards, BGC members have also committed to implementing a range of additional measures over the coming months as part of our Phase 2 commitments for online slots. These measures will enhance the transparency of games to players, both in the display of wins and clarity of game features, as well as adding friction and reflection to gaming sessions.

Members have been already been working to implement our Phase 2 commitments and have identified a number of measures which can be in place for new games by 31st January 2021. These include measures which will enhance both transparency and add friction for players.

Wins below the stake size

Total wins below the stake will be informative and will be differentiated from wins that are equal to or greater than the stake. Specifically;

  • The win amount will be displayed 
  • The win line is displayed long enough for player to understand the impact of the bet (in line with existing RTS 7E)
  • A brief sound can be used to make the player aware of the result (the return of funds to wallet)

In contrast, total wins equal to or greater than the stake may be celebratory and allow the following elements

  • The win amount can be displayed in a differentiating manner e.g., the win display could be in a text size that is greater and could utilise dynamic win animations, for example coin showers
  • The win line can be displayed with additional animation permitted
  • Celebratory sound effects can be used.

Bonus game notifications

Bonus games outside the base game will not be automatically triggered without a customer intervention, e.g., clicking a button to acknowledge that a bonus game has been won and can now be entered. In addition, after the end of a bonus game, the player will receive a notification informing them the bonus game has finished before re-entering the base game. If Auto-play is used during the bonus game, it will automatically stop before re-entering the base game. In the exceptional case that a bonus game is not triggered before the platform would normally time out, the operator has the right to clear down the game with any winnings being added to the player’s balance. 

The Code states that BGC members have also committed to implement in future the following additional measures:

  • Access to safer gambling information
  • Mandatory player interaction

In addition, BGC members have committed to exploring the following areas:

  • Game labelling
  • Increased staking
  • Auto-play
  • Display of net position and elapsed time

Strictly speaking, the BGC Game Design Code of Conduct is binding only on BGC members, but it can be anticipated that all UK licensed gambling software suppliers will be ‘encouraged’ to voluntarily implement its terms in advance of the RTS changes that will (in our view) flow in due course from the Gambling Commission’s above-mentioned consultation process. We say this not least because the BGC states as follows in the new Code:

BGC Membership – Adoption of the Code

The Betting and Gaming Council is committed to setting the highest industry standards and welcomes that our members are leading in doing so through their commitment to this Code.

The above Phase 2 standards will be implemented in line with the timeline outlined. Following a period of evaluation, the BGC may adjust these measures or recommend to the Gambling Commission that these standards are adopted as part of the RTS.

In the interim, compliance with the Code will be undertaken by members, including where operators use non-BGC game suppliers.