New rules for online slots & permanent ban on reverse withdrawals w.e.f. 31 October 2021

Following publication of the BGC’s Game Design Code of Conduct and last year’s consultation on the same subject-matter, the Gambling Commission has today (2 February 2021) published its ‘Consultation Response for online games design and reverse withdrawals and proposed changes to the design of online slots’ (that you can download below).

The following new rules will need to be fully implemented by UK licensed online operators by no later than 31 October 2021:

In its website announcement of the new rules (that you can also download below), the Commission says that it has focused on online slots “because of its features which increase the intensity of play and the corresponding risks to players. Slot games have by far the highest average losses per player of online gambling products”. In this respect, it cites its Covid-19 data that shows the average spend per slots player is £67 per month, compared with £36 for casino products and £45 for real event betting.

It goes on to state:

Since the publication of the Commission’s consultation in July 2020, further research has shown that using an autoplay feature has been linked to some players losing track of play, making it difficult for some to stop playing and in some cases gambling on other activities simultaneously.

Evidence shows that reverse withdrawal functions present a risk to players because of the temptation to continue gambling. In addition, the slot features being removed or more closely controlled have been associated with increased intensity of play, loss of player control, or binge play.

The Executive Summary to the Commission’s Consultation Response document reads as follows:

Executive Summary

During the summer we consulted on proposed changes to the design of online slots – specifically to make them safer for consumers. Alongside this consultation, we proposed restrictions on reverse withdrawals which would apply to all remote operators.

We know that the success of many technology companies, digital content creators and game designers depends on their ability to establish and maintain the engagement of their consumers on their website, mobile apps and – in premises – gaming machines.

We also know that speed of play, frequency of gambling opportunities, and other factors can increase the risk of addiction and harm. The changes outlined within this document will help to mitigate these risks for online slots players.

Online slots are one of the largest online gambling products by Gross Gambling Yield (GGY) – played by relatively few but with a high average spend. Structurally, these products have a number of features which can combine to significantly increase intensity of play and pose a relatively high risk. This is reflected in the associated problem and moderate-risk gambling rates and further details can be found in the Gambling product section of our National Risk Assessment.

At the time of the consultation, we were clear that proposals on the design of slots games and reverse withdrawals are just one step in reducing the risk of harm. It is an area which has seen technological innovation in terms of product design, and we expect operators to continually show an equal, and indeed greater, commitment to innovate in terms of consumer protection. The proposals in this consultation form part of a comprehensive package of work we are taking forward to make online gambling safer. The proposals related to:

  • a suite of new controls aimed at reducing the potential for consumers to be harmed by their gambling on the most intensive products: online slots
  • removing the ability of operators to reverse customer withdrawal requests.

It is our intention to proceed with most of the proposed changes as set out in the consultation document. Reflecting the responses received we have sought additional evidence before reaching a decision on some proposals and amended others.

We have set out our position on each proposal in the relevant section of this document and in addition a summary of the new remote gambling and software technical standards (RTS) requirements can be seen in Annex 1.

The new requirements will form part of a revised RTS which will take effect on 31 October 2021.

In relation to the above:

  • you can read here our commentary on the Gambling Commission’s first ever ‘National Risk Assessment’,
  • you can download below the above-mentioned ‘Annex 1’ that summarises the consequential changes to the Commission’s Remote gambling and software technical standards and testing strategy (a new version of which the Commission says it will be publishing shortly), and
  • the Commission states that “as a principle, operators must satisfy themselves that they are offering compliant games. Where they are not sure, any existing game will require independent retesting. All new games published after the implementation date will need to be tested. Games which are not compliant by the commencement date will need to be removed until such time as they can be verified. Games that require retesting could be prioritised based on popularity to spread the demand for testing”.

The Commission goes on to say within its Consultation Response document that it has developed a theory of change model and once the new requirements are in place, it will measure their impact through consumer research, operational data on slots and compliance assessments, adding that “the proposed RTS updates and guidance gives us a clearer basis to raise standards and we will monitor the effectiveness of the guidance through our ongoing compliance and enforcement work. If this approach fails to deliver the outcomes required, we will revisit the need to impose more prescriptive requirements for specific licensees or general requirements”.

Neil McArthur, Gambling Commission Chief Executive, is quoted as saying:

To make online games safer we are introducing a ban on features that speed up play, or give the illusion of control over the outcome. We are also introducing a ban on autoplay, losses disguised as wins, and slot spin speeds faster than 2.5 seconds. The evidence shows that these features increase the risk of harm to customers. This is another important step in making gambling safer and where the evidence shows that there are other opportunities to do that we are determined to take them.

Nigel Huddleston, Minister for Sports, Tourism and Heritage, has added:

Today’s steps will help curb the intensity of online gambling, introducing greater protections that will reduce the risk of gambling related harm. I welcome the Gambling Commission’s tough measures as we continue our comprehensive review of gambling laws to make sure they’re fit for the digital age.

Although the new rules were expected, they do serve to further erode the list of agenda items for the UK Government’s Review of the Gambling Act 2005, one question within the current Call for Evidence in relation to that Review asking “What evidence is there for or against the imposition of greater controls on online product design?”.


1. The Betting and Gaming Council has published the following response to the Gambling Commission’s announcement on games design:

Responding to the Gambling Commission’s announcement on games design, Michael Dugher, chief executive of the Betting and Gaming Council, said:

“As the standards body representing the regulated industry, the BGC is determined to drive change and promote safer gambling. That’s why we welcome the Gambling Commission’s announcement which builds on the BGC’s new code of conduct from last September for the design of online games in a bid to further improve player safety.

BGC members have already introduced measures including the slowing down of spin speeds and banning several gaming features which have caused concern.

Among the major commitments we have already introduced 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. We are also progressing a game labelling project which will improve labelling of games in order to educate players on key game characteristics.

None of these new changes apply to the unsafe, unregulated black market online, but the BGC will work with the regulator, academics, consumers and individuals with lived experience of betting-related harm to identify further best practice in game design going forward, to ensure we keep up to date with changes in technology.”

2. Updated versions of the Commission’s Remote gambling and software technical standards and testing strategy were published on 2 and 9 February 2021 respectively. They can both be downloaded below.