UKGC commences consultation on online slots game design & reverse withdrawals

As anticipated (albeit slightly later than it had forecast last month), the Gambling Commission has today (9 July 2020) commenced a consultation on online slots game design and reverse withdrawals. The consultation will close on 3 September 2020.

In its online consultation document (that you can download below), the Commission summarises its proposed “key changes to protect consumers” as follows:

  • 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 and
  • removing the ability of operators to reverse customer withdrawal requests.

adding that “this proposed suite of enhanced controls will be incorporated within the remote gambling and software technical standards (RTS), which sets out the specific technical standards that licensed remote gambling operators and gambling software operators need to meet”.

This consultation needs to be considered very carefully by remote gambling software providers and remote gambling operators alike, because the Commission makes the point that “for a number of the proposals contained within this consultation the manner in which an outcome is achieved will reflect each operator’s technical set up. With this in mind, we invite respondents to consider each proposal carefully and provide insight as to how the intended outcomes are best achieved with the resources and technology available”.

The consultation document addresses the following topics:

  1. Why are we consulting? In terms of background information, the Commission specifically includes reference to the following:
    • its CEO’s ‘Breakfast Briefing’ speech in October 2019 when he called for an effective Industry Code for Game Design that will set out:
      • the techniques that the industry plans to use when designing apps, online games and gaming machine products,
      • the risk associated with each product and how they can be mitigated and
      • a clear explanation of what is not acceptable;
    • the draft Code produced by a BGC working group led by Scientific Games and Playtech;
    • the Commission’s subsequent conclusion in June 2020 that the measures proposed by the industry were not by themselves sufficient, adding that:
      • it considered them to have “fallen significantly short” in a number of areas detailed within its Progress Update document, and
      • it would “use the commitments made as the basis for an LCCP consultation before the end of June 2020” (including in relation to mandatory loss limits and messaging around wins/losses and stake/time played increases).
  2. Defining online slots within the RTS. In this respect, it proposes the following definition: “Casino games of a reel-based type (includes games that have non-traditional reels)”.
  3. Prohibiting multiple slot games. In this respect, it proposes the following new RTS requirement 14C:
    • RTS requirement 14C: The gambling system must prevent multiple slots games from being played by a single account at the same time.
    • RTS implementation guidance 14C:
      • The system should either prevent a second slot game from being opened or close the first game when a player chooses to begin play on a different game.
      • Customers should be informed that they are only permitted to play one slot game at a time.
  4. Introducing speed of play limits. In this respect, it proposes the following new RTS requirement 14D:
    • RTS requirement 14D: It must be a minimum of 2.5 seconds from the time a game is started until a player can commence the next game cycle. It must always be necessary to release and then depress the ‘start button’ or take equivalent action to commence a game cycle.
    • RTS implementation guidance 14D:
      • A game cycle starts when a player presses the ‘start button’ or takes equivalent action to initiate the game and ends when the button is once again available to use.
      • A player should commit to each game cycle individually, continued contact with a button, key or screen should not initiate a new game cycle.
  5. Prohibiting player-led ‘spin stop’ features. In this respect, it proposes the following new RTS requirement 14E:
    • RTS requirement 14E: The gambling system must not permit a customer to reduce the time until the result is presented.
    • RTS implementation guidance 14E:
      • Features such as turbo, quick spin, slam stop are not permitted. This is not intended to be an exhaustive list but to illustrate the types of features the requirement is referring to.
      • This applies to all remote slots, regardless of game cycle speed.
  6. Prohibiting auto-play functionality for online slots. In this respect, it proposes the following new RTS requirement 8C:
    • RTS requirement 8C: The gambling system must require a customer to commit to each game cycle individually. Providing auto- play for slots is not permitted.
  7. Prohibiting effects that give the illusion of “false wins”. In this respect, it proposes the following new RTS requirement 14F:
    • Requirement 14F: The gambling system must not celebrate a return which is less than or equal to the total amount staked.
    • RTS Implementation Guidance 14F:
      • By ‘celebrate’ we mean the use of auditory or visual effects that are associated with a win are not permitted for returns which are less than or equal to last total amount staked.
      • Where the return is lower than or equal to the stake, the gambling system should not refer to the result as a win.
  8. Display of net position and display of elapsed time. In this respect, it proposes:
    • in relation to display of net position, the following new RTS requirement 2E:
      • RTS requirement 2E: All gaming sessions must clearly display the net position, in the currency of their account or product (e.g. pounds sterling, dollar, Euro) since the session started.
      • RTS Implementation guidance 2E: Net position is defined as the total of all winnings minus the sum of all losses since the start of the session
    • in relation to display of elapsed time, the following new RTS requirement 13C:
      • RTS Requirement 13C: All gaming sessions must clearly display the elapsed time since the session started.
      • RTS Implementation guidance 13C:
        • Time displayed should begin either when the game is opened or once play commences
        • Time should run for the duration of the session regardless of whether the customer minimises the session
        • Elapsed time should be displayed in seconds, minutes and hours
  9. Prohibiting reverse withdrawals (in order to update the Commission’s additional customer interaction guidance published on 12 May 2020, in which licensees were prohibited from offering withdrawal options for customers until further notice). In this respect it proposes the following new RTS requirement 14B:
    • RTS requirement 14B: Consumers must not be given the option to cancel their withdrawal request.
    • RTS implementation guidance 14B: Once a customer has made a request to withdraw funds, they should not be given the option to deposit using these funds. Operators should make the process to withdraw funds as frictionless as possible.
  10. Testing. In this respect, the Commission:
    • is mindful that “some of the changes outlined in this consultation (for example the introduction of the minimum spin speed at 2.5 seconds) may require some existing games to be re-tested”;
    • is mindful “of the fact that the draft code of conduct received from industry committed BGC members to adhere to several of the requirements contained in this document [including a 2.5 second spin speed, prohibition of split-screen slots games, removal of ‘turbo’ buttons and ‘slam-stops’] made with a commitment of being completed by the end of September 2020, and as such we do not expect that BGC members will have to additionally re-test games which have already been re-tested as parts of the code of conduct commitments”;
    • 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 commencement date for these requirements will need to be tested”.
      • “It is our view that games which are not compliant by the commencement date will need to be temporarily 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”; and
    • intends to “update the Testing Strategy to incorporate any new standards and changes made to the numbering of existing requirements as a result of the changes outlined in this consultation. This could include for example, that a testing report should include whether the licensee declared the game as a slots title”.

Announcing commencement of the consultation, the Commission has said:

We are consulting on changes to the design of online slots – specifically to make them safer for consumers.

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

We also know that speed of play, frequency of betting opportunities, as well as other factors on offer can increase addiction and risk of harm. The proposed changes outlined within this document will help to mitigate these risks for slots players.

Our interest in online slots is because it is the largest online gambling product by Gross Gambling Yield (GGY) – played by relatively few but with a high average spend. Structurally it has a number of features which can combine to significantly increase intensity of play.

This means it poses a relatively high risk, reflected in its associated problem and moderate-risk gambling rates.

We will evaluate the impact of the controls and friction proposed in this consultation to reduce the intensity of the play experience for consumers and will take further action if necessary.

Proposals around the design of slots games are just the first step in keeping players safe. Slots 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.

Regulatory intervention needs to keep pace with this and the proposals in this consultation form part of a comprehensive package of work we are taking forward to make online gambling safer.

To take part in the consultation, you will need to complete this Online Survey.