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The stake limit proposals outlined in this consultation response are in line with those intentions. Stake limits for online slots are only one part of the wider package of regulatory and legislative changes which is intended to create an appropriate balance. Similarly, some respondents highlighted concerns around the use of gambling-like mechanisms being applied to non-gambling contexts such as video games and cyrptocurrencies. 23% of respondents highlighted that young people will be discriminated against on the basis of age if a separate lower stake limit is implemented. Some industry respondents highlighted that a single stake limit would be easier to implement than 2 separate limits. Many of the comments and supplementary evidence focused on the positive impact of a stake limit on those either directly or indirectly affected by gambling-related harm.

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Such account-based protections will be further strengthened by proposals for new obligations on operators to conduct checks to understand if a customer’s gambling is likely to be unaffordable and harmful, in the form of frictionless financial risk checks. Around 20% of customers currently choose to stake over £5 on a spin at least once a year (so will be impacted by this measure), but only 0.6% of all spins are over £5. In addition to the formal consultation responses, we also received survey results from 3,898 members of the campaigning organisation 38 Degrees and a petition set up by GWL signed by 12,775 people.

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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.

The imposed limit should serve as a maximum stake which customers can choose to stake up to, rather than as a new default which operators drive customers towards, or which is otherwise seen as objectively ‘safe’. We believe these limits will achieve the government’s stated objectives of reducing the risk of gambling-related harm, with a lower risk of unintended consequences and less disruption to the majority of gamblers who do not suffer harm. This extensive selection ensures an engaging and high-quality gaming experience for your audience. Our support team is ready to address any technical issues promptly, including incident management support, system error resolution, and troubleshooting gameplay problems.

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Many of those who felt the description was too vague expressed concerns that gambling operators could be incentivised to develop products which are functionally similar to online slots but might be argued to be technically exempt to circumvent stake limits. Ahead of the consultation, we also requested data from Flutter, who introduced a maximum stake limit for slots games of £10 per spin across all of its brands in 2021. There were some clear themes amongst the responses, notably that online slots are a high-risk gambling product and that statutory stake limits are necessary to reduce the risk of gambling-related harm. Kong Casino is the best online casino for UK players. We have over 900 of the best online casino games, with more being continuously added.

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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.

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This data covered over 70 billion spins placed during the financial year to March 2023, increasing our understanding of current staking patterns for online slots. This includes academic research, parliamentary reports, and findings from the stake limit cut on B2 machines (fixed odds betting terminals) in 2019. This measure is designed to work together with the wider package of policies in the white paper, including financial risk checks, data sharing on high-risk customers, and making online games safer by design. We will then allow a further 6 weeks for the development of any necessary technical solutions before we expect the lower stake limit of £2 for young adults aged 18 to 24 to be in place. Following the passing of the secondary legislation, we expect there to be a minimum  of 6 weeks’ transition period for operators to introduce a £5 stake limit for all customers. Our reporting and analytics tool, included in our BackOffice, offers comprehensive casino reports and detailed gaming reports.

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Some respondents considered the description to be too vague and therefore open to loopholes, while others felt that it was too restrictive. Alongside updated data from the Gambling Commission on the size of remote gambling licence holders split by size of workforce and number of licences held. For young adults aged 18 to 24, just 2.1% staked over £2 for more than half of their spins and 0.4% staked over £5 for more than half of their spins. Only 3.9% of those aged 25 and over staked over £2 for more than half of their spins, and just 0.7% staked over £5 for more than half of their spins. However, 18 to 24 year olds placed a slightly higher proportion of stakes between £2 and £10, compared to older adults.

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After considering the consultation responses, we have decided to introduce a stake limit of £2 per spin for young adults aged 18 to 24. Several industry respondents suggested that implementation for a separate stake limit would take over 9 months. These respondents suggested that a separate stake limit for young adults would require extensive development by operators and software providers and would be far more complex and costly to implement than a universal limit. Overall, the majority (60%) of respondents favoured a stake limit of £2 or under for young adults aged 18 to 24. Of these respondents, the majority support a separate stake limit for young adults aged 18 to 24 that is £2 or below.

While smart TVs are not yet as optimized for online gambling as smartphones or desktops, the trend is shifting. To tackle the illegal online gambling market, we have introduced new powers for the Gambling Commission so it can more effectively take action against the black market through provisions in the Home Office’s recent Criminal Justice Bill. This is outside the scope of this consultation but has been considered as part of the Gambling Act Review and is covered in the gambling white paper. The majority of these related to proposals outside of the scope of this consultation, including recommendations for further action on advertising and changes to game design and customer-led tools.

We consider that this group will particularly benefit from a lower online slots stake limit. There is clear evidence of an increased risk of gambling-related harm among young adults, which can reasonably be concluded to be exacerbated by access to high stakes, rapid, and repetitive play on online slots. Alongside the GGY reduction, there will be some other costs to operators, such as the implementation costs of game development teams needing to test and deploy a stake limit on live games.