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Industry respondents expressed concerns about the impact of a stake limit on innovation within games. A similar number of respondents focused on the cost to the gambling industry and raised concerns about the displacement of customers to the illegal online market as a result of the introduction of stake limits. A few respondents argued that young people should not be allowed to access online slots games.

Some respondents also referenced evidence that some ethnic minority groups have a higher risk of problem gambling or being an affected other. A few respondents cited evidence that people with learning disabilities / on the spectrum of learning needs are at a greater risk of suffering gambling-related harms. Several respondents highlighted the difference in problem gambling rates between men and women. A separate limit for young adults aligns with the wider government approach to gambling of targeted and evidence-based interventions for those at risk, while not unduly restricting others.

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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.

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The primary difference is at staking levels over £10, which take up a lower proportion of overall stakes for young adults aged 18 to 24 than those 25 and over. Stakes over £5 comprised 0.06% of all spins and stakes over £20 comprised just 0.02% of all spins. To inform the consultation and consultation stage impact assessment, DCMS formally requested data from leading operators.

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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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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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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Developers are already exploring simplified versions of games tailored to TV interfaces, such as one-click slots or roulette with basic navigation. Technologies like Google Chromecast, Apple AirPlay, and Samsung Smart View allow you to stream your casino session to your TV in real time. Not all games display correctly, and filling out forms can be inconvenient. Platforms offering access to top non-GamStop casino options are increasingly exploring compatibility with smart TVs as part of their user experience strategy. Some respondents felt that this discrimination would be unfair and put young adults at a disadvantage when gambling online.

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The consultation was published alongside a consultation stage impact assessment to help inform respondent’s views. The introduction of a statutory levy on gambling operators will also ensure independent, long-term and trusted funding for high quality research to inform policy and regulation. In addition, in the time since consulting, we have looked to build on our evidence base by formal data requests to industry and carrying out desk research. We are grateful to the respondents who highlighted important evidence as part of their submissions.

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Most advocated for a minimum implementation period of 6 months and suggested that a longer period would be required for age-based stake limits. However, we acknowledge that the implementation of a separate stake limit adds a layer of complexity for businesses in making the necessary changes to software. We believe the evidence justifies increased protections for this cohort, including a separate lower stake limit. Some suggested the existing safeguards for this cohort are sufficient (and will be further strengthened via financial risk checks) and that separate stake limits would be disproportionate and largely ineffective.

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There are also multiple live blackjack variants that include extra features and rules to add new dimensions to the games, often making them more dynamic and fast-paced than traditional blackjack tables. Winnings are determined by the game being played, the likelihood of a win and the amount of money that’s been staked during the round. If the player wins the round they’ll get their stake back, plus their winnings. This is how much the player is willing to gamble for each round of the game, whether that be the spin of a slot game or a round of blackjack. The TV can act as a supplementary device for immersive visuals and social gameplay.

Problem gamblers who have voluntarily excluded themselves from physical casinos are likely to be able to gain access to gambling via the internet if they so wish. On the internet, bets are often smaller and may thus seem far more affordable than gambling at a casino, but the amounts being bet can quickly accumulate. Many online gambling sites also allow people to bet just a few pennies to start with, which can lure them in before they start spending bigger amounts. Many gambling websites offer practice or demo sessions where a person can take part in the gambling activity for free, and practise without staking any money. Your device becomes the casino, and it’s always in your pocket and ready to be played. Some surveys have found that compared to those who visit physical casinos, online problem gamblers are significantly less likely to have sought formal help.

We have considered feedback from respondents, including the concerns raised by operators in relation to the proposed description of ‘online slots’ where the proposed wording extended the definition established by the Gambling Commission in 2021. Many of these respondents considered that the proposed description was unclear or open to loopholes and may result in inconsistent application of the stake limit, but did not give specific examples of how it might be circumvented. A few respondents suggested that independent and accredited test houses should be responsible for classifying games rather than operators who may subjectively interpret whether a game meets the slots definition or not. ‘Maximum stake per spin’ means the maximum amount a player can pay or risk per spin or game cycle. While stakeholders broadly recognise online slot-type products as a distinct class of remote casino game and have an intuitive understanding of the key terminology such as stake and game cycle, these terms are not all defined in legislation.

The use of smart TVs for gambling is still in its early stages. Some smart TV manufacturers restrict gambling content or block downloads of related apps based on your geographic location. Also confirm that responsible gambling tools are available and functioning. This impacts how easily you can navigate casino sites, especially when placing bets or chatting.

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