High stakes: gambling reform for the digital age
Particular concern was raised in some submissions to the call for evidence that free bets or other promotional offers might encourage harmful engagement with gambling both in the present, and following a period of abstinence, and this was reflected in some of the most robust evidence available. Online gambling operators, like many other technology firms, have developed sophisticated means of segmenting their audience and keeping key customers engaged. The same study found a similar but much less pronounced trend for other advertising (influencing 3% of the ‘non-problem/low-risk’ group versus 9% of the ‘moderate/problem’ group), indicating the particular risk posed by direct marketing to those who are experiencing harm from their gambling.
Energy costs per machine will be estimated in the final stage impact assessment using an energy calculator. A more detailed estimate of the impact for each option will be presented in the final stage impact assessment, once further data has been collected. This increase is expected to be higher under Option 1 than Option 2, as operators will not be restricted by device constraints. Data on net expenditure per session shows that from April to September 2019, the vast majority of sessions across all machine categories ended in the player either winning money or losing up to £20. A ‘mixed session’ is a single session that takes place on games of different machine categories. Unlike Option 1, it would be much more difficult for an operator to increase the number of B3 cabinets on their premises by increasing the number of Category C or D in-fills and tablets that they site.
Should card account verification (such as chip and PIN or Face ID on mobile payment systems) be required if direct cashless payments are permitted on gaming machines? Therefore, the government’s position is to consult on what principles and player protections should be put in place to support any relaxation of the rules around playing gaming machines with a debit card. Permitting cashless in a targeted way, for example allowing debit cards to be used to pay for particular types of gaming machines or machines in certain types of venues, would not provide clarity on the principles and player protections required within a cashless framework.
A further safeguard to ensure that credit will not be available more widely is the fact that it will be offered at the casino’s risk following extensive anti-money laundering (AML), Know Your Customer (KYC) and Enhanced Customer Due Diligence (ECDD) checks at the point at which credit is offered. Alongside the removal of the prohibition, the Gambling Commission will specify in licence conditions and codes of practice the conditions under which credit may be offered, including checks which must be made. The Gambling Commission has made clear that it expects casinos to bank customer cheques in accordance with their normal banking arrangements. Until recently, casinos in Great Britain have been able to accept a cheque from the customer, which is a permitted payment mechanism under the Act.
From the early days of underground gambling dens to the modern era of licensed casinos, the UK has witnessed significant changes in the way casinos are regulated and operated. The ban took effect on 14 April 2020 and applies to nearly all online and land-based gambling establishments. Another measure aimed primarily at online operators is the ban on gambling with credit cards. All online casinos must participate in the multi-operator self-exclusion scheme GAMSTOP, the UKGC announced in January 2020.
Role of the UK Gambling Commission
This includes lotteries, betting on sports and horse races, bingo, as well as gaming machines at pubs and land-based casinos. We do not see this as being an issue for operators or manufacturers as it is already widely available on Category B gaming machines within all land-based gambling premises. While it is acknowledged that the risk of gambling harm may increase somewhat following a transition to 50/50, the stipulation outlined in Option 2 would ensure that operators offer a balance of higher and lower stake gaming machines.
The full impact is explored in further detail in Section 10 of Annex A. Alongside the changes to this ratio, we expect operators to continue to improve player safety controls as outlined above, and work with regulators to ensure full compliance. Without an increase in stakes or a change to the 80/20 rule, operators have highlighted their difficulties in meeting increased costs. Concerns regarding energy efficiency are particularly relevant, with operators estimating that costs have increased significantly over recent months. The code includes a commitment to introduce standards to all new land-based slots products such as ensuring cash payout games do not appeal to children and that awards below the stake are not celebrated.
However, over the longer term, some industry representatives have suggested that operators would likely further reduce their number of Category C and D cabinets in favour of multi-staking Category B cabinets. Under the scenario outlined in Option 2, it is anticipated that a genuine balance and choice of higher and lower stake machines would be achieved across venues. Indeed, we reviewed data that showed some operators, particularly in the bingo sector where tablets are in widespread use for playing bingo games, have significantly greater numbers of Category B cabinets than Category C and D cabinets. It would also provide greater flexibility in determining the make-up of their machines and potentially lead to the removal of machines, such as tablets and in-fills, that are infrequently played. Consequently, it would deter operators from offering tablets and in-fill devices as a way to increase the number of Category B cabinets on their premises.
Additionally, it advises the government and local authorities on various gambling-related issues and may recommend amendments to the current legislative framework. The agency has investigative powers and may prosecute illegal gambling operations. The UKGC has no authority over spread betting, which is regulated by the Financial Conduct Authority. On 1 October 2013 the National Lottery Commission was abolished, and its responsibilities – including monitoring and regulating the National Lottery – were transferred to the Gambling Commission.
We conclude that the 80/20 rule on gaming machines in arcades and bingo clubs is no longer required to offer the customer protections originally intended, and does not provide a workable framework for operators to make commercial decisions. The bingo trade organisation provided evidence of consumer demand for Category B gaming machines in venues, over and above Category C and D machines, particularly during the short breaks in the main stage bingo game. Currently, no more than 20% of the total number of gaming machines in licensed bingo premises and adult gaming centres are allowed to be Category B machines (known as the ‘80/20 rule’). If Parliamentary time allows, we would also consider making changes to allow trials of linked machines in venues other than individual casinos, and to permit the rollout of linked machines more generally (e.g. after a trial has taken place and the data analysed). The Commission also raised concerns that linked machines could encourage riskier gambling behaviour and be of concern for vulnerable customers, and that such proposals would need to be more fully explored. We will require any new or additional requirements for operators in relation to cashless payments on gaming machines to be in place before the prohibition is lifted.
Some industry stakeholders questioned the necessity of the sliding scale given the numbers of SSBTs where they are currently permitted are low, and this could be seen as adding to an already complex regulatory framework. This would mean any table gaming area would only count towards the minimum table gaming area if it constitutes 12.5% or more of the total table gaming area in the venue. Exempt venues will be prevented from increasing their gambling area further, from 16 May 2024. Those opposed to the reduction preferred a larger minimum table gaming area requirement in place such as 350sqm. With regard to venues currently operating with a gambling area of 1500sqm or more, the strongest preference from consultation respondents was for these venues to be made to reduce their gambling area below 1500sqm.
Our initial headline impact estimate (see table below) for key proposals which we are able to quantify, is a potential drop of between 3% and 8% in commercial Gross Gambling Yield (with a drop in online GGY of 8% to 14% partially offset by a land-based increase of 2% to 5%). The proposals are targeted with the intent of minimising this unintended consequence, and the resultant costs to industry, to be proportionate to the objective of reducing harm. Because harmful gambling tends to involve elevated spend, our package of measures to prevent harm is likely to reduce the revenue of gambling companies.
All stakeholders recognise the potential for a so-called single customer view (SCV) to tackle this risk. Customers’ ability to swap to another account risks undermining the effectiveness of an individual operator’s safeguarding interventions. Likely impacts are explored in more detail in Annex A of this white paper, and the Commission will give further consideration to impacts, including the potential for any unintended consequences, through its detailed consultation. The Data Protection and Digital Information (No .2) Bill, currently before Parliament, includes some important clarifications to the rules around lawful processing and the circumstances in which personal data collected for one purpose can be used for other purposes, which should make the law clearer in this area. We will also make sure consumers’ financial lives are not impacted through these checks, with credit scores being unaffected and potentially adverse consequences of reciprocal data sharing avoided. We recognise these proposals have significant implications for collection and handling of sensitive consumer data, raising important questions around privacy, data protection, proportionality, data accuracy, and reciprocal data sharing.
What measures, if any, do you think venues should adopt to ensure that no under-18s play on ‘cash-out’ Category D slot-style machines if the age limit is introduced? Should ‘cash-out’ Category D slot-style machines be required to move to age-restricted areas in venues? Should the government introduce an age limit on ‘cash-out’ Category D slot-style machines to 18 and over? This does not distinguish between ‘cash-out’ and ‘ticket-out’ machines. The survey found that in the last 12 months, 3% of respondents had spent their own money on fruit or slot machines and a total of 6% had experience of playing on fruit or slot machines.
Football Index was a novel betting platform that allowed customers to place bets on the future performance of footballers. In recent years, some products have started to blur the boundaries between gambling and investments or operators have marketed their platforms in such a way. Surrender of a licence means that an operator whose actions were causing concern is no longer able to offer services to customers in Great Britain, which may address the principal concern. In particular, it is concerned that licence holders are able to take action that can hinder or frustrate an investigation, including surrendering their licence during the course of the investigation.
So in common with the previous legislation, there has been a recognition that consent will not always be the appropriate basis for data processing. Consent is one way to comply with GDPR, but the new law provides five other ways of processing data that may be more appropriate than consent. The rules around consent only apply if a business is relying on consent as its basis to process personal data. One example of this is the myth that “data can only be processed if an organisation has explicit consent to do so”.
Any remote gambling operators that kept all their equipment, facilities, etc. offshore were exempt from applying for a licence. Before this act, remote operators were only required to non gamestop casino obtain an English licence if they had at least one piece of remote gambling equipment located within UK borders. Residents can access multiple domestic and offshore entities for casino gambling, poker and sports betting.
Respondents from the land-based gambling industry were generally supportive of proposals which would remove restrictions on supply, pointing to the unrestricted availability of the same products online. The casino measures section of the consultation received 41 responses from a variety of stakeholders, including gambling operators and trade bodies, local government organisations, campaign groups and academics. We will introduce an age limit of 18 and over for the use of ‘cash-out’ Category D slot-style gaming machines. We will allow direct debit card payments to be made on gaming machines, subject to the player protection measures outlined within this government response. In practice, this means that 2 Category B gaming machines on a cabinet device type can be made available to a minimum of one Category C or D gaming machine on a cabinet device type. This measure will apply on a device type basis, meaning that the ratio applies across the 3 different types of device on which gaming machines content is currently offered in arcades and bingo halls, namely cabinets, in-fills and tablets.
We will consult on raising the cap for the fees licensing authorities can charge adult gaming centres, betting premises, bingo premises, casinos and family entertainment centres for premises licences. In the land-based sectors, operators and industry bodies highlighted high pass rates for test purchasing and the adoption of ‘Think 21’ and ‘Think 25’ policies in licensed betting offices, bingo premises and casinos. The Patterns of Play data project, commissioned by GambleAware and based on industry-provided data, has been an important step forward in maximising the value of the rich data which operators collect to inform understanding of how players and online gambling interact. Unlike land-based gaming machines, such as in casinos, they have no statutory stake limits.
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- According to the NHS Long Term Plan more than 400,000 people in England are problem gamblers and two million people are at risk.
- • Lobby areas and toilet facilities may be taken into account but the non-gambling area shall not consist exclusively of lobby areas and toilet facilities.
- The measures set out today will shield players in the grip of addiction from harm and hold gambling firms to account when they fail in their responsibility.
- Where 1968 Act casinos are smaller than these requirements, we have proposed that they are able to benefit from an increased number of machines on a pro rata basis commensurate with their size and non-gambling area, and subject to the same ratio.
- It was also suggested that point of purchase messaging could also be used to communicate a wider range of risks including potential health harms.
Consultation responses included views from industry, academics, treatment providers and individuals. Responding to evidence, a lower level stake limit for young adults aged years old will be set at £2 per spin. In August 2026, a survey conducted by GamblingNews.uk found that 68% of Brits believe bookmakers sometimes „use anti-money laundering and responsible gambling checks as pretexts to void winning bets or delay payouts“.
A voluntary ban on front-of-shirt gambling sponsorship by Premier League clubs was announced in 2023, with clubs working to a phased exit. Applied to the net stake receipts of bookmakers and betting exchanges. Expect enhanced due diligence on any player who deposits heavily, uses unusual payment routes, or trips a risk indicator.
This includes many casinos monitoring customer expenditure across all gaming products, enhanced due diligence measures with trigger values for spend and loss applied to customers and algorithmic systems that use predictive models to identify customers at risk. While online operators are able to track play precisely and apply more tailored player protections, land-based casinos have adopted a range of measures in recent years that have enhanced player protections and tracking. As outlined in the white paper, it is our intention to bring greater coherence to the licence system by allowing 1968 Act casinos of a certain size to have the same gaming machine allowance as Small 2005 Act casinos. Unlike most commercial gambling, Category D gaming machines, which include coin pushers and crane grabs, are not restricted by age. In order to future proof the gaming machine industry and adapt to modern payment technologies, we are seeking views on a range of player protections that will ensure players can use modern payment methods whilst mitigating the risk of harm. Measures that we are seeking views on are intended to address inconsistencies between the different types of casino licence, as well as levelling the playing field to an extent between land-based and online operators.
