Making online games safer by design

The question

How does the UK Gambling Commission’s new rules modify online game design?

Key takeaway

Consumer protection on online gambling platforms is a growing area of focus. From 31 October 2021 new rules will ban features that increase gameplay speed, celebrate losses as wins or enable customers to cancel withdrawal requests.

The background

The Gambling Commission has been steadily increasing protections for consumers of online gambling platforms. In April 2020 the Commission strengthened protections relating to online age and ID verification, banned gambling on credit cards and improved customer interaction practices. Since then, the Commission has been keen to develop these protections further, particularly for online slots players. “Slots” are widely defined under the Commission’s new rules to cover reel-type games and casino games with non-traditional reels.

The Commission has found that slots game players have the highest average losses per player of any online gambling product. Slots are one of the largest online gambling products in terms of “Gross Gambling Yield” (ie they are played by few but recoup a high average spend per person). As a result, the Commission is keen to implement changes to slots rules to protect consumers. The Commission found that features that increase the intensity of play such as those that increase the speed of play and frequency of gambling opportunities increase the risk of addiction and harm.

The Commission aims to rigorously enforce the new changes from October 2021.

The development

The Commission is clearly moving towards a more consumer-protective stance. The new rules are intended to give players more control over their gameplay, which include:

• no auto-play features – all games must be started with a “start button” and there must be at least 2.5 seconds between each game cycle
• all gaming sessions must display the customer’s net position and elapsed game time since the start of the session
• players cannot engage in multiple slot games at once
• games can no longer celebrate losses as wins (or returns that are equal to the total stake gambled). Previously equal returns could be celebrated, but from 31 October 2021, only those wins that are greater than the total stake gambled can be celebrated (eg with fanfares).

Additionally, customers will not be able to cancel withdrawal requests (reverse withdrawals) on any online gambling platform. This means that once a withdrawal request has been made, the customer will not be able to override the request to gamble with the money instead.

Why is this important?

These developments will require remote operators to review and update online slots games and any other online gambling products that currently allow reverse withdrawals to ensure compliance by 31 October 2021. Slots games specifically will have to comply with the additional regulations and the Commission expects online operators to show a “greater commitment to… consumer protection”.

Online operators now only have nine months to implement the new rules ahead of the deadline.

Any practical tips?

Online gaming operators need to review how aspects of their platforms are impacted by the new rule, in particular their slots games and reverse withdrawal processes. For example, they should ensure ahead of the deadline that:

• any celebration settings are not triggered if the customer receives the same amount back as was gambled. Sounds and imagery that give the illusion of a win in an equal stake return scenario must be removed
• all games will need to be updated to check how reverse withdrawal policies are applied
• consider reviewing and disabling any slots game features that enable auto play or those that give an illusion of control over the outcome.

On a wider level, it is clear that the roll is on towards greater consumer protection measures on gaming platforms. If operators are aware of features on their sites which run contrary in spirit to this approach, now would be the time to start looking at them – before the regulators do. The government’s review of UK gambling legislation announced in December 2020 is further evidence of the way the regulatory wind is blowing.