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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.

Respondents also highlighted the importance of retaining consumer choice and the risk of consumers moving to the illegal online market if they are no longer able to stake at their preferred levels. We received 98 responses to the consultation, including 46 individual respondents and 52 from organisations. Operators currently offer stakes from as little as one penny per spin, and we would expect a range of staking options far below the maximum to remain available.

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The majority of these respondents had selected the same general limit in the previous question. While online gambling, particularly via smartphone, is by far the most accessible form of gambling, it does afford meaningful protections which cannot easily be replicated offline. We believe that a £5 limit will achieve the government’s stated objectives in a proportionate way, with a lower risk of unintended consequences such as displacement to the illegal online market. In deciding which option to pursue, we have been led by the best available evidence and guided by the overarching objectives of the Gambling Act 2005 Review of ensuring an equitable approach to the regulation of online and land-based gambling. 24 of the 96 responses to this question were from gambling industry representatives, and nearly all argued for a £10 limit to ‘strike a balance’ between protection and freedom. Many of those in support of a £2 limit (Option 1) felt that it was the option most likely to reduce average losses or to help minimise the risk of runaway losses and therefore have a significant effect in reducing gambling-related harm.

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.

This highlighted the overrepresentation of customers identified as high risk among high stakers, although this data could not explore the cause of such overrepresentation. In addition to the views and evidence provided through the consultation, DCMS has considered a wider body of background information to guide decision making. Parts 1 to 4 of this document sets out respondent views and evidence on each section of the consultation before outlining the government response and intended action in each area. During this time, 98 submissions were received, including 4 by email and 94 via our survey platform. In April 2023, DCMS published the white paper on gambling setting out the government’s plans for bringing the regulation of the gambling sector into the digital age.

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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.

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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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Respondents suggested that multiple definitions in legislation and regulation would cause confusion and technical challenges for the categorisation of games, as well as potentially unintentionally capturing games outside of scope of the limit. Some respondents called for regular reviews of the description to future-proof its relevance to new online gambling products. To ensure the statutory instrument introducing the maximum stake limit is fully effective, we need to ensure a common understanding and also ensure the chosen definitions capture all intended products without driving unintended consequences. The data also showed that very few people stake at high levels for most of their slots gambling.

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