On the 9th July 2020, the UK Gambling Commission (UKGC) published its consultation document on online slots game design and reverse withdrawals, which will close on the 3rdSeptember 2020.
The aim of the consultation is to provide the industry with UKGC’s ideas insofar as its planned consumer protection enhanced framework, and invites UKGC licensees to provide their feedback, as the introduction of such measures will surely require operators to carry out software, design and configuration changes to both their games and back-office control system.
The UKGC’s proposed framework includes the possibility of introducing new controls targeting those products that tend to present the highest propensity of problem gambling, mainly online slots. The proposed measures which will see their incorporation within the UK’s Remote Gambling and Software Technical Standards, will also see the UKGC not allowing operators to reverse customer withdrawal requests.
The consultation document states, “this proposed suite of enhanced controls will be incorporated within the remote gambling and software technical standards (RTS), which sets out the specific technical standards that licensed remote gambling operators and gambling software operators need to meet”.
A few of the proposed measures which should attract the operators’ attention include:
1. Defining online slots within the RTS as “Casino games of a reel-based type (includes games that have non-traditional reels)”.
2. Amending RTS 2E on the mandated display of Net Position, where “all gaming sessions must clearly display the net position, in the currency of their account or product (e.g. pounds sterling, dollar, Euro) since the session started…” where the Net position is defined as “the total of all winnings minus the sum of all losses since the start of the session”
3. Amending RTS 8C to prohibit auto-play functionality on online slots.
4. Amending RTS 13C: All gaming sessions must clearly display the elapsed time since the session started…where…time displayed should begin either when the game is opened or once play commences, [and the] time should run for the duration of the session regardless of whether the customer minimises the session… Elapsed time should be displayed in seconds, minutes and hours
5. Amending RTS 14C, by prohibiting multiple slot game being played by a single account (player) at the same time. This would probably require operators to change their control system to prevent a second slot game to open without the first slot having being closes or logged out from.
6. Amending RTS 14D, by introducing speed of play limits of a minimum of 2.5 seconds from the time a game is started until a player can commence the next game cycle. It must always be necessary to release and then depress the ‘start button’ or take equivalent action to commence a game cycle, that is from when a player presses the ‘start button’ or takes equivalent action to initiate the game and ends when the button is once again available to use. The proposed RTS 14D see that “A player should commit to each game cycle individually, continued contact with a button, key or screen should not initiate a new game cycle”.
7. Amending RTS 14E, by not allowing for ‘spin stop’ features, and thus “the gambling system must not permit a customer to reduce the time until the result is presented…features such as turbo, quick spin, slam stop [shall] not [be]permitted.
8. Amending RTS 14F, so as to make it clear to players that celebrations of part accomplishments or returns (through the use of “auditory or visual effects that are associated with a win”) which are at least not equivalent to the total amount staked cannot take place.
9. RTS 14B on prohibiting players to self-cancel withdrawals so as for the “Consumers…not [to]be given the option to cancel their withdrawal request. This means that once a customer has made a request to withdraw funds, they should not be given the option to deposit using these funds. Operators should make the process to withdraw funds as frictionless as possible.
A very important element that is taken into account in the Consultation document centres around the testing strategy, whereby the UKGC recognises (to some extent is alerting) that the above proposed changes will have an impact on the licensee’s systems, which will undoubtedly require system and design changes, and as a consequence will have an impact on the testing requirements of each operator.
The UKGC however warns operators that once the changes within the RTS come into effect, should such changes not be implemented within the designated effective timeframe (both for the games and functionality), the UKGC warns that:
“As a principle, operators must satisfy themselves that they are offering compliant games. Where they are not sure, any existing game will require independent retesting. …All new games published after the commencement date for these requirements will need to be tested…games which are not compliant by the commencement date will need to be temporarily removed until such time as they can be verified. Games that require retesting could be prioritised based on popularity to spread the demand for testing.”
The Consultation Document Questionnaire may be accessed by clicking here
This article is not intended to impart legal advice and readers are asked to seek verification of statements made before acting on them.
For further information on UK gaming licensing, compliance or for any required support services kindly contact our Head of Compliance Services Stefan Briffa or our Gaming Practice Partner, Reuben Portanier.