In July 2023, the Gambling Commission (GC) consulted on changes to remote game design requirements that would make remote games (excluding online slots which had been considered previously) safer and fairer for players with the aim of designing games in a way that can reduce players’ risk of harm and increase awareness of their game play.

This builds on responsible game design requirements that were imposed on slots in 2021, introducing new requirements in the Remote Gambling and Software Technical Standards (RTS) in respect of other casino products.

In May 2024, the GC confirmed six changes to the RTS relating to responsible game design. These changes will come into effect on 17 January 2025 and are summarized below:

– Player-led ‘spin stop’ features (RTS 14E): Licensees must not permit players to reduce the time they need to wait until the result of a game is presented. This prohibition applies to all casino games. Features such as turbo, quick spins or slam stops will be caught by this prohibition (although licensees should note these examples are not exhaustive, and any features that intensify the speed of a player’s game play may be caught under this prohibition).

However, the GC has clarified that this requirement does not apply bonus mechanics where an additional stake is not required. The implementation guidance also carves out certain game types from this prohibition, including those games that have a ‘scratch-all’ feature (i.e. on an instant-win type product) and games in which a player will lose their stake unless they take action to end the game (i.e. crash games). The GC’s rationale in excluding these games is that (i) they would be impossible to play if this functionality was removed and (ii) features such as the ‘sudden stop’ in crash games is not designed to speed up the game.

– Speed of play (RTS 14G): Licensees are required to implement a minimum of five seconds from when a game is started until a player can commence the next game cycle. This requirement will apply to all casino games (except slot games (which are already subject to a minimum speed of 2.5 seconds) and peer-to-peer poker games (although the five second requirement will apply to poker games played against the house)). The guidance confirms that a game cycle starts when a player presses the ‘start’ button and ends when (i) the player either loses all the money they staked/ won during the game or (ii) the player’s winnings are available for collection, and the start button appears to initiate a new game.

– Autoplay (RTS 8): The scope of the prohibition on automatic play has been widened from slots only to all online gaming products. The autoplay feature is considered problematic as it may lead to dissociation from playing behaviour, which subsequently increases the likelihood of harm. This is more problematic with fast and repetitive game types. The prohibition on autoplay means that games will need to be designed to require players to commit to each individual game cycle; but it will not prevent peer-to-peer poker players from auto-posting blinds. Interestingly, the GC has excluded auto-dabbing in bingo games from the autoplay prohibition on the basis this applies to starting a new game cycle rather than autoplay during the game itself.

– Effects that give the illusion of ‘false wins’ (RTS 14F): Gambling systems are prohibited from using auditory or visual effects for a ‘win’ when the player is not actually ‘winning’ more than their original stake. The motivation behind this change is a concern that positive reinforcement (i.e. through celebratory sounds or graphics) of returns below the amount staked can give players a misleading impression of their overall win/loss position.

This requirement now applies to all casino games (having already been in place for slots). Players must also be made aware of the result of their game cycle, including by displaying the total amount awarded (or lost) during that game play and a brief sound to signal the (positive) result of the game and a transfer to the player’s balance.

The GC identified concerns with live dealer casino games where, for instance, a croupier celebrates a win but (as it is not always clear to the croupier whether the amount won is above that player’s initial stake) they inadvertently celebrate a ‘win’. Whilst the prohibition refers to the ‘gambling system’ (and therefore does not include croupiers), the GC has nonetheless stated it expects those licensees offering such live games to deploy technology to improve this situation.

– Operator-led simultaneous products (RTS 14C): Operators are currently prohibited from allowing players to play multiple slots simultaneously (i.e. where a player can split their screen and have different slot games open on different tabs or by allowing a player to play multiple slot games on multiple screens). This functionality increases the speed and intensity of play on certain types of casino games, and could also circumvent restrictions on speed of play. The prohibition at RTS 14C will now also extend to all casino games (with the exception of peer-to-peer poker and also bingo and betting). The rationale for excluding these products is that they are not typically played simultaneously with other products and therefore present a lower risk.

– Display of net position and time spent (RTS 2E): Operators are required to display a player’s net position (being the total of that player’s winnings less the total of their losses since the start of the gaming session, in the currency of their account) from the time the respective gaming session started. A gaming session starts when a player begins playing the game for real money and ends when the player exits the game. Accordingly, a gaming session may include multiple game cycles. This requirement will apply to all casino games (except peer-to-peer poker).

Operators must also display the time elapsed throughout the gaming session (RTS 13C). The timer should commence either when the player opens the game or when they start playing.

If you have any questions about responsible game design, please get in touch.