In October 2025, the Gambling Commission (Commission) published its response to a supplementary consultation to clarify the definition of “deposit limits”, as operators had different methods of interpreting and applying deposit limits. This response followed a raft of changes to the Remote Gambling and Software Technical Standards (RTS), including changes to customer-led tools, following a response to the Commission’s consultation on broader changes to the LCCP and RTS published in February 2025.

Changes were set to be implemented in two stages, with the first set of changes to come into effect from 31 October 2025 and the second stage to be implemented in June 2026.

By way of reminder, the first set of changes concerned updates to RTS 12 on improving consumer choice of financial limits and the effectiveness of such limits. RTS 12 is now updated and all gambling businesses are required to:

• prompt new customers to set a financial limit before they make their first deposit and make it easy for them to review and alter their limit;
• remind consumers every six months to review their account and transaction information to help customers keep control of their gambling spend
• offer financial limits using free text and at the account level to help customers set meaningful limits
• provide financial limit setting facilities via a direct link on the homepage and deposit pages, minimising the number of clicks to reach these pages
• present setting a financial limit as the default choice, asking customers who choose to opt out to confirm they don’t want to set a limit.

The second set of changes, which were originally due to come into force on 30 June 2026, clarified that deposit limits should be “gross deposit limits” (rather than net deposit limits). A gross deposit limit caps the total amount a customer deposits into their account over a set period, without factoring in any withdrawals. By contrast, a net deposit limit offsets withdrawals against deposits.

All gambling businesses will be required to offer gross deposit limits to customers (which may involve re-introducing gross deposit limit options available to customers) and the offer of gross deposit limits must be presented with equal prominence to other types of financial limits that an operator may make available.

On 22 May 2026, the Commission published an update on its blog (see here) by which it informed the industry that:

• the implementation date for these changes has been extended to 30 September 2026 to allow operators more time to implement the necessary technical changes to comply with these deposit limit requirements; and
• the Commission has updated its response to the supplementary consultation on the definition of deposit limits to clarify that gross deposit limits must be set over fixed time periods (rather than rolling time periods). Rolling time periods may be used for other types of limits, as long as how the rolling time period works is made clear to players.

In its consultation response, the Commission observed that respondents had different interpretations of “rolling” periods. Some operators understood that the limit period would reset at a point based on when the limit was put in place, while others interpreted it as the limit duration restarting when the customer begins to gamble after a period of inactivity. The Commission considers that this ambiguity makes rolling time frames unsuitable for gross deposit limits, as they do not constitute a clearly defined period of time within the meaning of RTS 12B. Fixed time periods therefore provide greater transparency and consistency for consumers.

Operators that have reintroduced gross deposit limits due to these changes should inform customers of this when prompting them to review their account activity.

Despite the Commission’s extension, operators should not delay implementation work and should continue to monitor the Commission’s website for any updated guidance.

Practical steps that operators may wish to consider include:

• engaging legal teams to review deposit limit terms within the operator’s Terms and Conditions to ensure these are up to date and align with changes that will come into force on 30 September 2026;
• ensuring any financial limit currently described as a “deposit limit” meets the gross deposit limit definition under RTS 12B;
• updating customer support materials, including help pages and FAQs to reflect the restricted use of the term “deposit limit”;
• updating product user interfaces to ensure the required prominence of gross deposit limit options; and
• communicating any changes to customers in a clear and timely manner.