September 25, 2020

In our recent article ‘What’s next for responsible game design’, we dissected the House of Lords report ‘Gambling Harm – Time for Action’ (the ‘Report’) and opined on the future of responsible product design and the work already undertaken by the industry in this area.

Most notably, we asserted our view that minimising harm to problem gamblers by better game design is best served by the work currently being undertaken in these areas by the Commission and the Betting and Gaming Council (BGC).

The BGC has today released its inaugural BGC Game Design Code of Conduct (the ‘Code’) that is the culmination of its review into the design of gambling products to ensure that safer gambling principles are fully incorporated into industry games.

Amongst other commitments, the Code sets out new “Code Standards” that are split into two phases of delivery and apply to online slots products:

Phase 1

The following standards represent measures BGC members have committed to having in place by 30 September 2020:

• minimum game cycle speeds of 2.5 seconds;
• the ending of turbo play (which allows players to speed up games);
• removal of base game slam stops within games (these features allow players to interact with the base game to end it before it has naturally concluded); and
• scrapping multi-slot play functionality, where a player can place multiple stakes on different games at the same time.

Phase 2

BGC members have also committed to implementing a range of additional measures which aim to enhance the transparency of games to players, both in the display of wins and clarity of game features, as well as adding friction and reflection to gaming sessions.

BGC members have identified a number of measures which can be in place for new games by 31 January 2021:

• clearer presentation of wins/stakes so that total wins below the stake amount will be clearly differentiated from wins that are equal to or greater than the stake and the win line will be displayed long enough for players to understand the impact of the bet (in line with existing RTS 7E); and
• improving clarity of bonus game notifications and requiring affirmative action from players including, without limitation, the requirement that bonus games outside the base game will not be automatically triggered without a customer intervention, e.g. clicking a button to acknowledge that a bonus game has been won and can now be entered.

In addition to the Code Standards, the industry announced that it will, via its game design research lab, explore ways to improve the labelling of games in order to increase players’ understanding of key terms.

The BGC has also committed to working with academics, regulators, consumers and individuals with lived experience of betting-related harm to identify best practice in game design going forward, to ensure the Code keeps up to date with changes in technology.

The Code sets out a wide range of industry commitments that evidence a desire to embrace and enhancing player safety through responsible game design.

It remains to be seen whether the commitments and proposals outlined in the Code will appease the Commission and the industry’s most notable critics.

The inaugural BGC Game Design Code of Conduct can be found here https://bettingandgamingcouncil.com/wp-content/uploads/2020/09/BGC-Game-Design-Code-1.pdf