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We therefore intend that the description of ‘online slots’ in the statutory instrument will remain fully consistent with the Gambling Commission definition established in 2021. 78% of respondents agreed with the description of ‘game cycle’ proposed in the consultation. 86% of respondents to this question agreed with the description of ‘maximum stake’ proposed in the consultation.

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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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Part 1: The scope of limits

This phased approach gives acknowledgement to the development of any technical solutions by operators which may be required for age-based limits. If approved by Parliament, these will impose new licence conditions on remote gambling operators which the Gambling Commission will then be responsible for enforcing. Individual responses included 6 individuals working in gambling or gambling regulation and 3 academics or researchers. Alongside the consultation, we published a consultation stage impact assessment to help inform responses. The purpose of this consultation was to ensure that the government was able to consider the best available evidence, including on the impact of each option, when finalising policy decisions. Following the Department of Culture, Media and Sport’s (DCMS) review of the Gambling Act 2005, the gambling white paper published in April 2023 set out the government’s plans for modernising the regulation of the gambling sector.

The stake limit proposals outlined in this consultation response are in line with those intentions. Stake limits for online slots are only one part of the wider package of regulatory and legislative changes which is intended to create an appropriate balance. Similarly, some respondents highlighted concerns around the use of gambling-like mechanisms being applied to non-gambling contexts such as video games and cyrptocurrencies. 23% of respondents highlighted that young people will be discriminated against on the basis of age if a separate lower stake limit is implemented. Some industry respondents highlighted that a single stake limit would be easier to implement than 2 separate limits. Many of the comments and supplementary evidence focused on the positive impact of a stake limit on those either directly or indirectly affected by gambling-related harm.

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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.

These were considered separately to the case for a lower limit for young adults, which is discussed in Part 3 below. In line with the white paper commitment, the consultation outlined 4 options for consideration. If any of these descriptions prove too narrow to effectively deliver the policy intent, then both the government and the Gambling Commission will look to revise it. These respondents disagreed for different reasons, with some saying it was unclear, others arguing it was too restrictive, and others saying it was not restrictive enough and might contain loopholes. A frequently expressed opinion amongst industry respondents was to keep the description exactly aligned with the already established and widely understood Gambling Commission definition. Some operators responding to the consultation raised technical concerns about the description, where the proposed wording extended the definition established by the Gambling Commission in 2021 in an effort to ensure boundary pushing products are captured.

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All online play is account-based, and recent years have seen significant strides in the development of harm detection algorithms which monitor every aspect of a customer’s gambling to spot signs of risk and trigger interventions without human input. Moreover, it takes consideration of the structural differences between land-based in-person gambling and online play. We think that a £5 maximum stake for adults aged 25 and over will help to reduce harm because of the constraint on a player’s ability to place very large stakes quickly. Some respondents called for additional measures not in scope of the consultation, including further action on advertising and game design.

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We acknowledge the concerns that this wider description has the potential to unintentionally capture games outside of scope of the stake limit and the intention of the white paper. 65% of respondents who answered this question agreed with the description of ‘online slots’ proposed in the consultation. Online slots are ‘Remote casino games of a reel-based type (including games that have non-traditional reels or which combine elements of other games within a slot game mechanic).’ DCMS has continued to work closely with the regulator in considering the appropriate stake level for online slots, and considering how any new limits will overlap with other measures being consulted on by the Gambling Commission.

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After considering the consultation responses, we have decided to introduce a stake limit of £2 per spin for young adults aged 18 to 24. Several industry respondents suggested that implementation for a separate stake limit would take over 9 months. These respondents suggested that a separate stake limit for young adults would require extensive development by operators and software providers and would be far more complex and costly to implement than a universal limit. Overall, the majority (60%) of respondents favoured a stake limit of £2 or under for young adults aged 18 to 24. Of these respondents, the majority support a separate stake limit for young adults aged 18 to 24 that is £2 or below.