UK Launches Wave Of Pivotal White Paper Consultations

July 27, 2023
In a “key moment” for the UK gambling industry, the Gambling Commission and the Department for Culture, Media & Sport have both published their first set of highly-anticipated white paper consultations.


In a “key moment” for the UK gambling industry, the Gambling Commission and the Department for Culture, Media & Sport have both published their first set of highly-anticipated white paper consultations.

The Gambling Commission’s summer consultation opened on July 26 and closes on October 18, 2023.

A host of key areas are covered, including financial vulnerability and financial risk checks for online gambling.

Other topics in this round of consultations include improving consumer choice on direct marketing, strengthening age verification in land-based premises, extending personal management licence requirements and a number of changes to the composition and decision-making processes of the commission’s Regulatory Panels.

Tim Miller, Gambling Commission executive director for research and policy, said many of the proposals “have already had a significant amount of engagement and scrutiny, and the government's white paper sets out the policy positions”.

“We are pleased to now focus consultation and engagement on the detail of how such protections and controls can be implemented in practice. Today’s launch is a key moment in turning the commitments in the white paper into reality,” Miller said.

Separately, the DCMS has launched its own public consultations looking at what level stake limits should be set for people playing online slot games, which closes on September 20, and another one on measures relating to the land-based gambling sector, which closes on October 4.

The government is consulting on a maximum stake of between £2 and £15 per spin and on options to introduce greater protections when playing slots for 18 to 24-year-olds, such as lower stake limits of £2, £4 or requirements on operators to consider age as a risk factor for gambling-related harm.

Land-based casino changes under consideration include relaxing casino rules, changing gaming machine rules in arcades and bingo halls, cashless payments on gaming machines, introducing a legal age limit of 18 for certain gaming machines and ensuring that licensing authorities have the funding they need to carry out their duties.

Steve Ketteley​, a partner at Wiggin, explained that “the most significant of this raft of consultations has now begun”.

“Its significance cannot be overstated,” he told VIXIO GamblingCompliance.

“Clearly, the government seeks balance here though and the Commission should as well,” Ketteley​ said, adding that the challenge for the regulator and other stakeholders is to “identify a clear framework that determines what actually happens at those thresholds”.

“If all those concerned are to avoid the regulatory uncertainty that has plagued the affordability debate in the last 2-3 years, we all need some certainty. More references to outcome-based regulation, which leaves stakeholders scratching their heads, may just store up problems for the future. The Commission really needs to get this one right,” said Ketteley​.

In the Gambling Commission consultation, affordability proposals are split in two, covering financial vulnerability checks and financial risk assessments.

Vulnerability checks cover a “light touch” check to identify customers who may be particularly financially vulnerable.

These are envisaged as “unintrusive checks, using publicly available data at moderate levels of spend”.

The commission proposes that these are conducted at £125 net loss within a rolling 30-day period or £500 within a rolling 365-day period, which it estimates will reach approximately 20 percent of customer accounts and identify vulnerabilities such as where a customer is subject to bankruptcy orders or has a history of unpaid debts.

Risk assessments cover enhanced checks “at unusually high loss levels where the risks are greater” and “are proposed to be informed primarily by credit reference data”.

The regulator has proposed for them to apply where losses are greater than £1,000 within a rolling 24 hours or £2,000 within 90 days. It also proposes that the triggers for enhanced assessments should be lower for those aged 18 to 24.

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