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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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In the Gambling Commission’s participation survey, reporting on data in the year to March 2023, the problem gambling rate for 16 to 24 year olds (1%) was higher than the headline problem gambling rate (0.3%). Respondents who were not in favour of a separate limit raised concerns about some adults being treated differently based only on their age. Respondents also mentioned that younger adults may be less informed on the risks of gambling or may have lower incomes than older adults. It is unclear how many of those who supported consistency in limits for all adults would support a lower limit for young adults if the general limit is to be higher than £2. Our intention is that there will be future opportunities to review and if necessary adjust the limits. The Gambling Commission is also exploring improvements to online harm detection algorithms which will mean other markers of harm are more effectively identified and acted on.

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The primary difference is at staking levels over £10, which take up a lower proportion of overall stakes for young adults aged 18 to 24 than those 25 and over. Stakes over £5 comprised 0.06% of all spins and stakes over £20 comprised just 0.02% of all spins. To inform the consultation and consultation stage impact assessment, DCMS formally requested data from leading operators.

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29% of consultation respondents selected Option C (a stake limit for young adults aged 18 to 24 that is consistent with the limit for all adults but with extra operator vigilance). We also acknowledge the calls for changes to game design, specifically to slow down the speed of online slots games. A £5 limit aligns with the stake limit for B1 machines in casinos which we believe to be the most comparable land-based gambling environment in terms of risk.

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The majority of these respondents had selected the same general limit in the previous question. While online gambling, particularly via smartphone, is by far the most accessible form of gambling, it does afford meaningful protections which cannot easily be replicated offline. We believe that a £5 limit will achieve the government’s stated objectives in a proportionate way, with a lower risk of unintended consequences such as displacement to the illegal online market. In deciding which option to pursue, we have been led by the best available evidence and guided by the overarching objectives of the Gambling Act 2005 Review of ensuring an equitable approach to the regulation of online and land-based gambling. 24 of the 96 responses to this question were from gambling industry representatives, and nearly all argued for a £10 limit to ‘strike a balance’ between protection and freedom. Many of those in support of a £2 limit (Option 1) felt that it was the option most likely to reduce average losses or to help minimise the risk of runaway losses and therefore have a significant effect in reducing gambling-related harm.

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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