Our first detailed analysis of the White Paper focussed on the key proposals around product restrictions, namely stake limits, responsible game design, player centric tools and prize draws and competitions. In relation to responsible games design, the Government was clear that it wanted to introduce design controls to online products in order to “prevent harm at source and reduce the reliance on reactive harm detection systems”.

In order to assist, the Great Britain Gambling Commission (“Commission”) was tasked with providing information on previous responsible game design measures in order to provide guidance on the proposed new design controls.

Background

Back in February 2021 we wrote about the Commission’s raft of measures designed to make online casino games safer by design (“Game Design Measures”).

The Game Design Measures, to be implemented by online operators no later than 31 October 2021, included the outright ban of four key features of online slots games:

• features that speed up play or give the illusion of control over the outcome;
• slot spin speeds faster than 2.5 seconds;
• auto-play – which can lead to players losing track of their play; and
• sounds or imagery which give the illusion of a win when the return is in fact equal to, or below, a stake.

The Commission was tasked with assessing the impact of the Game Design Measures in order to be in a position to consider game design rules for online products generally, such as “limits on speed of play to reduce immersiveness and rapid losses and intensifying features such as simultaneous play of multiple games” and the provision of real-time data on session losses, before consulting in the summer of 2023 on specific updates to the remote technical standards.

The Commission has, today, provided its assessment on these Game Design Measures and the impact that it has had on the sector.

Assessment of online games design changes

 The Commission notes a number of key observations from its monitoring of gambling behaviours and attitudes after the Game Design Measures were introduced.  This includes:

• reduced play intensity on online slots products since the changes were introduced – the proportion of sessions lasting over 60 minutes fell from 7.8 percent to 6.9 percent.
• Stable ‘binge gambling’ on slots games – Reported binge information is stable, with a positive indication for post-change financial losses. Slots are still viewed as a product that is easy for people to become engrossed in;
• no increase in staking activity in response to the limit on spin speeds – There is strong evidence that staking has not increased because of the changes; and
• no evidence of a significant, negative impact on the enjoyment of gamblers.

While the Game Design Measures are still in its early stages, the report suggests that the Game Design Measures have not caused an increase in staking activity in response to the limit on spin speeds, have reduced play intensity and have not had any negative impact on the enjoyment of the games on gamblers.

The report is helpful in explaining where it obtained its data from and is quick to admit that much of the data available will be more reliable when observed over a longer period.  As such, many of the Game Design Measures do not appear to have resulted in significant improvements; however, the data available shows that no gambling behaviour has deteriorated. As with any new measures that are introduced in relation to game design, there will be a multitude of players who will not be affected and will continue to play as normal. This includes those players who always played slots at a slower pace than 2.5 seconds per spin prior to the implementation of the Game Design Measures, and as such their activity would not be captured by the report. This begs the questions of whether further research is to be conducted/captured prior to the games design consultation that will be published this summer.

That being said, the Commission should be applauded for publishing this report which is worth reading. The Commission is, rightly, being tasked with assessing the effectiveness of its own regulations (Game Design Measures) and, as the White Paper-based policy aspirations play out through consultations, the regulator must observe its duty to properly assess regulation in the round. It must clearly demonstrate the impact that all relevant regulatory changes implemented in the last few years have had. Only then can it realistically identify any residual gaps to fill to meet the Government’s objectives.

It will be interesting to see how this report will influence the consultation on responsible games design that is due out later this year. Will the Commission look for similar results that they have reported in their “Assessment of online games design changes” Report or will they look to introduce more significant changes?

The Commission’s “Assessment of online games design changes” Report can be accessed here.