UKGC White Paper Recommendations Include Affordability Checks, Online Stake Limits

The United Kingdom Gambling Commission (UKGC) has finally released a white paper it has been promising since December 2020. As expected, it contains several recommendations for reforming the country’s gaming industry, some of which may be unpopular with operators. The most substantial proposed changes target the online casino industry, while their retail counterparts could see a few limits loosened.

Weighing in at 268 pages, High Stakes: Gambling Reform for the Digital Age doesn’t make for light reading. However, much of what it contains won’t come as a surprise to the industry. Many of the recommendations are along lines the UKGC has already been exploring. For justification, the report leans heavily on past research, such as the 2020 National Strategic Assessment and last year’s Patterns of Play.

The proposed changes to online gambling include the following:

  • Mandatory affordability checks triggered by certain loss thresholds
  • Requirements for operators to share data relating to high-risk users
  • Stake limits for online slots
  • Possible other changes to product design requirements and deposit limits

Conversely, retail casinos – particularly small ones – stand to benefit in a few ways:

  • Increased limit on the number of machines and the ratio of mid- to low-stakes machines
  • Sports betting at all casinos, regardless of size
  • Repeal of the ban on cashless gaming

Another interesting proposal is the addition of a new levy on gambling, with the money going directly to research, education and treatment of gambling addiction. The paper doesn’t specify how large this extra tax should be.

Why is the UK Clamping Down on Gambling?

The UK’s gambling industry has been facing an upheaval for years. Whereas the US has been expanding, the UK market is much more mature, and gambling culture is more pervasive. The industry had few restrictions for many years but ultimately faced backlash in the public, media and political spaces due to a rise in gambling-related harms.

That has taken several forms, including escalating fines by the UKGC. While regulatory penalties of $100,000 to $350,000 still make headlines in the US, the UKGC has recently begun hitting operators with fines in the millions or even tens of millions of pounds for compliance and responsibility failures.

The white paper is, therefore, a document worth studying for US operators. It’s a crystal ball, offering a glimpse of one possible future if things get out of hand.

UK Gambling by the Numbers

Problem gambling is a notoriously tricky thing to study. Even estimates of its prevalence vary widely and depend on the methodology. The white paper points out that the Commission has calculated the rate in the UK to be as high as 1.3% at times and as low as 0.2% at others.

Whatever the actual rate, it’s small, but the consequences of gambling addiction can be dire.

The paper points out some good news. Gambling rates are highest among employed, educated and mentally healthy people, who are at comparatively low risk.

The flip side of that is that the risk of gambling harm is three times higher among those who are unemployed than those who are employed. It’s higher by a similar margin among those without university degrees than among graduates.

Patterns of Play also found that roughly 21% of online gambling accounts are net winners over the course of a year, while another 73% lose £1000 or less. For most people, that represents an affordable pastime in line with other leisure options. However, a YouGov survey also found that 34% of UK residents say they have less than £1500 in discretionary income per year. So, even some of these seemingly small losses may be creating financial problems.

Why the Focus on Online Casinos?

As for why the UKGC is singling out online gambling, the paper points out that 5% of adults in the UK have played online slots in the past year. Similar numbers have engaged in sports betting, with mobile sportsbooks now being the preferred way to bet. These rates are higher than any other form of gambling except the lottery.

The concern seems to be that the low stakes and ready availability of online gambling apps may be tempting to those whose financial situation should discourage them from gambling at all.

The Proposed Modifications to UK Online Gambling Regulation

The white paper proposes a few immediate changes and suggests many avenues for further exploration. A complete discussion of everything it contains – even just on the topic of online gambling – would be too much for one article. However, a relatively small number of suggestions are likely to have a disproportionate impact.

Affordability Checks: a Hot-Button Topic

The paper has been over two years coming. Throughout that time, it’s been no secret that affordability checks would be among the things it discussed. Indeed, the UKGC has been nudging operators ever more aggressively to conduct them, though it has stopped short of requiring them outright. The white paper recommends that they become a requirement.

Specifically, it recommends two tiers of checks with different triggers.

  • Quick, non-invasive checks for losses of £250 in one month or £500 in one year
  • More detailed checks with triggers of £1000 in a single day or £2000 in 90 days, or lower for gamblers under 24 years old

The former checks would look for red flags indicating the gambler might not be able to afford any significant losses. Such indicators would include court judgments or bankruptcy filings.

The more detailed checks would be similar to a credit check. The UKGC estimates only 3% of gamblers would be subject to such checks based on current activity levels.

Although an increasingly popular suggestion among problem gambling advocates, such checks aren’t without their critics. Detractors say they invade privacy and deprive gamblers of the right to make their own choices. Such objections will probably be even more vigorous if and when the conversation arises in the US.

Stake Limits for Online Slots

In 2018, the UKGC announced that it would reduce the stake limit on fixed odds betting terminals (FOBT) from £100 to £2. FOBTs are, essentially, a form of slot machine allowed in betting shops around the UK.

As many had warned, the change led to the closure of many betting shops. William Hill alone shuttered 700 locations.

An additional sore point has been that no such limit has been applied to online gambling. The main counter-argument is that accessing black market online casinos is easier than illegal retail gambling. Limiting the stakes of legal online casinos while illegal ones have no such limit might drive more gamblers to the black market.

Even so, the white paper recommends that some limit be applied to online slots. This could be as low as £2like the FOBTs. However, the report recommends considering a higher limit, up to £15. As with the affordability checks, it suggests a stricter limit for younger gamblers.

Data Sharing on High-Risk Customers

The paper recommends that when operators identify high-risk customers, there should be a requirement to share that information with one another. The idea is that if a player has exhibited harmful habits on one site, other operators should be prepared to intervene more quickly if the problem recurs.

Data-sharing requirements are starting to appear in the US as well. So far, however, they involve sharing data with the regulator rather than with other operators. New Jersey initiated such a program this year, for instance.

Further Design Changes

The UKGC already updated its design guidelines for slots in 2020. Those changes – controversial in their own right – forbade several popular features, such as:

  • Turbo spins for faster play
  • Sounds and animations that present a payout smaller than the bet size the same way they would a winning spin
  • Mechanics that provide the illusion of skill or choice without genuinely changing the result

The white paper recommends further review of the rules. However, it seems that additional changes would primarily be focused on slowing gameplay down further, as the rapid pace of slots is one of their main risk factors for creating addiction. At the same time, the paper recommends against treating other types of casino games differently. It points to certain roulette titles as allowing a slots-like pace of play and says these should be subject to the same rules.

US Operators Need to Think Ahead

Whatever policies the UKGC adopts as a result of the white paper won’t directly impact the US. However, the UK market provides an example of what the US industry might expect to happen if it continues on its current path.

In the sports betting space, for instance, we already see similar discussions on both sides of the Atlantic around athlete sponsorships and excessive advertising during games.

Any new regulations will have an impact on the industry, often one that’s negative in the short term. However, that impact is much more significant when operators aren’t prepared.

In the UK, the industry didn’t heed the writing on the wall and was blindsided by the FOBT stake limit and restrictions on slots design. Things needn’t go the same way in the US. The white paper represents a sneak preview of ideas that could make their way to US legislators and regulators over the next decade.

Companies that operate in both markets, like Flutter and Entain, won’t be caught off guard if that happens. But domestic companies like DraftKings and Caesars would do well to take heed and be appropriately proactive in minimizing the disruption of a future regulatory crackdown. Or, better yet, avoiding the need for one altogether.

About the Author

Alex Weldon

Alex Weldon

Alex Weldon is an online gambling industry analyst with nearly ten years of experience. He currently serves as Casino News Managing Editor for, part of the Catena Media Network. Other gambling news sites he has contributed to include PlayUSA and Online Poker Report, and his writing has been cited in The Atlantic.
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