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Some noted that many gambling operators already offer additional protections for customers aged 18 to 24 such as restrictions on high-value customer schemes, lower deposit limits, and bespoke social media advertising requirements. Others felt that a two-tier approach to stake limits would only serve to generate further disparity with the land-based sector where the same limits are consistent across all adults. 34% of consultation respondents were in favour of a universal limit of £2 across all adult age groups as the lowest limit within the consultation range. There were a number of views on whether additional protections are needed for young adults and whether a separate lower stake limit should be implemented.

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This highlighted the overrepresentation of customers identified as high risk among high stakers, although this data could not explore the cause of such overrepresentation. In addition to the views and evidence provided through the consultation, DCMS has considered a wider body of background information to guide decision making. Parts 1 to 4 of this document sets out respondent views and evidence on each section of the consultation before outlining the government response and intended action in each area. During this time, 98 submissions online casino were received, including 4 by email and 94 via our survey platform. In April 2023, DCMS published the white paper on gambling setting out the government’s plans for bringing the regulation of the gambling sector into the digital age.

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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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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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However, some industry respondents felt that a two-tier limit was still preferable to a universally low limit for all adults, despite the additional implementation challenges. However, some industry respondents were much more supportive of a separate age limit for young adults which recognises the particular risks for that cohort, and aligns with the broader aims of the white paper in protecting vulnerable groups. These respondents argued that a separate limit could be unfairly discriminatory and provide a precedent for discrimination based on other protected characteristics.

• There is clear evidence of an increased risk of gambling-related harm among young adults, which can reasonably be concluded to be exacerbated by access to high stakes, rapid, and repetitive play on online slots.
• The ‘summary of consultation responses’ including the figures and percentages in each section reflect only the respondents who engaged with each specific question, rather than the overall respondent body.
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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.
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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.

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Some respondents considered the description to be too vague and therefore open to loopholes, while others felt that it was too restrictive. Alongside updated data from the Gambling Commission on the size of remote gambling licence holders split by size of workforce and number of licences held. For young adults aged 18 to 24, just 2.1% staked over £2 for more than half of their spins and 0.4% staked over £5 for more than half of their spins. Only 3.9% of those aged 25 and over staked over £2 for more than half of their spins, and just 0.7% staked over £5 for more than half of their spins. However, 18 to 24 year olds placed a slightly higher proportion of stakes between £2 and £10, compared to older adults.

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