Changes to direct marketing, game design, personal management licences, and age verification

Planned changes to the Licence Conditions and Codes of Practice (LCCP) and Remote Gambling and Software Technical Standards (RTS) will impact licensed gambling operators.

In this article, Keystone Law gambling partner Richard Williams explains the changes and what operators need to be aware of.

Direct marketing – SR code 5.1.12 (remote casino, bingo, betting licences)

From 17 January 2025:

• All new and existing customers must be allowed to opt-in to direct marketing on a per product and per-channel basis (N.B. opt-out/pre-ticked boxes are not allowed):
  • Channel options – phone call, e-mail, SMS (text) (N.B. push marketing isn’t covered)
  • Product options – betting, casino, bingo.
• These opt-in options must be offered as part of the customer registration process.
• Licensees must not encourage customers to change their selection (the only option must be to accept or decline direct marketing).
• Customers must not receive direct marketing for products or via channels they have not specifically opted in to.
• Customers logging in for the first time after commencement of SR Code 5.1.12 must confirm their opt-in marketing preferences before they are permitted to gamble.
• Does not apply to lotteries and land-based operators.
• Operators should review their marketing consent procedures to ensure they comply.

Game design – RTS 14e, 14g, 8a, 14f, 14c, 2e & 13c

From 17 January 2025:

• Time for results (remote casino games) – Customers must not be able to reduce the time limit before a game result is presented. Turbo, quick spin, slam stop features are not permitted. Does not apply to bonus/feature games with no additional stake.
• Speed of play (remote casino, excluding P2P poker and slots) – Minimum five seconds between game start and next game cycle. A customer must manually commence each game cycle e.g. by pressing a start button.
• Autoplay (gaming including bingo) – Auto-play cannot be offered. Does not prohibit posting blinds in peer-to-peer poker.
• False wins (casino games) – System must not celebrate a win which is equal to or less than the stake gambled. Prohibits auditory or visual effects associated with a win, when nothing is actually won.
• Simultaneous games (casino, excluding P2P poker) – Customers must not be allowed to play multiple games at the same time e.g. split screen or multi-screen.
• Net position and time spent gambling (casino, excluding P2P poker) – Gaming sessions must display a customer’s net position (winnings minus losses) since the session started. Time elapsed in seconds, minutes and hours must be displayed for the duration of the session.

Personal management licences

• CEO or MD (or equivalent) is in overall management and direction of a licensee’s business and must hold a personal management licence (PML).
• The Chair of a Board holds a key role and must hold a PML (apply from 1 August 2024).
• The Head of AML/CTF holds a key role and must hold a PML (apply from 1 June 2024).

 Age verification (land-based premises)

• All adult gaming centres (AGC), bingo, family entertainment centres (FEC) and betting premises must conduct test purchasing or take part in collective test purchase programmes and must provide the results to the Gambling Commission.
• Think 25/Challenge 25 must be adopted as an age verification procedure to prevent gambling by those aged under 18.

If you have questions or concerns about these changes, please contact Richard Williams.