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Our view is that the description above is clear on the types of game in scope, but if necessary the Gambling Commission has powers to update the remote technical standards definitions to respond to emerging risks or boundary pushing products. The Gambling Commission consulted on this definition before introducing the new rules, and considered a number of amendments and / or alternatives suggested by stakeholders. Under Section 78 of the Gambling Act 2005, the Secretary of State may provide for a specified condition to be attached to gambling operating licences through secondary legislation. Slots must also display the money and time spent during a session. We acknowledge, however, that further evidence would be useful to inform precisely what the limit should be to achieve the government’s objectives of effective harm prevention with minimal disruption to those not being harmed. Any changes to the law will be made by secondary legislation to create a new licence condition on remote gambling firms.

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However, in light of the evidence that young adults (specifically those aged 18 to 24) may be a particularly vulnerable cohort, the white paper committed to consult on extra slot-specific protections for this group, as well as lower thresholds for financial risk checks. It is the age from which age-restricted products such as alcohol, tobacco and the full range of gambling activities are permitted. A £15 limit would also have the smallest effect on operator GGY of all the options being considered.

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This is the highest limit permitted on any land-based gaming machine at present. Stakes over £2 currently contribute an estimated 18% of slots GGY. For instance, on several occasions in previous years, the limits on land-based gaming machines have been adjusted to reflect the impact of inflation. However, we recognise those already in the grips of an addiction are the most likely to respond to the stake limit in other ways than reducing spend.

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In contrast, play on land-based gaming machines is often anonymous, although staff are on site and able to intervene. With the imposition of a stake limit, we expect maximum prizes will also shrink as operators adjust their commercial exposure. This description will be adapted in legislation to introduce a maximum stake limit. To note, our intention is that the imposed limit should serve as a maximum stake which customers can choose to stake up to, rather than as a new default which operators drive customers towards, or which is otherwise seen as objectively ‘safe’. Sometimes operators add a bonus to the stake as a promotional device, but here the stake is taken to refer only to the customer’s own money put at risk. “stake” means an amount paid or risked in connection with gambling and which either-

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