The inception of the Apple App Store was a turning point in the distribution and monetisation of apps for mobile phones.

Challenges preceding the App Store

Prior to the App Store, we had a somewhat dysfunctional and convoluted way to install extended
functionality on our mobile phones—or, in a lot of cases, no ability whatsoever.

I recollect building Symbian App’s and trying to install them on Nokia and Ericsson phones. To be
honest, it was so painful and difficult to monetise, we gave up.

New European legislation

The Apple App Store has estimated annual revenues of $24bn, making it one of, if not the most valuable, digital storefronts.

New European legislation comes into effect on 7 March 2024 that will have a sizeable impact on Apple’s policies. The most notable will be: Removing the restriction on In-App Purchasing (IAP), allowing third parties to use external payment for services, and external App Stores.

Let’s drill into this in a bit more detail.

Challenges and changes to IAP

Back in 2020, Spotify lodged a complaint against Apple to the European Commission Anti-Trust organisation, stating Apple IAP was anti-competitive and restrictive.

An unnamed (but I suspect we can all guess) audiobook and e-reader retailer made a similar claim. Additionally, the Epic Games lawsuit in the U.S., while not considered directly, seemingly influenced the commission’s decision and contributed to the introduction of new legislation under the Digital Markets Act (DMA).

Fundamentally, under the DMA Apple cannot mandate the use of IAP by app developers, allowing apps to access external payment services to top up or buy content.

This, I think, overall is good for the industry, though, and we should be mindful of this, Apple has the right under the DMA to charge “commission,” and I suspect they will do this through the App Store submission process. We’ll have to wait and see on that one!

Regulating external app stores

The second item is External App Stores. Apparently, the restrictive practices that Apple applies to their “Guidelines” (let’s face it, they are rules) under their review process are considered anti-competitive. Now I have to say that I disagree with this.

As we have seen with Google, which now has a similar review process to Apple with their Play Store, both companies are trying to build trust and stop fraudulent apps from being installed on their platforms. With the significant increase in digital fraud, surely their approach should be applauded rather than maligned?

Interestingly Google offers a Side Loading option, where you can install an app off a website or even a third-party “App Store.” It flags several security warnings on installation, and on more recent versions of Android, a setting must be enabled (buried deep in the menu) to turn this feature on.

In our own analysis of this and surveying user behaviour, we found an almost zero uptake of this feature by “normal” consumers. Sure, the techies occasionally used it, but this shows consumers preferred appetite is to “buy” from trusted merchants (Apple).

Implications for real-money gaming

What’s next? Well, the new Apple Guidelines have been published, and the original 4.7 section has subtly changed; importantly, section 5.3 has NOT changed, and critically, the issue of IAP never applied to the Betting, Gaming, and Lottery (BGL) industries. So, ironically, the Digital Markets Act is somewhat irrelevant to us.

The original guideline requirement under 4.7.1 of “not provide access to real-money gaming” has been removed. However, critically, this has been added to 4.7: “You are responsible for all such software offered in your app, including ensuring that such software complies with these guidelines and all applicable laws.”

Therefore, we view this as meaning that the organisation submitting an app to Apple App Store is responsible for ALL content that the app offers and, critically, within the BGL space, that it complies with all the Apple Guidelines and local applicable laws.

So, provided your HTML5 casino games are licensed by an appropriate regulator (and thus comply with applicable laws), you are now free NOT to embed the content in the app – bye, bye ODR.

We are still waiting for full clarity from Apple… Part of their answer has been to submit an app and see what happens – which is exactly what we have just done – so we’ll see, but this does seem to be a 180 reversal of Apple’s original 2019 guideline change.

About mkodo

mkodo is a leading provider of digital apps and user interfaces for the lottery and gaming industry worldwide.

Licensed and regulated by the Alcohol and Gaming Commission of Ontario (AGCO) in Ontario and Gaming Policy and Enforcement Branch (GPEB) in British Columbia.

Founded in 2001, the company has been recognized for its core strength to develop and deliver successful digital experiences to the target audience of their customers’ online users.

mkodo’s clientele comprises several leading lotteries and gaming companies around the world, including the majority of the Canadian lotteries and some of the largest gaming operators in the U.K. For more information, please visit

Stuart Godfree is a recognised leader in the iGaming industry. Back in 2001 he co-founded mkodo, the award-winning B2B iGaming supplier of mobile and front-end technology, after starting his career as an applications engineer. In 2010, Stuart became mkodo’s managing director.

He has more than 2 decades worth of expertise in the industry and in 2023 officially launched GeoLocs, an alternative geolocation verification service which has been used exclusively by mkodo’s clients for over a decade. 

The UK government will introduce a £2 stake limit for 18- to 24-year-olds playing online slots, alongside a £5 stake limit for adults aged 25 and over.

The decision follows a 10-week consultation period, during which the majority of respondents supported the proposal outlined in the gambling white paper

The aim is to reduce the risk of gambling harm associated with online slot games, including the potential of large losses, extended play sessions, and binge playing. 

Unlike land-based gaming machines in the UK, online slots currently have no statutory stake limits.

The limits will come into force in September. 

Operators will have a six-week transition period to comply with the general £5 stake limit rules, followed by an additional six weeks to develop any necessary technical solutions to ensure full compliance with the lower £2 stake limit for young adults aged 18 to 24.

Higher problem gambling rate

The government said the lower stake limit for young adults, set at £2 per spin, reflects the age group’s higher average problem gambling score compared to other demographics. 

Factors such as lower disposable income, ongoing neurological development affecting risk perception, and common life stage challenges like managing money for the first time all contribute to their vulnerability. 

Evidence also suggests a stronger correlation between gambling-related harm and suicide among young adults.

Gambling minister Stuart Andrew (pictured) said: “Although millions of people gamble safely every single day, the evidence shows that there is a significantly higher problem gambling rate for online slot games.

“We also know that young adults can be more vulnerable when it comes to gambling related harms, which is why we committed to addressing both of these issues in our white paper.

“The growing popularity of online gambling is clear to see, so this announcement will level the playing field with the land-based sector and is the next step in a host of measures being introduced this year that will protect people from gambling harms,” he added. 

A concerning trend

GambleAware CEO Zoë Osmond praised the government’s move as a crucial step in protecting young people from the harms of online gambling.

“Our research shows a concerning trend with this age group experiencing an increase in harm arising from gambling and online slots are very high-risk products.

“As we continue our work to tackle this growing public health issue, we will collaborate with the government and others across the gambling harms sector to ensure there are no missed opportunities when it comes to the introduction of robust preventative measures, including new regulations such as these,” she said. 

The stake limits represent just some of the proposals outlined in the government’s white paper to modernise the gambling sector. 

Other proposals include the introduction of a statutory levy for research, prevention and treatment, as well as the much-discussed affordability checks

The government said responses to the wider white paper measures will be published soon.

Curaçao’s Minister of Finance has defended the government’s decision to issue a direct licence before the passage of its new gambling law.

This month, Curaçao MP Steven Croes voiced concerns over the government approving the first direct licence to a gambling operator under the new regime.

Croes was concerned as the new licence, which was issued to Rhino Entertainment Group entity White Star BV, was authorised prior to the passage of the island’s new gambling law.

The controversial National Ordinance for Games of Chance (LOK) is currently making its way through Curaçao’s parliament.

According to the government, the bill is intended to clean up the online gaming sector through direct licences, improved standards, and a revamped regulator.

However, the proposed law has faced criticism from the Curaçao Bar Association, MPs, and the Advisory Council which scrutinises legislation. As such, the bill is currently being reworked.

“The recently expressed objections of members of parliament are currently being investigated and the LOK will be adjusted where necessary,” said Minister of Finance Javier Silvania.

The Dutch government is also investigating whether the LOK complies with an original 2020 deal to clean up the gambling industry in return for Covid-19 relief funds.

Minister cites 1993 law

Silvania defended the ministry’s decision to grant the first licence before the passage of the LOK.

He argued the licence was authorised under the 1993 Offshore Gambling Ordinance (LBH), which he said “remains fully applicable as long as it is not repealed by the national ordinance”.

Historically, Curaçao licences have been issued to only six master licence holders, which then franchise sub-licences to prospective operators.

These sub-licences, which were not provided for in the original law, lack many of the regulatory requirements of the master licences. It is this system which has faced widespread criticism for its lack of oversight.

However, the 1993 law itself is a brief document. Consisting of around three pages, the lack of detail in theory allowed a broad scope for the government to set out the particulars of its regulatory regime.

Since it is not yet clear when the LOK will enter into effect, the minister said he had decided to “develop a new policy based on the LBH,” where the island’s Gaming Control Board (GCB) can issue direct permits to operators.

“By having direct control over the issuing of licences to operators and exercising direct supervision over them, the GCB can itself carry out the necessary background checks on potential and existing license holders, thereby helping to identify and deter persons or entities with links to criminal activities, such as money laundering or organised crime,” said Silvania.

“The new policy therefore aims to increase confidence in our online gaming industry by mitigating the risks of criminal, fraudulent, misleading and unfair practices. This is also crucial in view of the upcoming CFATF Mutual Evaluation (MEVAL), which will take place in June this year.”

While Croes requested a copy of the licence, the minister refused citing “sensitive information” contained within.

Two bills legalising lottery, casino and sports betting have been passed to Alabama’s State Senate for consideration after being approved in the state’s House of Representatives.

House Bill 151 and House Bill 152, if approved by the senate, would pave the way for the introduction of a state lottery, limited casino gambling and sports betting, and introduce new rules including tax rates to govern the activities.

HB151 was passed last week by 70 votes in favour against 32 in opposition, while HB152 was passed by 67 votes to 31.

“We heard you loud and clear from the polling, and we’re giving the citizens the right to decide what they want in the state as it relates to gaming,” said Republican Alabama State Representative Chris Blackshear, who sponsored the bill, after it was approved.

The bills will now head to the Alabama Senate for consideration. If approved there, they will be put to a statewide vote later this year.

If approved by a majority of Alabama’s population, the legislation would be passed to Governor Kay Ivey to be signed into law.

Ivey has already expressed her support for the bills in their current form.

“The proposal passed by the House will clean up and crack down on the rampant illegal gambling and will give Alabamians the opportunity to have their say on regulated, limited forms of gaming,” she said in a statement last week.

Bill contents

HB152, which sets out the details of what a regulated gambling sector in Alabama could look like, offers some insights into what operators in the state could expect if the bills are passed.

For the operators of casinos, or “casino-style gaming establishments”, a minimum $5m licence fee would be applied, and a maximum of seven licences would be issued.

One of those licences would be reserved for the Poarch Band of Creek Indians.

Gaming services providers would also need to seek licensure in the state and pay any associated fees, as would any prospective sports betting operators.

Further, the bill would see a 24% tax on net gaming revenue (NGR) established for casino-style gaming, which is estimated would generate between $315m and $492.2m in tax revenue annually for the state.

Sports betting, meanwhile, would be taxed at 17% of NGR, which would generate an estimated $15m-$41.5m in additional tax revenue annually, according to HB152.

Further, the bill would establish the Alabama Lottery Corporation to run lottery games throughout the state, which would contribute an additional estimated $305.6m-$379.4m to Alabama’s finances each year.

A new regulator, the Alabama Gaming Commission, would be established to oversee the sector, and would receive powers to issue fines to non-compliant companies up to a value of $100,000.

Lawmakers in the Netherlands have rejected a proposal for an outright ban on advertising, but have approved two other new measures related to the country’s gambling sector.

Rule change attempt

Last week, members of parliament across three different political parties (Derk Boswijk of the Christian Democratic Appeal, Mirjam Bikker of the Christian Union and Michiel van Nispen of the Socialist Party) each introduced a motion in the Netherlands’ lower house related to the gambling sector.

Boswijk introduced a proposal for a total ban on gambling advertisements – intended to take previously approved legislation to ban all untargeted advertising one step further, and ban all ads across the board, including direct marketing.

Bikker, meanwhile, put forward a motion to introduce cross-operator playing limits for customers, to prevent players simply moving from one operator to another once their play limits have been reached.

Finally, van Nispen introduced a third motion to allow for more severe penalties to be applied to gambling companies not in compliance with local regulations, allowing the regulator to issue fines up to a value of 10% of a company’s turnover.

Ad ban falls through

The proposed outright ban on gambling advertising was supported by the same MPs whose efforts previously saw the introduction of a ban on untargeted advertising – meaning ads were longer be permitted outdoors or on TV and radio.

That ban came into effect in July last year, with a further ban on sports sponsorships by gambling companies set to be enforced from July 2025.

However, when introducing a motion to extend the impact of the ban even further, MP Boswijk said: “The question in advance is whether the minister is open to a total ban on gambling advertisements. 

“Gambling advertisements reach a broad audience of children, young people and young adults, for example through sponsorship on the t-shirts of football teams.”

MP van Nispen also supported the effort, asking minister for legal protection Franc Weerwind: “How can we expand this advertising ban even further?”

The proposal sought to treat gambling advertising in the same way as tobacco ads, via the introduction of a blanket ban across the board.

When the proposal came to be voted on by Dutch MPs across the chamber, however, it fell just short of the 76 votes in favour required to advance its progress.

The proposal received 70 votes in favour, meaning a slim majority of 80 MPs rejected it.

New rules approved

In the other two cases, however, MPs were able to garner sufficient support to advance their proposals to the next step.

MP Bikker’s proposal to introduce cross-operator loss limits was approved by 79 MPs across the chamber, and Bikker therefore requested further information from Minister Weerwind on how the proposal will be implemented.

For his part, Weerwind advised against the introduction of such a limit, and is not legally obliged to implement the notion.

Elsewhere, MP van Niespen’s proposal to introduce harsher penalties for non-compliant operators received broad support across the house, as 102 out of 150 MPs voted in favour of the rule change.

The proposal is intended to ensure that bad actors in the sector are hit with fines “that really hurt,” worth up to 10% of their annual turnover.

Van Niespen also made clear that tougher action still should be taken against those companies which do not prevent repeat violations from taking place.

“As far as we are concerned, permits should also be revoked, for example in the event of recidivism,” he said. 

“Has that ever happened, the withdrawal of a permit? I do not think so. As far as we are concerned: end of story for the cowboys without morals.”

The Gambling Commission (UKGC) is set to receive increased powers to block websites offering illegal gambling under the UK’s new Criminal Justice Bill.

The Criminal Justice Bill is a wide-ranging amendment to UK criminal law, aiming to improve the ability of police and other law enforcement agencies to combat a variety of different crimes.

It has passed its first and second readings in the House of Commons and is currently being discussed at the committee stage.

Once approved there, it will move onto the report stage before undergoing a third reading in the House of Commons.

It will then be passed on to the House of Lords for further consideration before being signed into law.

Increased powers for IP suspension

Part of the bill aims to improve the ability of law enforcement and other investigative agencies to suspend IP addresses and domain names that are being used in serious crime.

The law will allow police and other agencies to apply for court orders requiring IP or domain name providers to block access to any website thought to be used for criminal purposes.

At present, UK law enforcement is able to gain access to certain IP addresses blocked through public and private partnerships, whereby providers will often voluntarily suspend domain and IP addresses following a request.

However, new powers for law enforcement are set to be introduced because voluntary suspension of IP and domain addresses is not always an option.

In cases where domains are listed outside the UK, for example, the same voluntary arrangements are not available, and internet infrastructure providers based abroad will only take action following the handing down of a court order.

The new law therefore enables UK law enforcement agencies to apply for court orders which can be served to entities based outside the country.

New powers for the UKGC

In a public bill committee discussion yesterday (16 January), Labour MP Carolyn Harris asked Minister for Policing Chris Philp (pictured) if the law may be used against “illegal gambling sites and crypto casinos”.

In response, Philp said that where illegal activity is taking place, the provisions of the bill would apply.

The bill also includes provisions for “a member of staff of the Gambling Commission of at least the grade of executive director” to make applications for court orders to be handed down to those it expects to be involved in crime.

“That is very helpful and will strengthen our hand with overseas entities that might not respond to a polite request but are willing to act when there is a court order,” Philp said.

“I hope that is something that we can all get behind. It will help protect our constituents from online crime, particularly fraud, but other forms of illegal activity, including illegal gambling.”

The new powers should help the UKGC in its ongoing efforts to crack down on unlicensed gambling operators.

In 2021/22, the regulator received additional funding to help tackle illegal gambling, resulting in a 500% increase in enforcement actions against unlicensed operators in 2022/23.

Between May and July 2023, the UKGC was able to restrict access to four of the top 10 illegal domains in the UK via geo-blocking, while web traffic to the market’s largest illegal sites fell by 46%.

Brazilian president Luiz Inácio Lula da Silva has officially signed the country’s sports betting and iGaming bill into law.

The legislation sets out rules for online gambling operators as well as licensing processes and tax rates.

In December, the bill underwent several changes as it was passed between Brazil’s Chamber of Deputies and Senate, before finally being approved by the lower house to await presidential sanction.

Before Federal Deputies approved the bill, stipulations for operating online casino games were returned to its contents having previously been removed.

That means the law now approved by President Lula will allow operators to offer both sports betting and iGaming in Brazil.

Player winnings taxed in full

The legislation was passed almost exactly as it was approved by the Chamber of Deputies, although one significant change did take place before its approval.

Previous editions of the rules suggested that player winnings would be taxed at a rate of 15% on any amount over R$2,112 (€397).

That threshold, however, was deemed inappropriate as it would result in a different tax rate to other gaming modalities, such as lotteries. 

As a result, all online gambling winnings will now be subject to a flat 15% tax, regardless of the size of the win.

Licence applications inbound

Following the law’s approval, Brazil’s Ministry of Finance is set to issue regulatory decrees and other provisions to allow the sector to become regulated.

Once the relevant legal documentation has been published, operators will have 180 days to formally submit their licence applications and adapt to the new rules.

Brazil’s government aims to have all the relevant regulations published this month.

Applicants for licences will be required to pay R$6m, and will need to abide by a series of rules to ensure consumer protection, responsible gambling and sports integrity.

Brazil’s sports betting bill has been approved by the country’s Senate and will now pass back to the Chamber of Deputies for final approval.

Before the bill was approved by senators, however, the introduction of regulated iGaming (online casino) was removed as opposition senators voted to exclude it from the bill by a vote of 37 votes to 27.

Once the newly amended bill is approved by representatives in Brazil’s lower house, it can be signed into law by president Luiz Inácio Lula da Silva.

Betting rules finalised

With amendments now made in the Senate, it’s likely the rules have reached their final form before being officially signed into law.

Senators approved the tax rate on operators set at 12% of GGR, as well as an additional tax set at 15% of customer winnings over R$2,112 (€394).

Originally, the bill included a tax rate of 18% of GGR and 30% of customer winnings, but those rates were lowered in November.

Back in October, Brazil’s Finance Minister Fernando Haddad invited companies interested in securing a licence in the country to declare their interest.

At that time, the Ministry also set out several of the requirements for licensees including that foreign operators must apply for licensing through a Brazilian subsidiary with a headquarters and legal representative based in the country.

Other requirements around responsible gambling, advertising and the protection of sports integrity were also set out at that time.

iGaming gone

The biggest change undergone by the bill in the Senate was the removal of iGaming.

Senators postponed their vote on the bill twice prior to its approval yesterday (12 December) in order to give more time to consider the inclusion of online casino.

Ultimately, senators voted against its inclusion due to fears around the responsible gambling implications.

Another amendment to the bill saw the explicit prohibition of the use of physical gaming machines in establishments such as bars, supermarkets and bakeries.

Supporters of including iGaming in the regulations, however, said it would guarantee additional revenue for the government from games that are already being offered to Brazilians on the black market.

The bill’s rapporteur, Angelo Coronel (pictured), said following the vote that: “Online games, according to information we obtained throughout this report, are responsible for around 70% of betting revenue. 

“As it was approved in the Senate, the government will only have 30% of what it expected to collect,” he concluded.

Coronel had previously suggested that the regulation of sports betting and iGaming could generate as much as R$10bn per year for the government.

Macau’s government has drafted a new legislative bill featuring an explicit ban on online betting, as well as harsher penalties for those conducting illegal gambling activities.

The bill also aims to explicitly define and outlaw the practice of so-called parallel betting or side betting.

It was announced by Macau’s secretary for administration and justice André Cheong Weng Chon, who is also the spokesman for the government’s top advisory executive council.

If approved, the bill will replace Macau’s current criminal law on illegal gambling, which was established in 1996.

Online ban and increased penalties

Given that Macau’s current gambling law was introduced before the proliferation of online betting, the new bill proposes an explicit ban on the operation, promotion and organisation of all online gambling activities, regardless of whether the respective IT systems and equipment are installed in Macau.

The bill would also introduce more severe penalties for those found to be breaking gambling laws. At present, those operating unlawful gambling activities may face a prison term up to a maximum of three years.

The new bill proposes increasing this limit so that the penalty for gambling offences may include prison terms of between one and eight years.

Further, the bill would also lift restrictions on police’s ability to search private homes at night, which at present they are prevented from doing.

For the purposes of investigating certain gambling crimes, the new bill would allow police to search private homes between the hours of 9pm and 7am without permission from the resident.

The bill will be submitted to Macau’s Legislative Assembly in due course for review and debate, after which there will be a vote on whether it is signed into law.

Parallel betting ban

Another key element of the new bill is to introduce an explicit ban on parallel betting, sometimes called side betting.

This development follows on from efforts in recent years to clamp down on the activities of junket operators in the region.

Junket operators help facilitate gambling for wealthy Chinese visitors to Macau, by extending credit and collecting on their debt on behalf of casino operators.

Operating junkets is permitted in Macau given that operators hold a licence, but the number of licensees has fallen dramatically in recent years, from more than 200 in 2013 to just 36 in 2023.

Parallel betting is one well-known but illicit activity of junket operators in Macau.

Under this system, players can bet a given amount in Macau’s casinos, with the understanding that all bets are in fact of a higher value – for example by multiplying each bet by a factor of 10, or by placing bets in Hong Kong dollars with the understanding that the “real” bet value is in US dollars.

That way, customers can place a bet of $1,000 in the casino, with an understanding between the player and junket operator that the actual bet is worth $10,000, with any wins or losses to be settled between player and junket accordingly.

The practice is illegal but thought to be commonplace among junket operators, as a way of working around strict limits on the amount of currency customers can bring from the Chinese mainland into Macau.

Parallel betting results in less revenue being collected by casino operators, and therefore less tax being paid to Macau’s government.

The new legislative bill therefore proposes to explicitly define and outlaw the practice.

Kindred Group has published a summary of its responses to the UK government’s public consultations on its review of the 2005 Gambling Act.

After publishing its white paper on the review earlier this year, the government and Gambling Commission (UKGC) invited stakeholders across the sector to provide responses to the new policy proposals.

In an article published today (1 November), Kindred head of corporate affairs Tom Banks set out the operator’s response to several of the review’s key topics.

Financial risk checks

Among the most controversial government proposals set out in the white paper was the introduction of financial risk or vulnerability checks, designed to prevent customers from gambling with more than they can afford.

Kindred said it was supportive of the proposal generally, but “only where a truly frictionless check was possible in reality, piloted by operators and tested extensively before rolling out via a licence requirement.”

The operator fully believes in using technology to keep players safe, it added, and believes the introduction of financial risk checks is a natural progression from the framework it currently has in place across its UK business.

“However, we believe further work is needed on the nature of the frictionless check itself, so we supported the testing of the check before implementation as a licence requirement,” it said. 

“A pilot of this technology is critical to its future success – operators have the experience and systems in place to understand whether it will work in reality, and crucially if it meets the government’s ambition as genuinely targeted and frictionless for players.”

Kindred suggested the checks should be technologically driven and therefore “strongly disagreed” with a proposal for operators to manually review all checks, as this would be “impractical and unreasonable.”

Further, the operator disagreed with proposals requiring operators to acquire postcode and job title data from customers, which it suggested is “not helpful when assessing affordability” and would add unnecessary friction to the customer journey.

Direct marketing opt-in

Another proposal put forward in the white paper would require operators to obtain all customers’ consent in order to share direct marketing and promotional offers with them.

Again, Kindred expressed its support for the proposal in general but with some caveats.

The operator supports the introduction of a ‘by channel’ opt-in system where customers can choose through which communication channels they wish to receive direct marketing.

However, it said, the company strongly disagreed with a requirement which would oblige operators to seek ‘re-approval’ from those customers already opted in to direct marketing.

“Our current customers have already consented to receiving marketing communications across channels and for specific products – under law that is applicable at the time they gave consent – and should therefore not be in scope for this proposal,” it said.

Rather, a requirement for the operator to opt-out all of its existing customers and asking them to opt back in “would be going above and beyond the scope of the white paper,” it said.

“If any new requirement stops us from being able to contact these customers overnight, we will have a significant impact on our ability to communicate with them going forward (despite them having previously consented to receive communications from us) and it may impact the more sporadic and infrequent customers,” it concluded.

Online slot stake limits

The government also asked for feedback on its proposal to introduce stake limits to online slots of between £2 and £15, with the possibility of introducing a lower limit for customers aged under 25.

“We were supportive in principle of the overarching ambition to ensure online slots are safe – and made the point that on our platforms, we already integrate measures such as lower limits for 18-24 year olds and lower affordability players on a dynamic basis,” Kindred said in response.

However, it added that it believes stake limits should be based on risk and not “blanket numbers,” as any limit agreed upon will not be followed by operators in the unlicensed market.

“This impact is acknowledged in the white paper, but further consideration should be given to the knock-on effect of a slot limit that is too low in relation to player shifts to the unregulated market,” it concluded.

Consultations on the above matters have now closed, and stakeholders across the industry await feedback on their responses from the UKGC and government.