The UKGC's First White Paper Consultation: OpenBet and Neccton's View

After years of preparation – and speculation – the United Kingdom Gambling Commission (UKGC) finally released its White Paper in July 2023 and then opened the formal consultation period. Even several weeks before the close of the first consultation period, the UKGC reported it had received over 1,800 submissions, and there were surely many more submitted during the final weeks. OpenBet and Neccton are proud to be among the many respondents to the consultation.

In the quest for improved player protection, it is critical that the UKGC consider currently available research and data around markers of harm in player behaviour. With the growing amount of data available due to the rise of online gambling, the industry has more information than ever to analyse to better identify what behaviours are markers of harm – and how to properly intervene to protect players. While the UKGC has focused on financial vulnerability and affordability checks, we have urged the regulator to consider other academically sound methods that will be more effective in promoting safe gaming and a thriving industry.

Using the Data We Already Have To Protect Players

Academic studies show that there must be a holistic view of the player’s activity to identify harmful patterns. For example, problem gamblers are more likely to lose more money per gambling day, lose more money per session, and deposit money more frequently per session, along with also depleting their accounts more often.

Here, the combined view of the player’s activity can give a more accurate view of whether a player is experiencing gambling harm without needing to go through a cumbersome, invasive, and time-consuming financial vulnerability check. Technology, such as Neccton’s Mentor platform, is a real-time player tracking tool that uses machine learning to analyse player behaviour and identify problematic play before it escalates.

The analysis of gambling behaviour can more quickly identify players experiencing harm and allow for a more effective and timely intervention. Such intervention can be based on data readily available to operators using the right technology and tools. This avoids the delay and intrusion on a player’s personal information created by the financial vulnerability check.

Establishing Healthy Habits for Players

There are many steps that can be – and should be – taken to encourage players to have healthy habits when using gambling entertainment. Some online gambling companies have introduced responsible gambling tools such as targeted personalised messages as a way of helping players stay in control, but there are many nuanced and proven tools available. It is essential that industry and regulators look to proven solutions backed by data and research.

One study evaluated the effectiveness of targeted messages among online gamblers who played at a selection of sites from July 2019 to January 2020. The results showed that online gamblers receiving personalised feedback (i.e., text messages concerning their own actual gambling behaviour) wagered significantly less money on both the day they read the message and seven days after. The data support the results found by previous laboratory and real-world studies showing that targeted personalised information can be an effective tool for online gambling companies to reduce gambling expenditure among their clientele.

Similarly, cool-off periods have proven to be a highly effective tool in regulating player behaviour. One study showed that gamblers who were treated with longer mandatory breaks (i) tended to take longer voluntary breaks, and (ii) interacted more frequently with the tool (for instance, by clicking the ‘logout’ button). In fact, players who take their cool-off periods often become more sustainable, long-term players than those who might burn out within weeks or days of establishing a gaming account.

Operators should utilise tools such as notifications, messages, RG-trained customer service calls, wagering/deposit limits, and cool-off periods that allow players to review their play/spend over their history of using the system – all of which can help players make informed decisions about their engagement with a gambling platform.

Further, doing this has the benefit of keeping the consumer engaged with a platform/operator who is regulated by the UKGC and will have the player’s interests in mind. Shutting players out of their accounts indefinitely while a financial review is undertaken could result in the player simply moving to a less scrupulous (including illegal) operator, who will not ensure that player protection is prioritised.


For decades, the UK has been a standard bearer for the gambling industry around the world. The White Paper consultation process will be ongoing for many months as we all work together to create a sustainable gambling industry, and we look forward to continued participation in this vital process.


Auer & Griffiths, Using Artificial Intelligence Algorithms to Predict Self-Reported Problem Gambling with Account-Based Player Data in an Online Casino Setting, J. Gambling Stud., 19 July 2022.

Auer & Griffiths, The Use of Personalized Messages on Wagering Behavior of Swedish Online Gamblers: An Empirical Study, Computers in Human Behavior, Sept. 2020; see also Auer, Hopfgartner & Griffiths, The Effect of Loss-Limit Reminders on Gambling Behavior: A Real-World Study of Norwegian Gamblers, J. Behav. Addict., 12 Nov. 2018.

Hopfgartner, Auer, et al., Cooling Off and the Effects of Mandatory Breaks in Online Gambling: A Large-Scale Real-World Study, Int’l J. of Mental Health & Addict., 17 Jan. 2023.

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