• Kishan Patel

Design of gambling products

Updated: Dec 11, 2021

Online gambling has surged over the past decade. With reduced costs and increased accessibility, online gambling is highly profitable to the industry and is unsettlingly addictive for players. Most online games facilitate cognitive biases through the illusion of control and often contain characteristics that particularly appeal to younger customers. The industry has repeatedly resisted reform and suggested that product design has little influence on harm but somewhat down to the individual, despite clear evidence suggesting otherwise.


The Gambling Industry has grown over the past decade, primarily due to the upsurge of online gambling.

Online gambling products are subject to:

  • reduced costs,

  • increased accessibility,

  • improved advertisement effectiveness,

  • increased vulnerability to cognitive biases,

  • and increased potential for neurostimulation.

Electronic gaming machines and online casino products have been repeatedly associated with unsettlingly high gambling addiction levels among players. These products have structural characteristics that affect human decision-making and behaviours, and therefore addiction potential, such as:

  • free bet offers,

  • high event frequencies,

  • random ratio reinforcement schedules,

  • near misses,

  • losses appearing as wins,

  • multiline betting, and

  • exaggerated audible and visual reinforcements 101

In the UK, fixed-odd betting terminals (FOBTs), a type of electronic gaming machine, quickly proliferated in clusters before drawing attention and campaigns for change due to their addictive potential. Recently, the maximum individual stake allowed for FOBTs was reduced from £100 to £2. However, this change took several years to be enacted with resistance from the government, primarily due to the sector's concerns regarding job losses. The estimated job losses resulting from reducing the maximum stake were greatly overstated, as, before the regulation change, physical betting shops were already in decline due to the ongoing increase in online operations.

Though similar in style and addictiveness to FOBT's, operators and legislation have not attempted to alter the wagering limits of online fixed-odds betting. Early evidence on live in-play sport-betting and cash-out features are also hypothesised to contain structural characteristics that facilitate cognitive biases through illusions of control to consumers. Gambling products are also designed to maximise appeal among possible customers. Notably, a significant number of online slot games are expected to appeal to younger customers who have some familiarity with particular names, characters, animations, or other graphics. Furthermore, these products often contain animated characters, which are expected to disproportionately attract younger customers and propagate cognitive biases around the level of risk involved. The same issues are also expected to be suffered in fantasy-team styled products, which essentially involve adapting popular sport fan games into gambling games. One example of this, the Football Index, which contains structural characteristics that lead towards cognitive biases and appeal to young people, worryingly has been allowed to operate with a license under a fraudulent business model.

Newly introduced changes to online slot games include rules on the speed of play and near misses; and are due to be implemented in November 2021. Characteristically and despite clear evidence, the industry has previously denied any association of gambling-harm and the type of gambling product. Characteristically, the industry has instead sought to deflect blame on to the individuals who suffer harm until changes are mandated by regulation.

What is known?

Gross gambling yield of remote betting, bingo, and casino 102

  • 2013: £0.9bn

  • 2014: £1.1bn

  • 2015: £2.2bn (remote operators required to register for a GB license)

  • 2016: £4.2bn

  • 2017: £4.8bn

  • 2018: £5.3bn

  • 2019: £5.7bn

Football Index (Great Britain Gambling Commission license: 09/09/15 – 11/03/21) 103

  • 09th September 2015: License approved

  • 2nd October 2015: Launched

  • January 2018: 100k users

  • July 2018: Shirt sponsor for Bristol Rovers announced 104

  • June 2019: Shirt sponsor for Nottingham Forest announced 105

  • Late 2019: 500k users

  • January 2020: Gambling Commission warned “an exceptionally dangerous pyramid scheme under the guise of a ‘football stock market’” 106

  • August 2020: Shirt sponsor for QPR 107

  • 11th March 2021: Administration and license suspended

Appeal to children

  • A non-exhaustive list of examples of gambling products that utilise cartoon animals, fairy tales, colourful exaggerated graphics, and names, that may appeal particularly to children and young people

  • Adventure Trail

  • Age of the Gods

  • Age of Dragons

  • Aquaman

  • Batman The Riddle Riches

  • Berry Berry Bonanza

  • Captain’s Treasure

  • Djinn of Storms

  • Dragon Champions

  • Dragon Spark

  • Dynamite Digger

  • Fluffy Favourites

  • Halloween Fortune

  • Hansel and Gretel

  • Jack and the Beanstalk

  • Justice League

  • Kings Court

  • Lara Croft Temples and Tombs

  • Loco the Monkey

  • Mad Max Fury Road

  • Monopoly

  • Norse Book of Dwarves

  • Norse Gods and Giants

  • Piggy Payout

  • Pirate Princess

  • Prince of Olympus

  • Rainbow Rewa

  • Rainbow Riches

  • Reacttoonz 2

  • Red Riding Hood

  • Rick and Morty

  • Sahara Riches Cash Collect

  • Sinbad

  • Spartacus Super Colossal Reel

  • Terminator

  • The Goonies

  • The Mask of Zorro

  • The Nutcracker

  • Transformers

  • Voyage of Adventure

  • War of Gods

Proportion of individuals who gambled in the past year with gambling disorder per type of activity


BGPS 1999 %


​BGPS 2007 %


​BGPS 2010 %


​BGPS 2010 %

[at least monthly gambling] (DSM-IV)

Health Survey 2016 %


National Lottery Draw






Any other Lottery












Football pools












Slot machines





Online slot machine style games / instant wins




Horse races






Dog races






Events [other than horse or dog races] with a bookmaker




Sports betting




Betting on non-sports events



Fixed Odds Betting Terminals





Betting exchange



Spread betting





Table continued...

Table games in a casino






Private betting






Fruit machines


Poker at a pub/club





In Store: Sweden 2015% (PGSI)

In Store: Sweden 2018 % (PGSI)

Online: Sweden 2015% (PGSI)

Online: Sweden 2018% (PGSI)











Sports betting










Slot machine / casino games










Timeline of Fixed Odds Betting Terminals 111

  • 2001 - Fixed Odds Betting Terminals (FOBTs) introduced

  • 2005 - approximately 20,000 FOBTs 112

  • 2007 - approximately 30,000 FOBTs 112

  • 2016 - The APPG on FOBTs recommends a reduction to £2 spin

  • 2017 - Treasury ignores Gambling Commission advice that FOBTs are high-risk

  • 2018 - DCMS recommends £2 maximum

  • 2019 – 32,810 FOBTs 102

  • 2019 - the maximum bet on FOBTs was changed from £100 to £2

What the industry said?

Neil Goulden, Chair of the Association of British Bookmakers 113

"There is very clear evidence that problem gambling is about the individual and not any specific gambling product or products.

“Altering stakes and prizes is not an effective form of player protection, nor does it balance the constant regulatory dilemma of allowing the vast majority of our eight million customers to enjoy their leisure time as they see fit, whilst protecting the small minority who do develop problems with their gambling.

“At the same time, the ABB recognises the need for effective consumer protection and we will be introducing a ‘Code of Responsible Gambling in LBOs’, which will build on current best practice and give consumers the self-help tools they need to avoid excessive or irresponsible gambling.

“In doing so, the ABB is putting consumer and player protection at the core of responsible gambling in the UK.”

Goulden purports evidence that is distinctly against a consistent global evidence base which has repeatedly demonstrated that some gambling products are more addictive and harmful than others. Notably, Goulden shifts the responsibility from the industry who benefits from addiction to the individual who suffers from it.

Michael Dugher, Member of Parliament for Barnsley East 114

“More gamblers have problems with scratchcards and slot machines than FOBTs. The review must be widened. And they have to stop beating up on high street betting shops.”

While still an MP and three years before taking the CEO role for the industry lobbying group the BGC, Michael Dugher opposed a government crackdown on FOBTs, citing a couple of different reasons. First, Dugher states that individuals with gambling disorder played the national lottery more than FOBTs. Although the national lottery is vastly more popular as a product, this sentence is worryingly misleading as FOBTs have significantly higher addiction rates than the national lottery.

Secondly, Dugher said such action would harm jobs in high street betting shops. Both excuses fail to tackle the issue of gambling harm caused by FOBTs. Such statements are designed to derail the conversation by deflecting other issues while providing zero solutions.

Betting and Gaming Council 72

“The BGC are already working with the Gambling Commission on new affordability checks and a new code of conduct for game design, including slowing spin speeds on games and removing some in game features.”

The BGC in working with the Gambling Commission, admit that they have responsibility and control over harmful gambling. In this statement, the BGC also acknowledges the need for reform in affordability checks and the structural characteristics of products such as game features and speed of play.

The Gambling Commission 115

“Proposals around the design of slots games are just the first step in keeping players safe. Slots is an area which has seen technological innovation in terms of product design and we expect operators to continually show an equal, and indeed greater, commitment to innovate in terms of consumer protection.

Regulatory intervention needs to keep pace with this and the proposals in this consultation form part of a comprehensive package of work we are taking forward to make online gambling safer”

Gambling Commission suggests that efforts on online slot game design are just a first step in keeping players safe.

Research since 2010 has reflected that online slot games have among the highest rates of addiction by activity, suggesting a significant delay between evidence and action.

Brigid Simmonds, Chair of the Betting and Gaming Council 116

"I am pleased with our members' hard work and continued commitment to delivering substantial progress on the three safer gambling challenges set by the Gambling Commission on high value customers, advertising and game design.

The progress reported today including restricting under 25's from qualifying for high value customer accounts; strengthened advertising rules and games with slower speeds and the removal of some functionality comes despite difficult operating circumstances during the COVID-19 crisis.

These measures, along with our recently announced 10 pledge action plan for COVID-19 safer gambling and our 22 industry safer gambling commitments will significantly transform and improve the environment for our customers and the wider public.

We agree with the Gambling Commission that there is still more work to do and we will rise to the ongoing challenge."

Following pressure from campaigners and the Gambling Commission, Simmonds acknowledges significant issues with industry practices surrounding high-value customers, advertising, and game design. Simmonds then vaguely comments on the industry's progress and commitments and again acknowledges the need to transform industry practices.


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