Assessment of the proposal against the Standing Order criteria
40. Our predecessor committee, the Deregulation Committee,
examined no fewer than eight deregulation orders amending various
aspects of the 1968 Act. In its report on the proposal for the
last of these, the Deregulation (Bingo and Other Gaming) Order
2001, published in May 2001, it noted its concern that the regulatory
reform procedure was being used to make piecemeal changes to the
Act, adding complexity to the statute book.
That Committee noted the issue in March 2001 of the Home Office
consultation document on this very proposal, which it believed
was likely to "arouse some dissent".
It recommended that its successor committees should pay particular
attention to the possibility that the cumulative effect of further
amendments to the law by regulatory reform order might represent
a "'substantial' or 'manifestly controversial'" change
to the law which might be more suitable for primary legislation.
41. In view of the concerns expressed by our predecessors,
we have examined whether the proposal is indeed appropriate for
the regulatory reform procedure. In our view, the present proposal
does not purport to make a substantial or controversial change
to the 1968 Act of a kind which might be better proceeded with
by means of a bill. We believe that the proposal appears appropriate
for delegated legislation.
Removal or reduction of
42. The Department believes that the present legislation
imposes "outdated requirements which add unnecessarily to
costs and prevent the flexible use of modern technology"
by gaming machine operators and suppliers.
It indicates that the proposal would remove three burdens imposed
on gaming machine operators by the 1968 Act:
a) a requirement that jackpot and higher-value AWP
machines shall be operated solely by coins
b) a requirement that jackpot and higher-value AWP
machines must be able to accept payment for a single game,
c) a restriction preventing jackpot machines retaining
a player's winnings in the machine for future play.
43. Our analysis of each of these burdens is set
out below, first in respect of jackpot machines and then in respect
of higher-value AWP machines. The Government does not intend to
amend the law in respect of lower-value AWP machines.
Burden (a): methods of
payment into and out of gaming machines
44. The effect of the 1968 Act is to designate coins
as the only means of payment into, and out of, jackpot machines
and higher-value AWP machines.
Section 26(1)(b) of the 1968 Act requires all gaming machines
to have "a slot or aperture for the insertion of money or
money's worth in the form of cash or tokens."
The proposal would amend this provision by removing the requirement
for jackpot and higher-value AWP machines to have a slot to accept
coins or tokens.
45. In respect of jackpot machines, the Department
believes that the 1968 Act imposes a burden on operators by requiring
such machines to operate solely by means of coins. Section 31(3)
of the 1968 Act provides that coins alone may be inserted into
a jackpot machine in order to play a game on the machine. Sections
31(4) and 31(5) provide that the only prize which may be delivered
by the machine shall be in the form of a coin or coins.
46. The proposal would remove the requirement that
jackpot machines can accept payment, and pay out prizes, only
by means of coins, by :
- removing the overall requirement in section 26(1)(b)
of the Act that gaming machines must have a slot for the insertion
- amending section 31(3) so as not to specify that
payment into the machine must be in coins, and
- removing the requirements in section 31(4) and
(5) that prizes must be delivered by means of coins.
47. The proposal would instead enable such machines
to accept payment for games by means of banknotes in addition
to coins, as well as by other "non-cash media" such
as a smartcard (referred to in the draft order as "an object
capable of being inserted into the machine to pay for a game or
games"). It would also enable machines to pay out money prizes
in a variety of means other than by coins, that is, by banknote,
by cheque, by a credit to a smartcard, or by a credit note or
token or other means.
48. Although the consultation paper specified the
forms in which payment of winnings from a jackpot machine might
be made, namely "banknotes, smartcard credits, a cheque or
a credit note or token redeemable in full by the operator",
the proposal does not prescribe the specific forms of non-cash
payment which may be made into or out of a jackpot machine. The
Department argues that "exhaustively specifying" such
forms of payment may inadvertently exclude an acceptable means
of payment or may "unnecessarily constrain" future technical
49. The Department's identification of the burden
imposed by the current legislative requirements, and the means
it proposes for removing it, both appear to be sound. We conclude
that the removal of the requirement that jackpot machines must
receive payment in coin, and pay out winnings in coin, constitutes
the reduction of a burden on the operators and the players of
50. In respect of higher-value AWP machines,
the Department argues that the burden is contained in section
34(5B) of the 1968 Act, which provides that the maximum charge
for play on a higher-value AWP machine shall be the same as that
on a lower-value AWP machine. Section 34(2) of the 1968 Act provides
that the maximum charge for one game on a lower-value AWP machine
shall be "one or more coins or tokens inserted into the machine
of an amount or value not exceeding . . . 30p."
51. The 1968 Act does not specifically rule out payment
of winnings from higher-value AWP machines in means other than
coins, although the wording of section 34(5C) prevents the payment
of winnings in tokens. However, the Department believes that if
the machine may receive coins alone as payment for play, then
in practice it will pay out prizes only in coins.
52. The Department considers that the proposal would
remove a burden by enabling higher-value AWP machines to accept
payment by banknotes in addition to coins. The proposal would
not enable the payment of prizes in any medium other than cash.
Such machines would therefore not be able to accept payment via
smartcards or pay out prizes by cheque, smartcard credit, credit
note or token.
53. We have identified a drafting issue in relation
to the way in which the proposal purports to lift this burden.
The proposal is intended to allow higher-value AWP machines to
accept banknotes in addition to coins, but not to accept smartcards.
However, it appears that the proposal, if made, would not have
this precise effect, and could in fact allow smartcards and even
credit cards to be inserted into the machine as payment. This
issue is addressed at greater length at paragraphs 156 to 160
54. We nevertheless conclude that the Department's
identification of the burden in current legislation appears to
be sound. Subject to a satisfactory resolution of the drafting
issue which we discuss below, we conclude that the removal of
the requirement that higher-value AWP machines must receive payment
in coins, and pay out winnings in coins, constitutes the removal
of a burden on the operators and the players of such machines.
Burden (b): accepting payment
for a single play
55. The effect of section 31(3) of the 1968 Act,
in relation to jackpot machines, and sections 34(5B) and 34(2)
of the Act, in relation to higher-value AWP machines, is to require
that such machines must be able to accept a coin or coins up to
the value required for a single play.
At present the maximum payment for a single play of a jackpot
machine is 50p, while the corresponding maximum for a higher-value
AWP machine is 30p.
56. The Department has not explicitly set out why
it believes that this legislative provision constitutes a burden
on operators or players of jackpot and higher-value AWP machines,
although it does state in passing that it believes the relaxation
of the burden will benefit the industry financially.
The March 2001 consultation document stated that "requiring
machines which accept smartcards and banknotes to provide for
players to insert sums of 30p or 50p in coin would be redundant
and needlessly expensive for manufacturers and operators."
This appears sufficient to demonstrate that sections 31(3), 34(2)
and 34(5B) of the 1968 Act impose a burden on operators and players
of both types of machine.
57. The proposal would remove this burden by removing
the requirement that all gaming machines falling within the scope
of Part III of the 1968 Act must have a slot or aperture to accept
coins or tokens. One effect of the removal of this requirement
is that operators will be able to operate jackpot machines which
may accept banknotes and smartcards only, and higher-value AWP
machines which may accept banknotes only.
58. We considered a further issue in this respect.
The initial consultation document proposed that Gaming Board guidelines
should retain the requirement that jackpot and higher-value AWP
machines which were to be operated by coins only should continue
to be able to accept payment for a single play.
The Government now considers that it would not be appropriate
for the Gaming Board to reinstate in its guidelines the effect
of a legislative provision which Parliament would have removed
by means of this order, and that in any case "it would not
serve much purpose for the Board to do so." The Department's
change of heart is discussed further at paragraphs 99 to 104 below
in relation to necessary protections, and in paragraphs 145 and
146 below in relation to consultation.
59. It appears to us that the Department's identification
of the burden and the means whereby it is to be removed is sound.
We conclude that the removal of the requirement that jackpot
machines and higher-value AWP machines must be able to accept
separate payment for a single play constitutes the removal of
a burden on gaming machine operators.
Burden (c): retention of
winnings in gaming machines
60. The wording of sections 31(4), 31(5) and 34(3),
and 34 (5C) in the 1968 Act means that prizes won in one session
of play on a gaming machine must be paid out at the end of that
session, and cannot be retained in the machine for future play.
The proposal would amend the law in respect of jackpot machines
to enable players to retain their winnings in the machine after
a session of play.
61. The Department did not set out in the explanatory
statement, nor in the consultation document, why it believed the
present requirement constituted a burden, and on whom the burden
fell, although it indicated in passing that it believed the removal
of the requirement would benefit the industry financially.
62. Consequently we asked the Department to specify
the nature of the burden it considered was imposed by the present
requirement that prizes won in one session of play on a gaming
machine must be paid out at the end of that session, on whom it
considered the burden fell, and how the proposal would reduce
or remove the burden.
63. The Department has indicated that the burden
falls on persons potentially liable for prosecution if they operate
gaming machines in a manner which is not compliant with the existing
law (for example, operating machines which retain winnings for
future play). This requirement on operators constitutes a burden
as set out in the Regulatory Reform Act.
64. The Department has also explained the practical
effect of the burden imposed by the law: it results in additional
wear and tear on a gaming machine's coin-handling mechanisms,
and requires players who wish to replay their winnings to reinsert
the coins they have won.
65. We conclude that the Department has satisfactorily
demonstrated that the proposal would remove a burden by removing
the requirement that gaming machines must pay out their winnings
rather than carrying them over for further play.
New burdens to be imposed
by the proposal
66. The Department indicates that the proposal will
create one new burden, which will fall on operators of jackpot
machines. It intends to require operators of jackpot machines
which pay out through non-cash media (that is, smartcards, tokens
or other as yet unspecified means) to redeem these for cash or
cheque (or a combination of the two) on demand on the premises
where the machine is used.
The Department believes that this will safeguard payments to customers
by ensuring that "players are readily able to ascertain the
amount of any winnings in media other than coin and to claim it
in cash or cheque on demand at the premises where they have won
it." The Department considers that this requirement would
also result in practical benefits to players, who would be able
to receive potentially large money wins in non-coin form.
67. We note that the Government does not at present
propose to make it a specific offence for an operator to refuse
to honour a legitimate smartcard credit. The Department argues
that this is because gambling debts are unenforceable in law (a
provision of the Gaming Act 1845). It indicates that reform of
this aspect of gaming law is beyond the scope of the present order,
although it is likely to be reformed via the forthcoming Gambling
Bill. This point is dealt with in greater detail in the context
of necessary protections at paragraphs 92 to 98 below.
Requirements to be imposed by non-statutory means
68. The Department envisages that the operation of
the new machine and smartcard systems will require further customer
safeguards. It proposes that these safeguards should be provided
by the means of Gaming Board guidelines for the suppliers and
distributors of gaming machines. Such guidelines would be non-statutory
and non-binding, although the Government argues that they can
be effectively enforced by the Gaming Board, which issues certificates
of fitness to gaming machine suppliers (but not to operators).
Without such a certificate a gaming machine supplier cannot lawfully
69. The proposed guidelines which the Board intends
to operate in respect of the new machine and smartcard systems
are set out at annex A to the explanatory statement. The Department
considers that these guidelines will impose further requirements
on the suppliers of new machines, in that they will make detailed
rules about the operation of such machines. The Department describes
these new requirements as new burdens. However, they are not to
be imposed by means of the order, and do not depend on legislation.
They are discussed in greater detail in the context of necessary
protections at paragraphs 106 to 133 below.
New burden: proportionality
70. Section 1(1)(c) of the Regulatory Reform Act
provides that a regulatory reform order may impose a new burden,
but that that burden must be proportionate to the benefit which
is expected to result from its creation. The Department argues
that the new requirement which is to be imposed by the proposal
provides a necessary safeguard for users of gaming machines.
71. We were not satisfied with the Department's assessment
in the explanatory statement of how the draft order met the proportionality
test. The Government's assessment of the test related to the entirety
of the new burdens which it proposes should be imposed, by means
of non-statutory guidelines issued by the Gaming Board as well
as by means of the draft order. We therefore asked the Department
to provide an assessment of how the new burden to be included
in the draft order would meet the proportionality test without
reference to the Gaming Board guidelines.
72. In response, the Department identified the benefit
which would arise from the new burden to be imposed by the draft
order, namely that a player using a smartcard or other non-cash
means to play a jackpot machine would be able to recover any money
won or any credit stored on a smartcard. It also considered that
the benefit which the proposal would bestow on the operator from
being able to run jackpot machines which use smartcards would
be proportionate to the new burden to be imposed on the operator.
73. We are satisfied that the Department has demonstrated
that the new burden is proportionate to the benefit which is expected
to result from its creation.
New burden: fair balance
74. Section 3(2) of the Regulatory Reform Act provides
that a proposal may create a new burden only if:
- the provisions of the order, taken as a whole,
strike a fair balance between the public interest and the interests
of the persons affected by the burden being created (section 3(2)(a)),
- the extent to which the order would also remove
or reduce other burdens, or have other beneficial effects for
those affected by current burdens, makes the order desirable (section
75. The fair balance and desirability tests are relevant
here because the proposal would create a new burden.
Section 3(2)(a): fair balance
76. The Department argues that the removal of the
burdens it has identified would have important financial benefits
for the gaming machine industry. To recap, these burdens are:
a) the restriction on methods of payment,
b) the requirement to accept payment for a single
c) the prohibition on retention of winnings in a
77. The Department has set out how it believes the
proposal meets the fair balance test.
Those affected by the new burden would be machine operators and
players. Machine operators, it argues, are prepared to support
a change in the law, as the new burden would arise from the wider
freedom they would have to configure their machines in a more
efficient way. Players would be placed in an advantageous position
by the new burden since they would in practice be able to secure
payment of any non-cash winnings on demand.
78. The Department also considers that the public
interest would be served, as far as operators and players of machines
are concerned, by an increase in the efficiency of operation of
gaming machines. The public interest would additionally be served
by the inclusion in the proposal of protections intended to ensure
that machines are operated in ways which do not risk encouraging
players to use them excessively. It therefore believes that the
provisions of the draft order strike a fair balance between the
public interest and the interests of persons affected by the burden
79. The protections against excessive use contained
in the proposal are material to the Department's assessment of
how the draft order meets the fair balance test. However, they
are not contained in the draft order, but in the accompanying
Gaming Board guidelines. We have considered whether the operation
of the proposed Gaming Board guidelines will sufficiently maintain
necessary protections. Our specific findings in relation to necessary
protections are set out at greater length below.
80. We conclude that the proposal strikes a fair
balance between the public interest and the interests of the operators
and players of gaming machines.
Section 3(2)(b): desirability
81. The Department indicates that the Government
believes the proposal is desirable because it would offer estimated
benefits to the gaming machine industry of £1.85 million
a year. The Department believes that the proposal would also offer
"some benefits" to players, but it does not set out
what they are in the body of the explanatory statement. The Regulatory
Impact Assessment attached to the explanatory statement states
that the anticipated benefits to players are as follows:
. . . more choice in methods of playing machines
and [the receipt of] prizes in a more convenient form. [Players]
would also benefit from fewer machines down time and fewer disputes
if the machine does not pay out properly.
82. Although the Government has not stated here that
the proposal also removes one or more burdens, we are satisfied
that the draft order would do so. We therefore conclude that
the extent to which the order removes or reduces one or more burdens,
or has other beneficial effects for persons affected by the existing
law, makes it desirable for the order to be made.
Continuing necessary protections
83. The Department did not initially set out its
view of whether the existing law affected by the proposal afforded
any necessary protection and, if so, how that protection was to
be continued. This gave us no firm basis for assessing the extent
to which the protections in the proposal and in the proposed Gaming
Board guidelines continue any necessary protections. We therefore
asked the Department to list the protections which it considered
were contained both in present legislation and in current Gaming
Board guidelines on the operation of gaming machines, to indicate
the extent to which it considered these protections would be continued
by means of the order and the proposed new guidelines; and to
indicate, in respect of any protections which are not to be continued,
whether it considered they were necessary.
84. In its response the Department set out the three
protections which it believed were contained in the present legislation,
a) The fact that players must pay for games in coin.
As the highest-value coin in circulation at present is £2,
this in effect means that players must make a separate decision
to commit each sum of up to £2 to play.
b) The fact that players of jackpot machines are
paid out in cash when they win.
c) The requirement that machines must be able to
accept payment for a single play. The provisions of the 1968 Act
relating to jackpot machines and higher-value AWP machines both
require that "the charge for play for playing a game once
by means of the machine shall be a coin or coins of an amount
not exceeding [value]".
Protection (a): payment for games in coin
85. The present requirements in the 1968 Act are
that jackpot and higher-value AWP machines may accept only coins
in payment, and may pay out only by means of coins. Whether or
not these provisions were intended as protections when the legislation
was first enacted, they appear now to operate as forms of protection
for the users of such machines.
86. The requirement in sections 26(1)(b), 31(3),
(4) and (5) and 34(5D) of the 1968 Act that payments into the
machine may be made only by means of coins prevents users of gaming
machines from committing more than the maximum value of a single
coin (at present £2) to play at any one time, and therefore
provides a protection against committing larger sums of money
to play in a single action. A separate action is required to insert
each coin, which gives the player opportunity for reflection.
We note that there is at present no legal limit to the number
of coins which may be inserted into the machine at any one time,
and there is no requirement for operators to pay out unused coins.
87. The Government proposes to continue protection
(a)which has the effect of setting the maximum payment
into a machine at £2by means of Gaming Board guidelines,
which will require machines accepting banknotes or smartcards
to be programmed so that players must make a fresh decision to
commit each separate tranche of £2 or less from their smartcard,
inserted banknote or winnings to play the machine.
88. This protection will not be continued in legislation,
but the Department considers that this provision is "entirely
equivalent to what currently exists" in legislation. The
existing law does not define £2 as the maximum payment which
may be inserted into a machine in order to play. The Department
nevertheless believes it appropriate that there should be an upper
limit equivalent to the highest value coin in regular circulation.
One consultation response called for a £5 upper limit (equivalent
to the lowest-value banknote in general circulation), a suggestion
the Department rejected.
89. We agree that, wherever a player is able to insert
large sums of money into a gaming machine, there ought to be an
upper limit on the amount the player is able to commit to play
at any one time. We believe that this upper limit ought to
be equivalent to the highest-value coin in general circulation
(at present £2), and that in principle the limit ought to
be expressed thus in Gaming Board guidelines.
90. We have considered whether provision for this
necessary protection ought in fact to be included on the face
of the draft order, rather than in Gaming Board guidelines. We
have concluded below that the Gaming Board will be effective in
the administration and enforcement of the guidelines which will
accompany the draft order. We are therefore prepared to allow
the Department the flexibility to make provision for this form
of protection by means of guidelines, and believe that the limit
should be expressed as proposed above.
91. We are content that this necessary protection
should be continued by non-statutory means.
Protection (b): immediate payment in cash
92. At present the player of a jackpot machine is
in effect guaranteed to receive all winnings in cash, because
of the requirement that such a machine may pay out only in coins.
Although there is no specific requirement for a higher-value AWP
machine to pay out winnings in coins, the Department argues that
in effect they do so, as they may at present accept only coins.
Thus for both types of machine the player is in theory guaranteed
an immediate payout of winnings, as the present legislation does
not allow winnings to be carried over for further play. The Department
has, however, noted that while the 1968 Act defines the maximum
prizes which gaming machines may pay out, it does not require
operators to pay them.
93. This protection is to be continued in respect
of non-cash media by means of the new burden in the draft order:
that is, the requirement that operators running jackpot machines
which pay out in non-cash media should pay out the full value
of a player's winnings on demand by cheque, cash or a combination
of the two at the premises where the machines are used for gaming.
The consultation document indicated that the Government did not
propose to make it a specific offence for an operator to refuse
to honour a legitimate smartcard credit, but that "a consistent
pattern of improper refusal to settle smartcard credits would
plainly have an impact on the operator's market."
94. We have considered whether the requirement for
operators of jackpot machines to pay out winnings in full by cash
or cheque is an adequate continuance of the protection which the
operation of coin-only machines presently provides. In doing so,
we took into account the response to the consultation document
from Cardiff University Law School, which argued that the protection
which the proposal provided for the consumer in respect of smartcard
redemption was insufficient. A mere requirement on an operator
to pay out a smartcard credit would not be enforceable, as under
the Gaming Act 1845 gambling debts are not enforceable in law,
and the threat of market sanctions against an operator who failed
to pay out on a smartcard would depend very much on the operation
of the market in the operator's area. It believed that if operators
were to be given the commercial advantages of the use of smartcards,
their obligations to players should be set out in law.
95. In response the Department has argued that the
level of protection provided to players who win prizes which are
to be delivered from machines by non-cash payment methods is equivalent
to the protection presently afforded to players who win cash prizes:
"there is no significant difference so far as the player
is concerned between being paid out in cash directly by a machine
and being paid out by non-cash means which are redeemable on the
We note that in fact the level of protection is slightly increased,
since there is at present no explicit requirement on operators
to pay cash prizes (for example, in situations where a machine
does not have sufficient coins to pay out a prize).
96. It is intended that the forthcoming Gambling
Bill will repeal the provisions of the Gaming Act 1845, and will
establish a process whereby gambling debts are enforceable through
the civil courts. The Department conceded that it would be possible
to disapply the 1845 Act from gaming machine smartcard debts,
and to make it a criminal offence to refuse to pay out on a smartcard
credit. However, to include such provisions in the draft order
would be disproportionate in the overall context of the present
law on gambling, and would create a situation where relatively
small smartcard debts would be legally enforceable, while larger
debts in connection with betting or casinos would not be.
97. The Department has set out more fully why it
believes that the operators of jackpot machines would in any case
be unlikely to refuse to pay out on a legitimate smartcard credit.
Operators of casinos and bingo clubs need a magistrate's licence
to operate, and are subject to Gaming Board monitoring. Should
these operators refuse to pay out on smartcard credits won on
jackpot machines on their premises, the Department argues that
the Gaming Board would have to consider applying to the magistrates
for cancellation of their licence. Operators who run jackpot machines
in members' clubs need magistrates' permits to operate their jackpot
machines. The Department believes it improbable that they would
refuse to pay out on a gaming machine prize won by a member or
a guest, and that if this were the case members could have recourse
to a club's own procedures.
98. The present level of protection for players of
gaming machines is not perfect: there is no present requirement
in law on operators to pay out cash winnings from a machine. As
we note above, the level of protection provided for payment from
machines by non-cash means is in fact slightly higher than that
provided for in existing legislation. We are therefore satisfied
that a necessary protection is continued in this respect.
Protection (c): payment for a single play
99. Protection (c) is not to be continued. The Department
does not consider this protection to be a necessary one: "it
does not add to consumer safeguards to have law which requires
that players must always be able to insert, in effect, their loose
change into a gaming machine".
100. In removing the requirement that jackpot and
higher-value AWP machines should be able to accept payment for
a single play, the proposal would remove a form of protection
for users of these machines. At present, if they wish to, players
can limit the stake they commit to the machine to that required
for a single game. Under the proposal, machines which accepted
smartcards and/or banknotes would no longer be required to accept
the minimum stake: the proposed Gaming Board guidelines might
require players to commit as much as £2, unrefundable, to
a higher-value AWP machine which can charge no more than 30p for
a single play.
101. The Home Office, in its consultation document,
initially proposed to retain the protection in Gaming Board guidelines,
but in the explanatory statement the Department indicated that
it was not to be retained, as it was "redundant and needlessly
expensive" for machines which were designed to accept smartcards
and/or banknotes to have to accept payment for a single play.
When we asked why the requirement was to be dropped from Gaming
Board guidelines, the Department explained that on reflection
it was not considered "necessary or logical to require coin-only
machines to accept payment for a single play when machines taking
banknotes do not", and that the issue should be a commercial
matter for the industry to decide.
The proposal would also remove this requirement from machines
which could continue to accept coins. Operators will therefore
decide whether they wish to retain machines which can accept payment
for a single play in order to attract casual players.
102. GamCare (the National Association for Gambling
Care, Educational Resources and Training), in its response to
the consultation, stated that it believed the requirement to accept
payment for a single play was "an important safeguard, especially
for the occasional or casual player." It nevertheless understood
the reason for removing the requirement, and raised no objection
to it, on the understanding that relevant machines would display
clearly the minimum stake which had to be committed to play the
machine, together with the number of games which could be played
for that stake.
103. The Department's stated intention is that "the
player should always easily be able to know how much it will cost
to play on the machine."
The Gaming Board is not aware of any machine which does not show
the price of a game on its face, and the Department states that
it has never been necessary to set such a requirement. Once the
requirement that all machines should be able to accept payment
for a single play is removed, however, the amount which a player
will have to insert into a machine to play a game will in many
cases be more than the price of a single game. We consider that
if it is the Department's intention that the player should always
easily be able to know what it will cost to play on the machine,
it should take this issue into consideration. We nevertheless
agree with the Department in its overall assessment of the protection.
104. We agree with the Department that the present
protection in respect of accepting payment for a single play is
not a necessary one, and may be dispensed with.
105. We are therefore satisfied that the proposal
would continue all necessary protections.
Protections to be contained
in Gaming Board guidelines
106. Apart from the new protection to be included
in the draft order (discussed at paragraphs 93 to 98 above), all
other safeguards on the operation of the proposed new types of
machine are to be enshrined in proposed Gaming Board guidelines.
The Department believes that the guidelines are needed "to
ensure adequate safeguards for customers." 
It believes that it is more appropriate to include these safeguards
in guidelines, as they are easier to adapt to circumstances "in
the light of a rapidly-changing, high-tech industry."
107. A draft of the guidelines is available at annex
A to the explanatory statement. The Department states that this
draft is "broadly in its final form" but may be subject
to minor changes before coming into effect. The Department has
assured us that he guidelines will be in their final form when
the draft order is laid for final scrutiny.
They are to be issued under the authority of the Gaming Board,
which will discuss any amendments to them with the Department
before such amendments are issued.
108. The safeguards which the Department indicates
are to be implemented by means of Gaming Board guidelines will
- a specification of £20 as the maximum denomination
of banknote which may be used in a gaming machine
- a requirement that a player cannot transfer more
than £20 credit from a smartcard to a machine without having
to remove and reinsert the card
- a requirement that gaming machines using banknotes
or smartcards be programmed so as to require players to make a
fresh decision to commit a sum of up to £2 from their banknote,
smartcard or winnings credits to playing the machine, every time
the amount on the play meter falls below the minimum charge for
a single play
- a requirement that players who decide not to
commit a fresh sum of up to £2 to playing the machine are
subsequently able to retrieve all the money owed them by the machine,
with the proviso that the machine may be able to retain sums of
up to £1, which may be used for further play or (if insufficient
for a single play) retained for use by subsequent players
- a requirement that players with credit on the
play meter less than that required to play a single game are then
able to collect all money owed to them by the machine (subject
to retention in the machine of sums of up to £1).
109. The Department also indicates that the Gaming
Board's present guidelines for the operation of AWP machines prevent
players of machines being able to accumulate more than five times
the maximum prize from the machine. This restriction is to be
110. The guidelines which the Gaming Board presently
issues to the gaming industry are not subject to parliamentary
control, although amendments to them are discussed with the Department
before they are made. The proposed guidelines which are to be
issued with the draft order are similarly not to be subject to
parliamentary control. The Department argues that the proposals
"do not significantly alter the overall balance" between
the statutory protections to be delivered by means of the draft
order (which it describes as "core protections") and
the non-statutory protections to be assured by means of the Gaming
111. We have considered above the issue of the protection
in the existing law concerning the maximum sum a player may commit
to play a machine at any one time. We are content that it should
be continued by means of Gaming Board guidelines, as the Department
proposes. Therefore we agree with the Department's analysis
that the proposal adequately maintains the present overall balance
between statutory and non-statutory protections. Our concerns
over the provisions of certain individual protections to be included
in the guidelines are set out below.
Automatic credit to smartcard
112. The consultation paper indicated an additional
safeguard to be included in the Gaming Board guidelines, namely
a requirement that whenever a smartcard is withdrawn or ejected
from a gaming machine, the machine shall first credit the card
with all the money owing to the player.
This requirement does not appear in the list of proposed guidelines
in the explanatory statement. The Department's analysis of consultation
responses indicates that two consulteesthe British Casino
Association and Gala Leisurehad argued that this requirement
would disrupt players' playing patterns.
113. The Department has explained that, on reflection,
it considers this requirement to be technically impractical, given
the other requirements applying to the operation of smartcards.
If a player emptied a smartcard of value, it would be automatically
ejected, but would first have to have all the value recredited
to it: it would therefore be impossible for a player to commit
the full value of a smartcard to play on a machine.
Provision of smartcard readers
114. The explanatory statement indicated that Gaming
Board guidelines would provide for premises which have gaming
machines to have smartcard readers separate from such machines
for customers to use to check the amount remaining on a smartcard
without inserting it into a gaming machine. 
115. The draft of the Gaming Board guidelines attached
to the statement states that "a facility must be available
on the premises which will show the player what credits his smartcard
holds without requiring credits to be spent or a game to be played.
In practice, this requires that this facility is provided by the
machine, where the contents of the smartcard will be shown on
a display until either the player transfers money from the smartcard
or withdraws the smartcard."
116. We asked the Department to explain the discrepancy
between the explanatory statement and the draft guidelines. In
response the Department stated that it did not now think a separate
smartcard reader was necessary, as "it is better for the
player to have a reader conveniently sited in the machine he is
It also explained that the Gaming Board could exert more direct
control over smartcard readers sited in machines, as the Board
could exert more direct control over suppliers, and through them
over manufacturers: if a manufacturer produced a machine which
the Board did not like, it could exert its influence over machine
suppliers not to use it or site it.
117. We note that it would in any case have been
difficult for the Gaming Board to enforce any guidelines on the
provision of smartcard readers on the operators of gaming machines,
as the guidelines are addressed to suppliers and not to operators.
118. We are nevertheless concerned that the Department
appears to have reversed its position on a provision in the proposal
which appeared to constitute a valuable safeguard for the player.
Although the draft Gaming Board guidelines require a smartcard
reader to show a player the amount of credit on the card without
requiring credits to be spent or a game to be played, it is entirely
conceivable that manufacturers might construct machines which
would invite or induce a player to transfer credit or to play
a game as soon as a smartcard was inserted into the machine. We
believe that this would be an unacceptable development and would
reduce the level of protection available to the player. We
believe that the draft Gaming Board guidelines should be amended
so as to provide that a player who inserts a smartcard into a
gaming machine shall not receive any inducement or invitation
to play a game on the machine unless and until the player has
committed money to play.
Retention of surplus credit
119. The Department envisages two situations where
Gaming Board guidelines will allow a gaming machine to retain
a player's money in the machine:
- where the amount on the play meter is less than
that required to play a single game, and
- where the amount on the bank meter is less than
£1 (enabling the machine to pay out from the bank meter in
round pound amounts).
120. The provision that a machine is not required
to pay out a sum on the play meter which is less than the stake
required for a single game is, the Department states, in line
with present Gaming Board guidelines on the operation of gaming
machines: "there are often occasions when a small amount
of money, not enough for a single game, is left in the machine."
We accept that in this respect the present level of protection
is therefore retained.
121. The provision that amounts of less than £1
can be retained on the bank meter is of greater concern to us.
The industry might argue that it is more convenient for payouts
from the bank meter to be made in round pound amounts, and this
may make practical sense for machines which pay out prizes in
coins. The Department argues that the provision is acceptable,
since, once the requirement on machines to accept payment for
a single play is removed, machines which accept only £1 or
£2 coins will not have lower value coinage to pay out smaller
122. At present, therefore, it appears that the retention
of small cash residues in a gaming machine is tolerated because
machine design renders it impractical to pay them out in full.
Electronic means of payment are not, however, affected by this
mechanical impediment. We believe that technological developments
in the gaming machine industry ought to work to the consumer's
benefit. Accordingly we see no good reason why, in principle,
players using jackpot machines which can accept and pay out value
by electronic means should not be able to collect the full value
owing to them on the bank meter at any reasonable time. We would
expect the Gaming Board guidelines to reflect this principle.
123. It would in any event be open to operators of
smartcard-enabled machines to decide that it is in their interests
to set their machines to make full payment from the bank meter
to a smartcard, thereby encouraging the use of smartcards and
attracting players from cash-only to smartcard-enabled machines.
124. We asked the Department whether it believed
that the retention of small sums on the bank meter of a gaming
machine might constitute an inducement to a player to continue
playing the machine. The Department told us that the player protection
issue was whether the player had to pay for that further play,
and argued that at present players with cash residues left on
a machine could insert coins to make up the difference between
the residue and the amount required for a single play. It therefore
believed that the draft order would introduce nothing new.
125. New sections 31(3A), (3B) and (3C), to be inserted
by the draft order, provide for the use of smartcards in jackpot
machines and for their redemption. Section 31(3B)(c) provides
that any payment by the operator to redeem a smartcard must be
of the 'appropriate amount'. Section 31(3C) defines this amount
by means of a formula, (A+B)-C, where A is the amount paid for
the smartcard, B is the amount of any prize to be credited to
the card and C is the amount charged for one or more services
where the card has been used to pay for those services. Such services
would include play on a jackpot machine, and might also include
play on other amusement machines or the purchase of food or drink.
126. Where a smartcard is used to play a gaming machine,
and is then offered for redemption, it therefore appears that
the card must be redeemed in accordance with the formula ('cost
of credits to card' plus 'winnings') less 'amount paid for play'
(which will presumably always be a multiple of the charge for
a single play). This does not appear to allow any leeway for a
machine to retain any cash residue on the play or the bank meters
when a smartcard has been used to play the machine. An operator
running smartcard-operated machines which were set to retain cash
residues of less than £1 on the bank meter might therefore
risk a breach of the law. We draw this matter to the Department's
Retention of winnings in gaming machines
127. The requirement in the 1968 Act that gaming
machines must immediately pay out a player's winnings in full
appear to constitute a form of protection for the player. While
the proposal would remove this requirement, the Department proposes
to replace it with a requirement in Gaming Board guidelines that
winnings shall either be paid out directly or credited to the
bank meter for the player to collect or transfer to the play meter
Enforcement of existing and proposed Gaming Board
128. The Department acknowledges that the Board's
guidelines are non-statutory and non-binding, but argues that
they can nevertheless be effectively enforced, as Schedule 6 to
the 1968 Act empowers the Board either to revoke a certificate
issued to a person who sells, supplies or maintains gaming machines,
or to decline to renew it, if it considers that the holder of
the licence is 'not a fit and proper person'. The Department indicates
that the Board "regards its guidelines as covering matters
which can be taken into account in assessing whether a certificate
holder is fit and proper", and that this view has been tested
successfully in the courts.
129. Certificates under section 27 of the 1968 Act
are issued to gaming machine suppliers by the Gaming Board for
periods of five years, and are renewable. The annual report of
the Gaming Board for Great Britain for 2001-02 states that there
were 678 certificates in force in Great Britain on 31 March 2002.
Of the applications decided in the financial year 2001-02, one
application for a new certificate was refused by the Board. No
certificates were revoked, and no applications for renewal were
refused, although the holders of 18 certificates due for renewal
during the year did not apply for renewal.
130. We asked the Department to provide an analysis
to cover the last three financial years for which figures were
available of the Board's activities in certifying suppliers and
refusing and revoking certificates: its response is set out in
The Department states that breaches of the guidelines are extremely
rare, and are normally dealt with by discussions with the supplier
or the manufacturer of an offending machine. The ultimate sanction
is the removal of the supplier's licence. The Department has also
demonstrated how it believes the Gaming Board guidelines, which
are addressed to suppliers, can be enforced upon operators.
131. In its response to the Government's consultation,
GamCare raised a number of issues relevant to the operation of
the Gaming Board's guidelines. GamCare believed that the enforcement
powers of the regulatory authorities should be improved, stating
that "despite the assertion in the consultation document,
it is our understanding that the regulator's powers to enforce
compliance are only partly effective."
It also believed that certificates of fitness should be issued
to operators of gaming machines, as well as suppliers.
132. In response to our invitation to elaborate on
its concerns over the Board's enforcement powers, GamCare stated
that its principal concern in this respect was in the illegal
siting of higher-value AWP machines in areas which could be accessed
by minors, a licensing issue which it accepted was out of the
Gaming Board's hands.
While this issue is clearly of some concern, it is not directly
relevant to the matter before us, which is the Gaming Board's
ability to enforce its guidelines on the suppliers of gaming machines.
The Department recognises that in some instances Gaming Board
control can be brought to bear only indirectly, but it considers
that in this instance the Board's powers will be effective.
133. We are satisfied that the Gaming Board will
be effective in the administration and enforcement of the guidelines
which will accompany the draft order.
134. The consultation document relating to the proposal
was issued by the Home Office (the department then responsible
for gambling matters) on 19 March 2001, and published on the Home
Office website. Responses were invited by 15 June 2001. The consultation
began before the Regulatory Reform Act had received Royal Assent,
and consultation therefore took place under the provisions of
the Deregulation and Contracting Out Act 1994. The Home Office
indicated in its consultation document that the consultation was
intended to satisfy the requirements of the Regulatory Reform
Bill should it be enacted. In the explanatory statement to the
proposal the Department indicates that the Government is satisfied
that the consultation has satisfied the requirements of section
5(1) of the Regulatory Reform Act.
135. Fifty responses were received to the consultation,
mainly from individual gaming machine suppliers and operators,
representative bodies (for example, BACTA, the operators' trade
association), churches and religious organisations, charities
with interests in gambling, and academics. The Department has
summarised the responses in the explanatory statement (paragraphs
136. A sizeable majority of the consultation responses,
from all sectors consulted, welcomed the proposed changes insofar
as they enabled the appropriate and efficient use of modern technology
in gaming machines. A number of responses did, however, raise
issues in relation to problem gambling which were not adequately
covered in the Department's explanatory statement, and we have
raised these with the Department.
137. A number of consultees pointed out that spending
virtual cash (that is, credits on a smartcard) rather than real
cash would mean there was less of a psychological barrier to excessive
This might in turn lead to an increase in problem gambling on
gaming machines, possibly exacerbated by the actions of unscrupulous
suppliers and operators.
138. The Department indicated that, while the Government's
aim was to require all parts of the gambling industry to operate
to the highest standards of social responsibility, it was beyond
the scope of the order to enshrine this requirement in law. However,
it envisaged that a new Gambling Commission, to be established
by the proposed Gambling Bill, would be responsible for issuing
codes of practice on social responsibility which would form part
of operators' licences. It noted that the gambling industry was
making encouraging progress in setting up a trust to pay for the
treatment of problem gamblers and to commission research into
the causes of problem gambling.
139. The consultation document stated the Government's
concern that the proposed changes should not exacerbate problem
gambling. It indicated that it "seem[ed] unlikely" that
players' playing patterns would alter. In support, it cited two
assertions made by the gaming machine industry: that 70 per cent
of winnings on gaming machines, normally smaller winnings, were
replayed into machines (based on analysis of data collected by
the manufacturer JPM in the course of a research exercise); and
that most players would decide in advance the limit to their session
expenditure (based on a poll of leading gaming machine operators
conducted by BACTA). The Department believed that the proposed
changes would be unlikely to alter this pattern of behaviour.
140. The consultation response received from Cardiff
University Law School observed that the consultation paper made
no reference to the Gambling Prevalence Survey, undertaken by
the National Centre for Social Research, the results of which
were published in 2000, which it stated was the only recent large
scale sample which tested problem gambling, although it did not
capture specific data about players' turnover on machines. Contrary
to expectations, the survey had found that gaming machines were
not the worst temptations for problem gamblers.
141. The response of the Centre for Research into
the Social Impact of Gambling based at the University of Plymouth,
noted the Government's assertion that the proposed changes would
not exacerbate problem gambling. It stressed that it was "absolutely
imperative" that research should be undertaken to address
the potential impact of the changes, both on the patterns of consumption
of gaming machine users and on their likely effects on problem
gambling behaviour, prior to the changes being made,
142. We asked the Department whether it had commissioned,
or was aware of, any independent research into the likely effects
of the new machines and payment methods on player behaviour and
problem gambling. The Department responded that it had commissioned
no specific research on the draft order, as it would be difficult
to carry out in advance of the changes being made. It noted that
the Gambling Review Body had reviewed a wide range of research
evidence before it had endorsed the proposed changes. A review
of this research evidence carried out by independent consultants
for the Gambling Industry Charitable Trust had indicated that
machines could be configured to increase the risk of excessive
play, but that there was no evidence to suggest that there were
significant risks in allowing players to insert value into machines
in one form rather than another.
143. We recognise that it is difficult to simulate
the effects on player behaviour of gaming machines which cannot
yet lawfully be operated in Great Britain. But we do not necessarily
share the Department's confidence that the new machines will not
pose any significant additional risks to player behaviour. We
consider that the Department should arrange for an independent
monitoring programme to assess the effects of the new machines
on player behaviour, to report the results of the monitoring programme
to the House and to take appropriate action should it appear that
the new machines are exacerbating problem gambling behaviour.
The monitoring programme should be rolled forward to cover the
operation of the new machines covered by this proposal under the
similar provisions which the Department indicates will be enacted
via the Gambling Bill.
Changes to proposal following consultation
144. The Department states that there have been no
changes to the proposal as a result of representations received
145. The Government, in its consultation document,
proposed to include in Gaming Board guidelines the requirement
that those jackpot and higher-value AWP machines which did not
accept smartcards and/or banknotes (that is, ones which would
continue to be coin only) should remain capable of accepting payment
for a single play. In the explanatory statement, the Department
explains that it had dropped this requirement from the proposal
because it believed that it would be inappropriate for Gaming
Board guidelines to re-impose a provision which had been removed
from legislation by Parliament, and that in any event it would
not serve much purpose to do so. We have addressed the Department's
arguments in this respect at paragraph 101 above.
146. The Department states that as the substance
of the issue of accepting payment for a single play had already
been raised in the initial consultation document, it believed
that to drop the requirement in the case of coin-only machines
did not raise any separate issues, and it did not therefore believe
that any new issue of principle had arisen which would have required
re-consultation on the proposal.
147. We are satisfied that the proposal has been
the subject of, and taken appropriate account of, adequate consultation.
Costs and benefits
Financial costs and savings
148. The Department identifies costs to the industry
which will arise from operators either converting their machines
to accepting notes (a cost of between £250 and £300
per machine) and smartcards (£170 per machine). BACTA consider
that operators wishing to have the full benefit of the new methods
of play will have to purchase new machines: these are likely to
cost in the region of £2200, compared to £2000 for a
current machine. These initial costs to the industry would reduce
the immediate benefit of the proposals in year one, but the Department
considers that they would soon be absorbed in subsequent years.
149. The Department indicates that the overall financial
benefits to the industry will be delivered in the form of:
- reduced maintenance costs (owing, for example,
to coin jams)
- reduced down times (that is, when a machine is
out of action)
- fewer engineering visits to machines
- reduced disruption when altering stake or prize
limits or introducing new coins
- improved money handling and cash flow procedures
for operators; and
- increased efficiencies for manufacturers who
presently manufacture machines for the domestic and European markets.
It states that 49% of faults on jackpot machines
are coin-related, either on acceptance or at payout,
and notes that it is much easier and quicker for operators to
deal with banknotes and smartcards than with coins.
We note, however that in its consultation response GamCare countered
the assertion that the new machines would be more reliable than
the old coin-operated machines. It believed that the more complex
the methods of payment into and out of a machine were, the greater
the likelihood of machine breakdown.
150. The Department believes that as a result of
the proposal, players will be able to receive prizes in a more
The consultation document notes that the current top prize of
£1000 (since amended to £2000) for jackpot machines
operated in licensed casinos must be paid out in coins from the
machine itself, and that a payout in this form may significantly
burden the mechanism of the machine.
151. We have noted above the substantial variance
between the overall benefit to the industry estimated in the March
2001 consultation document£9.5 million annuallyand
the estimated benefit of the proposed order, which is now set
at £1.85 million, or less than 20% of the initial estimate.
The Department explained that this drastic revision has come about
because the proposal cannot now allow the use of smartcards, payouts
in means other than coins, or the optional retention of winnings
for future play, in higher-value AWP machines. The industry has
expressed its frustration that the proposed reform of the law
applying to jackpot machines cannot at present be fully extended
to higher-value AWP machines.
152. We asked the Department why, given the very
significant reduction in overall benefits which the proposed order
will now achieve, the Government has decided to press ahead with
the draft order at this time and in this form. As noted above,
the Department believes that there is no reason not to proceed
now with "a modest package of reform that will immediately
deliver small, but real, advantages to the industry".
The Gambling Bill is expected to implement wider reforms, including
those originally envisaged in the consultation paper.
153. The Department believes that there will be benefits
to gaming machine players, who will have more choice of machines,
may experience greater reliability in machines paying out and
who will be able to receive prizes in a more convenient form.
It also identified potential benefits to machine suppliers and
operators in the event that the United Kingdom adopts the euro,
as operators of note-only machines would not have to have their
coin acceptors replaced.
154. We asked whether gaming machines in Great Britain
are at present able to accept payments in euro, and/or to pay
out in euro, and whether the proposal would make any difference
to these arrangements. The Department and the Gaming Board "consider
it (at the least) highly probable" that current legislation
allows machines to accept payment and pay out prizes in euro or
other currencies subject to the sterling maxima in the 1968 Act,
and they do not believe that the present proposal would alter
155. A regulatory impact assessment is at annex B
of the explanatory statement. On the basis of this and the
other information provided by the Department, we are satisfied
that the proposal has been the subject of, and taken appropriate
account of, estimates of increases or reductions in costs or other
benefits which may result from the implementation of this proposal.
156. The explanatory statement indicates that, in
relation to higher-level AWP machines, the proposal is intended
to enable them to accept only coins and banknotes, and to pay
out only coins and banknotes. The Department states that machines
would not be able to accept money by means of any medium other
than cash. But it is by no means clear that the draft order, if
made, would amend the 1968 Act in this way.
157. The draft order would amend section 26(1)(b)
of the Act to remove the requirement for jackpot machines to accept
coins only and for higher value AWP machines to accept coins and
tokens only. It would also amend subsections 34(5B) and (5D) to
remove the requirement that higher-value AWP machines should accept
and pay out by means of coins only. The draft order does not,
however, specify what means of payment may be made into
a higher-value AWP machine. It appears that the effect of the
proposal, if made, would in fact be to enable higher-value AWPs
to accept any form of payment, extending to smartcards
and even to credit cards.
158. The explanatory statement made it clear that
this outcome is not intended. We therefore drew the point to the
Department's attention. The Department responded that while, at
present, higher-value AWP machines are not prevented from accepting
tokens as payment, in practice no machines do accept tokens in
payment, as they must pay out a money prize. Even though the requirement
that these machines must accept only coins or tokens in payment
will be removed once section 34(5B) is amended, the requirement
in section 34(5C)that the machine must deliver a money prize will
remain. The Department therefore argues that in practice higher-value
AWP machines will still be able to accept payment for play only
by means of coins and banknotes, and not by smartcards or any
other non-cash means.
159. We are not persuaded by this analysis. The Department
has accepted that there is in effect a small loophole in the law,
which may be enlarged once the draft order is made. It argues
that the effect of the law is in practice determined by the mechanical
operation of machines, and appears satisfied that the situation
will not change should the draft order be made.
160. In our view, the effect of the draft order,
if made, would be to leave an already complex and unclear piece
of legislation even less clear than before. We find it difficult
to understand why the Department should not seek to tighten the
drafting of the order in order to remove the possibility that
credit cards may be used for payment. This is a purely technical
amendment which will have no effect on the substance of the proposal
and will provide greater clarity. We therefore recommend that
the draft order be amended so as to stipulate that higher-value
AWP machines may accept only coins and banknotes as payment for
19 Fourth Report of the Deregulation Committee, Session
2000-01, The Final Deregulation Proposals, HC (2000-01)
Ibid., para 50, footnote 25 Back
Ibid., para 51 Back
Explanatory statement, para 19 Back
Contained in sections 26(1)(b), 31(3), (4) and (5) and 34(5D)
of the 1968 Act Back
Contained in sections 31(3) and 34(5B) of the 1968 Act. Back
Imposed by sections 31(4), 31(5) and 34(3), and 34(5C) of the
1968 Act Back
Lower-value AWP machines may accept stakes in the form of coins
or tokens and pay out prizes in coins, tokens and non-monetary
form: explanatory statement, para 42. Back
Explanatory statement, para 33 Back
Explanatory statement, paras 28-29 Back
Explanatory statement, para 40 Back
Gaming machines: methods of payment: a consultation paper,
Home Office, March 2001, para 54 Back
Explanatory statement, para 16 Back
Explanatory statement, para 30 Back
Explanatory statement, paras 31B32 Back
Explanatory statement, para 34 Back
Explanatory statement, para 63 Back
Consultation document, para 50 Back
Explanatory statement, para 130, and consultation document, para
Explanatory statement, para 63 Back
Explanatory statement, para 57 Back
Explanatory statement, para 59 Back
Appendix B, paras 10-11 Back
Explanatory statement, annex B Back
Explanatory statement, para 135 (Justices' Clerks' Society) Back
Appendix B, para 27 Back
Consultation document, para 57 Back
Appendix B, paras 17-18 Back
Appendix B, paras 25, 22 Back
Appendix B, paras 23-24 Back
Appendix B, para 20 Back
Appendix B, paras 40-41 Back
Appendix B, para 39 Back
Explanatory statement, para 61 Back
Appendix B, para 44 Back
Appendix B, para 46 Back
Appendix B, para 45 Back
Consultation document, paras 52 and 61 Back
Explanatory statement, paragraph 68 Back
Explanatory statement, annex A Back
Appendix B, para 38 Back
Appendix B, para 43 Back
Appendix B, para 42 Back
Report of the Gaming Board for Great Britain 2001-02, HC (2001-02)
1016, pp 52-57 Back
Appendix B, para 51 Back
Consultation document, para 60: "The [Gaming] Board's guidelines
are not part of the law. But it can enforce them effectively." Back
The Department has indicated that its proposed Gambling Bill will
create a Gambling Commission which will license both suppliers
and operators of gaming machines. Back
Appendix D Back
Appendix B, para 49 Back
For example, GamCare, the Church of Scotland, the Methodist Church,
the Wesleyan Reform Union, Nottingham Trent University and the
Welsh Assembly Government. Back
Appendix B, para 58 Back
Appendix B, para 60 Back
Explanatory statement, para 97 Back
Explanatory statement, para 100 Back
Explanatory statement, para 102 Back
Consultation document, para 36 Back
ALegal glitch could delay parts of deregulation order@, BACTA
press release, 13 November 2002 Back
Appendix B, para 66 Back
Appendix B, para 67 Back