10 March, 2021

Spin cycle

Just about every country is unique in terms of where it stands on slot machine legislation, but the UK has followed a more circuitous route than most. Paul Sculpher, director at GRS Recruitment, and Nick Arron, a solicitor and lead partner in the gambling team at Poppleston Allen, discuss the path that brought us to now, lessons learned, and effective ways to forge ahead.

Paul Sculpher:

There is a squadron of categories currently within the legislation, and it's been a moving target as long as I can remember, shaped by commercial forces, problem gambling concerns and shifting interpretations of what can be made to look legal on a machine.

The categories are primarily split with reference to the venue in which the machines are located, with B1 at the top of the tree - casino slots. Category A, which would have sat at the top of the table with potentially unlimited stake and prize but has never been legalised as such, as they were destined for the fabled Regional Casino category, which was scuppered some years ago.

B1 slots are currently up to £5 stake and £10k or £20K prize if linked to a progressive jackpot, and are restricted purely to casino licences, of which there are around 140 in operation in the UK (COVID restrictions notwithstanding, and we'll no doubt see some never to re-open).

The rules regarding B1 machines have shifted over the years too, with 20 per licence permitted right now, and the curious sight in several UK properties such as Empire Leicester Square and Genting Southend of twin licences in the same building, arranged physically so they can be discrete businesses and double up their slot allowances. In my early days in casinos as a trainee dealer in the old Stanleys Southampton casino, the original limit was two slots per casino, and you were stuck with coin operated slots only, paying out via tubes and eventually belt-fed hoppers. It seems like only yesterday that, as a shift manager, I'd repeatedly have to get horizontal on the floor and clear a tube jam from the bottom of the tubes upwards with an unbent coat hanger thanks to someone putting the coin bins in the wrong way round.

Eventually technology moved on along with the law and we moved to six, then 10 and now 20 slots per licence, with the parallel movement to the aforementioned hoppers, then TITO and card-based cash systems. Prizes moved on apace as well, from the £500 per machine in the early days to now.

It's actually been a formative experience for the casino industry, moving from where we were to where we are. Many UK casino executives would bemoan the lack of interest in slots held by site managers, and while I think it's a lot better now than it was a decade ago, the low percentage of site income offered by slots years ago has in some cases clung on in management approaches - slots are still seen by a minority as a box that sits in the corner. In truth they represent a critical income driver that should, along with the electronic roulette product, carry equal weight on the priority list for management attention.

Slots are still seen by a minority as a box that sits in the corner. In truth they represent a critical income driver that should, along with the electronic roulette product, carry equal weight on the priority list for management attention.



Nick Arron

There are several other categories for slots in the UK, and they're generally a whole lot more contentious. This starts with seaside arcades, which are allowed to offer slots in Category D, which can pay up to £8 (or more if coin pushers and cranes machines) and be played by children. This, as one might imagine, is not really in line with how many other countries approach the provision of slots, and leads to accusations of "training" kids to gamble. Bingo clubs and other membership clubs such as working men's clubs and snooker halls have generally had special provision under the law, which has changed over the years but generally allows them a limited number of higher stakes machines to go along with the (theoretically) better controlled environment that's on offer. Then we get to arcades and pubs. The machines allowed to be offered here used to be identical under AWP (Amusement with Prizes) rules, although that name does imply they bear no problem gambling risk, which clearly isn't the case. You could argue all day how great that risk is, but with potential for £20 to get eaten in a matter of minutes, disposable incomes can be at risk at speed. The rules for arcades and bingo also took a turn back in the early 2000s, when parties identified an opportunity to work with the law to offer higher prizes on their slots. It takes a bit of figuring out, but by offering multiple simultaneous games of prize bingo, and that prize bingo having a cash prize of £25, operators were able to offer slots with £500 prizes on slots known by operators variously as "Section 21" and "Section 16" machines (depending which element of the law they were, well, bending). This was all good, but the 2005 Gambling Act slammed this door shut. After this, the change in rules seemed to accelerate. Arcades and bingo clubs were allowed an allocation of higher prize (B3) machines on a per licence basis, which led to some enterprising operators subdividing their sites into multiple licences (with arcade licences being easier to secure than casino licences) to allow more lucrative high prize machines. Since then there has been an 80/20 rule to more fairly determine how many higher prize machines are permitted. This led to the beginning of the situation we see today.

Paul Sculpher

That's all without mentioning arguably the biggest change to all slot and electronic gaming of all - FOBTs. The FOBT was introduced in 2001 when presumably some enterprising betting employee realised there wasn't any legal difference between betting on the outcome of a 37 runner horse race, and a 37 compartment roulette wheel. Their genesis came as quite a surprise to at least one casino operations project manager, me, when I was walking down the street in Maidenhead to see a Ladbrokes shop advertising roulette machines. We in casino land had presumed until that point that the electronic roulette we had recently started rolling out in casinos would be the exclusive preserve of the better protected casino environment. The history of the limits applied to gaming on FOBTs is generally well known, but suffice to say that in 2018, when the maximum stake was reduced to £2 per spin (from £100), there was a major impact on the market. The damage to the betting shop industry may not have been quite as bad as feared, but certainly many shops closed and without question many gamblers, the majority of whom were in control of their gambling, no longer had a handy place to gamble the way they wanted to right there on the high street. This led to the current situation.

Nick Arron

As we stand now, casinos are sat with 20 B1 slots per licence, while bingo and arcades can have up to 20% of their machines as B3, while AWPs in pub and the rest of the arcade footprint can offer stakes up to £1 and prizes up to £100. One thing we're seeing is the rise of arcades (adult gaming centres or AGCs) in high streets, presumably to fill the void created by betting shops closing. It seems clear that the idea is to offer a gaming experience somewhat akin to the higher stakes and higher prize option that's been hooked out of betting shops. Every change to the status quo, of course, is subject to the law of unintended consequences, and this one is no different.

Operators' thoughts are now turning to the Gambling Review, and the implications for the slot business in the UK. It seems clear that the emphasis will be mainly on curbing the perceived excesses of the online world, but all verticals will be under the microscope.

On the slots side, certainly with reference to my specialist area of offline casinos, there's a strong hope that the Gambling Review will finally address the machine allowances. On the face of things, it doesn't really make sense that casinos are limited to 20 slots in a highly regulated and well managed environment if one is safe, from a problem gambling point of view, then why wouldn't 50 be safe, if there's demand.

The current conversations seem to revolve around possible harmonisation of machine allowances. That's a reference to harmonisation with the new casino licences created by the 2005 Gambling Act, which were allowed two slots per gaming table (for "small" licences) and five per table (for "large" licences). While you wouldn't really be able to say the 2005 Act was a great success in regard to the "experiment" for 16 new licences - half of them haven't even been developed, and likely won't be - at least it's fair to say that the increased machine allowances haven't led to any recorded surge in problems with machine gaming. They also haven't led to the mysteriously terrifying prospect of "machine sheds".

An increased slot allowance for casinos, meaning smaller sites could offer perhaps more than 30 slots, would be a welcome boost to a sector that has been battered more viciously than most by the pandemic situation, and it's tough to see much risk attached to the prospect. It remains to be seen how much appetite there is for any concessions to operators, whether online of offline, but this Gambling Review may be a pivotal point for all sectors of the industry.