Five regulated markets have written down how an online slot is allowed to behave, but they haven’t written down the same thing. Great Britain and Ontario both require at least 2.5 seconds between slot spins, Germany requires an average of five, and the Netherlands sets no interval at all while closing off every route a player could use to avoid pressing the button. Brazil is drafting its own version now, which is why the comparison is worth having this month rather than in the abstract. One game build cannot be shipped to all five, and every time a regulator moves a number, the whole live library has to be tested again before it can keep running.
Key Takeaways
- Online game design rules govern how a licensed game behaves rather than what it pays out: whether autoplay is permitted, how long a spin must take, whether a player can speed up the result, and whether a game may celebrate a return smaller than the stake.
- The minimum interval between game cycles is 2.5 seconds for slots in Great Britain (RTS 14G) and Ontario (Standard 2.18) and an average of five seconds in Germany (§ 22a(6) GlüStV 2021). Great Britain applies five seconds to non-slot casino games from 17 January 2025, so it holds two numbers in one rulebook, and the Netherlands sets no interval at all.
- Brazil’s Secretaria de Prêmios e Apostas has been preparing an interministerial ordinance on game design since early August 2026. It has not been published yet, and published accounts disagree on whether the interval will be 2.5 or five seconds, and the draft is reported to give operators 30 days to change platform design and 180 days to recertify every game.
- Enforcement is already running. Ontario’s AGCO ordered a C$70,000 penalty against Booming Games (Malta) Limited on 20 August 2026 after prohibited auto-play ran on several slot titles for months, and the regulator found it through its own compliance work rather than a complaint.
What do online game design rules actually cover?
They govern the mechanics of play, not the odds or the return to player. A regulator writing them is trying to keep a player making a conscious decision about each wager, so the rules cluster around the features that reduce how many decisions a player takes.
- Autoplay, meaning any function that starts the next game without the player doing anything. The Dutch approval schema has the strictest definition, since it treats bonus buy, buy free spins and holding a key down as versions of the same thing.
- Speed, meaning a minimum time from the start of one game cycle to the point where the next can begin. This is the number that varies most.
- Speed-up features, meaning turbo, quick spin and slam stop buttons that shorten the wait for a result or give a player the impression they control it.
- Celebratory effects on a losing or break-even outcome, where a return equal to or smaller than the stake is presented with the sound and animation of a win.
- Parallel play, meaning operator-led functions that let one customer run several games at once.
Stake caps sit alongside these rather than inside them. Great Britain caps an online slot stake at GBP 5 per game cycle, or GBP 2 for players aged 18 to 24, under regulations effective 9 April and 21 May 2025. Germany caps a virtual slot machine stake at EUR 1 per spin. Ontario and the Netherlands set no cap.
A second group of duties gets less attention, and it covers what the game must show rather than what it must not do. Ontario requires a slot session to display net position in Canadian dollars (Standard 2.21) and a means of tracking time played (Standard 2.22), and Great Britain requires net spend and net time under RTS 2E and 13C. That matters in the build, because a display duty touches the interface while a speed rule touches the game engine, and different parties usually own those.
How do the UK, Ontario, Germany, the Netherlands and Brazil compare?
The table compares the five markets on the features that force a code change.
| Market | Autoplay | Minimum interval between game cycles | Speed-up or turbo | Celebrating a return at or below stake | Stake cap per spin |
| Great Britain | Prohibited (RTS 8A) | 2.5 seconds for slots (RTS 14G); 5 seconds for other casino games from 17 January 2025 | Prohibited (RTS 14E) | Prohibited (RTS 14F) | GBP 5, GBP 2 for ages 18 to 24 |
| Ontario | Prohibited for slots (Standard 2.16) | 2.5 seconds for slots (Standard 2.18) | Prohibited (Standard 2.19) | Prohibited (Standard 2.20) | None set |
| Germany | Prohibited (§ 22a(4) GlüStV 2021) | 5 seconds on average (§ 22a(6)) | Not addressed separately | Not addressed separately | EUR 1 (§ 22a(7)) |
| Netherlands | Prohibited, including bonus buy and holding a key (KS.09.05_2.0) | None set | Not addressed separately | Not addressed separately | None set |
| Brazil (draft) | Proposed prohibition | Reported as either 2.5 or 5 seconds, not settled | Proposed prohibition | Proposed prohibition | Not proposed |
Sources are footnoted at the end. The Brazilian column describes a draft ordinance that had not been published at the time of writing, so treat it as the direction of travel rather than the final text.
Read down the columns rather than across the rows. Autoplay is prohibited everywhere here, which makes it the closest thing this subject has to an international standard and something a supplier can safely build to. Almost nothing else is settled. The interval is 2.5 seconds, five seconds or nothing depending on where the player happens to be sitting, and turbo and celebratory effects are prohibited in the two markets that wrote detailed slot standards and simply unaddressed in the two that did not.
Germany sits at one end of the range, and not only on speed. Section 22a of the GlüStV 2021 also bans jackpots outright at paragraph 8, on the basis that stakes and winnings must not be pooled to create prizes for future games, and bans playing more than one virtual slot game at a time at paragraph 10. Put the EUR 1 cap next to those and the German product stops being a slower version of the same game and becomes a different category that happens to share a name.
Why does the difference between 2.5 and five seconds matter?
Because it halves the theoretical maximum number of chargeable events in an hour. At a 2.5-second minimum a slot can in principle complete 1,440 game cycles an hour, and at five seconds it can complete 720. Real play sits well below either ceiling, since people pause, read, change stake and leave, but the ceiling still sets the shape of the product.
Put the interval next to the stake cap and the gap widens. A British slot at GBP 5 and 2.5 seconds has a theoretical maximum stake of GBP 7,200 an hour. A German virtual slot machine at EUR 1 and five seconds has a maximum of EUR 720. That is a tenfold difference in the outer limit of what one session can be worth, between two European markets that both consider themselves strictly regulated.
So the argument in Brazil comes down to which number to pick, since nobody there is disputing the principle. ANJL and IBJR, the two industry associations, met SPA officials on 7 August 2026 and argued for 2.5 seconds, citing Great Britain and Ontario as precedent. What makes that hard to settle is that Great Britain does not hold one position: it requires 2.5 seconds for slots and five for other casino games, including house-banked poker variants such as three-card poker, with peer-to-peer poker excluded. Both numbers came from the same regulator and the same policy programme, so five seconds is a judgement call rather than a harm threshold anyone has proved.
What did Ontario’s C$70,000 penalty show about enforcement?
It showed that the regulator will go after the supplier rather than the operator, and that it will find the breach itself. On 20 August 2026 the AGCO ordered a C$70,000 penalty against Booming Games (Malta) Limited after a prohibited auto-play function ran on several of its slot titles in Ontario for several months before being switched off.
Two details in it belong in a contract review. The AGCO cited two standards, not one: Requirement 2 of Standard 2.16 for the prohibited feature, and Requirement 3 of Standard 4.09 for failing to monitor and test the gaming system across its life, so shipping the feature and failing to notice it were treated as separate breaches. The AGCO also described the discovery as its own proactive compliance work and said it then notified the affected operator, so the operator learned about a problem in its own lobby from the regulator.
The penalty went to the studio, and the games were live on the operator’s site, in front of the operator’s customers, for months. Booming Games has 15 days to request a hearing before the Licence Appeal Tribunal.
What is Brazil about to decide?
Brazil is preparing an interministerial ordinance on the design, user experience and functioning of online games, and the reported content goes well past spin speed. Alongside the autoplay ban, no turbo function and a minimum interval between rounds, the draft is reported to prohibit countdown timers, celebratory sound and animation on losing bets, live winner rankings and real-time prize feeds, pre-filled deposit and bet amounts, tutorials or statistics that make a game look like a test of skill, chat between users, loyalty schemes based only on deposit volume, and promotional offers shown to a player who is requesting a withdrawal.
The deadlines are the part to read first. Reporting on the draft puts 30 days on platform design and user experience, and 180 days on recertifying every game in the library.
ANJL and IBJR did not oppose the rules, but asked for them in two phases, so that conduct, interface, transparency and advertising duties start immediately while anything touching game mechanics waits until the rules for B2B suppliers are finished. That sequencing point is real rather than a delaying tactic, because an operator cannot change how a slot behaves. The studio wrote it. Until Brazil regulates suppliers directly, the duty to deliver compliant mechanics falls on a licensee that cannot deliver it on its own.
What does a design rule change cost in operations rather than in product?
The expensive part is proving the new build rather than writing it. A change to how a game starts, how long it runs or what it does on a losing spin is a change to a certified component, so an accredited laboratory has to test the title again and issue a fresh certificate before it goes back in front of players. That is per title, in every market that requires it, and the cost is carried whether or not the title earns anything.
Brazil has accredited several laboratories, starting with Gaming Laboratories International in March 2024 and followed by eCOGRA and Gaming Associates. Laboratory capacity is finite. If a 180-day clock starts for every licensee at once, everyone queues at the same doors in the same window, and whoever booked capacity against the draft will be in front of whoever waited for the published text.
Budget for three numbers rather than one: the laboratory fee per title, the studio development time to change the build, and the revenue a title does not earn while it sits out of the lobby waiting for its certificate. The third is the one nobody puts in the business case, and it is the only one that scales with the length of the queue.
Then there is who pays, which is usually not settled in writing anywhere, since most operators do not own the games they run and an aggregator often sits between them and the studio. The long tail is the related problem, because a studio deciding which older titles are worth recertifying for one market will quietly not recertify some of them, and the operator finds out when the title disappears from the lobby. Great Britain is the warning on timing: the five-second rule for non-slot casino games took effect on 17 January 2025 with no transition window for games already live.
What should operators do before the next rule change?
Treat game design compliance as a library management problem rather than a product one, and do five things before the Brazilian ordinance is published.
- Count the live library per licence: how many titles are live in each market, which studio owns each one, and which aggregator delivers it. Most operators cannot answer that in a morning, which is the first finding.
- Build a market-by-market design matrix covering autoplay, minimum interval, speed-up features, celebratory effects, parallel play, stake cap and net position display, so a new rule can be scored against the library in an afternoon.
- Mark the titles that comply with a market only because that market has no interval rule. Today that is the Netherlands, and Brazil until the ordinance appears, and those titles are the ones most exposed to a single number changing.
- Read the supplier and aggregator contracts for two clauses: who funds recertification triggered by a regulatory change, and what happens commercially to a title the studio decides not to recertify in time. If neither clause is there, open that renegotiation now rather than inside a 180-day clock.
- Book laboratory capacity against the draft rather than the final text, and accept that some of it will be wasted. Wasted laboratory time is cheaper than a lobby with holes in it.
Boardroom Questions
- How many live game titles do we carry in each licensed market, and can we produce that list today rather than in a fortnight?
- Which of our markets set no minimum interval between game cycles, and what share of our revenue there comes from titles that would need rebuilding if a 2.5-second or five-second rule arrived?
- Do our supplier and aggregator contracts say who pays for recertification when a regulator changes a design rule, and if not, when are we opening that conversation?
- Who inside our business is monitoring the Brazilian ordinance, and have we booked laboratory capacity on the assumption it publishes this quarter?
- If a studio told us it will not recertify 15% of our catalogue for one market, do we know which titles those are and what they earn?
Sources
1. Gambling Commission, Remote gambling and software technical standards, updates effective 31 October 2021: RTS 8A autoplay, RTS 14C simultaneous play, RTS 14E turbo and slam stops, RTS 14F celebrations of returns at or below stake, RTS 14G minimum spin speed of 2.5 seconds, RTS 2E and 13C net spend and net time display.
2. Gambling Commission, Summer 2023 consultation response, Proposal 2: Speed of play. RTS 14G requires a minimum of five seconds from the start of a game until the next game cycle can be commenced for casino games other than slots, effective 17 January 2025, with peer-to-peer poker excluded and house-banked poker variants included.
3. Gambling Commission, Online slots stake limit guidance, and The Gambling Act 2005 (Operating Licence Conditions) (Amendment) Regulations 2025: GBP 5 per game cycle from 9 April 2025, GBP 2 per game cycle for customers aged 18 to 24 from 21 May 2025.
4. Alcohol and Gaming Commission of Ontario, Registrar’s Standards for Internet Gaming, in force 4 April 2022 and amended May 2026, Standards 2.16 to 2.22.
5. Alcohol and Gaming Commission of Ontario, news release, 20 August 2026: AGCO orders C$70,000 penalty on Booming Games (Malta) Limited for a prohibited auto-play feature, citing Requirement 2 of Standard 2.16 and Requirement 3 of Standard 4.09.
6. Glücksspielstaatsvertrag (GlüStV) 2021, § 22a Virtuelle Automatenspiele: paragraph 4 on automatic continuation of play, paragraph 6 on an average minimum duration of five seconds, paragraph 7 on a EUR 1 maximum stake per game, paragraph 8 on the jackpot prohibition, paragraph 10 on parallel play.
7. Kansspelautoriteit, Keuringsschema spelsysteem kansspelen op afstand, version 2.1, 1 October 2024, norms KS.09.05_2.0, KS.09.06_2.0 and KS.09.07_2.0, which prohibit automatic participation and name bonus buy, buy free spins and holding a key down as circumventions.
8. Secretaria de Prêmios e Apostas (SPA/MF), draft interministerial ordinance on the design, user experience and functioning of online games, unpublished at the time of writing. Reported content and deadlines, and the meeting of 7 August 2026 between SPA officials Fabio Augusto Macorin, Andiara Maria Braga Maranhão and Leandro dos Reis Lucchesi and the associations ANJL and IBJR, reported by Focus Gaming News, BNLData and iGaming Business during August 2026. The 2.5 versus five second figure is reported inconsistently across those accounts and should be confirmed against the published text.
9. Gaming Laboratories International, accreditation by SPA to certify betting systems, live game studios and online games for Brazil, March 2024; eCOGRA and Gaming Associates subsequently recognised as certifying entities.