Dispute avoidance advice
Last updated: November 2026
Slots Games Feature Graphics
We have received a recent run of complaints from consumers who argue that the design of digital slots games creates an intended, misleading impression that they are ‘building up’ towards an inevitable feature round or bonus game. Typically, these are games where symbols are scattered on the reels and collect in a ‘pot’ which appears to fill and occasionally grow, giving players a belief that they are close to triggering some form of feature.
In almost all cases, the game provider confirms that the triggering of the feature is entirely random and the graphics exist only for the ‘entertainment of the player’.
We accept that more frequent slots players will know or will have learned by experience that these graphics are not illustrative of an imminent win, but we are also satisfied that a number of people genuinely believe that they can deposit or play further reasonably anticipating that the rewards for the pots they have built up must be just around the corner.
IBAS’s approach is to accept that if a game is published on a licensed operator’s website, the game must have been tested to meet the specifications required by the appropriate regulator. Nevertheless, we believe that these techniques, clearly designed to encourage further play, can cause confusion and a breakdown of trust with certain customers. We would encourage you to ask suppliers to remove graphics which have significant scope to mislead, or to improve the clarity of messaging which explains the true meaning of these graphics.
We have reported our concerns in this area to regulators.
We have similar concerns about games which do award some feature or bonus when a ‘meter’ is filled up or trail completed – but where the pathway to the feature fills up disproportionately quickly in its earlier stages and disproportionately slower the closer it is to being completed. This process is almost always set out, subtly, in the game rules; however we have seen many examples of it creating mistrust and a relationship of bad faith with consumers.
Soccer Stats: Can your named provider deliver?
IBAS has written many times on concerns about the transparency and consistency of data used to settle football bets, particularly on individual player performance markets.
We maintain that betting on ‘matters of opinion’ is inherently less satisfactory than betting on ‘matters of fact’. “Shots on target” have always had a subjective element but now many companies offered betting on total “shots”, which seem to us to have a much wider scope for disagreement. Similarly “fouls”.
We accept that bets based on these statistics resonate with bettors – they’re popular and growing. We still believe that governing bodies and organisers of competitions should make meaningful effort to create standard statistics that are used equally by every betting operator. Different websites recording different outcomes results in inevitable increases in disputes. The betting industry has power it could use to lean on these bodies to standardise their data.
We recently considered a dispute that was based on a mechanism where bets on a particular player carried over to any player brought on to replace them as a substitute.
The problem was that the match was a Friendly and there was no official referee’s report to confirm who replaced who. Various sports data websites displayed conflicting information – the graphics displayed on the live television broadcast conflicted with the audio commentary. In the end IBAS determined that bets had to be settled in accordance with the records filed by a named data provider, even though it seemed highly unlikely that the named data provider was in attendance or had any better idea as to the proceedings surrounding the substitutions.
In our view the ‘substitute replacement’ promotion was ill-suited to the fixture because of the lack of official match data; and the named data provider was not the right one for that particular event.
The sports data provider market is dynamic, contracts change hands frequently and this can make the rules or terms of betting operators quickly look outdated. We recommend that terms governing the settlement of these markets are reviewed regularly with particular care being taken to name providers who are appropriate for the role their data will play, and whose data is open to public scrutiny so there are no legitimate challenges to the transparency of the process.
VAR Ruled Out Goals: What happens next?
From time to time, we see disputes which arose from the premature reopening of markets after a goal appears to have been scored, but which is later reviewed and ruled out. Ideally, all operators would agree that after a goal is scored, none will reopen betting markets until the match resumes. We appreciate that this is unrealistic – and everyone is searching for a commercial edge.
Often, we find that rules and terms for what happens where markets are offered, temporarily, on a false premise, are unhelpfully ambiguous. For example, if Harry Kane scores a goal in the 10th minute of a football match, and the market “Harry Kane to score a hat trick” is reopened, what happens to bets placed before the VAR process begins and later rules out the opening goal.
Do bets stand but rebooked on Harry Kane to score 2 or more goals (because the premise of the bet was that Kane would score two further goals from that point)?
Do bets stand on the hat trick but at a reworked price which reflects he now has to score three further goals and not two?
Are bets made void on the basis that the bet was struck on a false premise – that Kane already scored one?
It is infinitely better if these questions are answered by rules which predate the incident occurring – and it is always less satisfactory for everyone, if we attempt to find a fair solution once we know the outcome of the match.