Public health advocates continue to push for stricter regulations on gambling advertising, likening bookmakers to tobacco firms. On September 17, the House of Lords Liaison Committee released a report urging the government to ban gambling ads "as soon as practicable". The committee also recommended that the government abandon its goal of expanding the regulated gambling industry, advocating a return to the pre-2005 principle that gambling should be tolerated rather than promoted, arguing that there is "no evidence for the safety of gambling advertising."
However, the gambling industry disagrees with this perspective. Grainne Hurst, chief executive of the Betting and Gaming Council (BGC), described the committee’s report as "a deeply misguided document which risks weakening, rather than strengthening, consumer protection."
The report claims that between 1 million and 1.5 million adults in Great Britain are engaged in problem gambling; this figure comes from the Gambling Commission’s Gambling Survey for Great Britain (GSGB), which states that 2.4% of adults score eight or higher on the Problem Gambling Severity Index. This estimate is at odds with the NHS Health Survey for England, which found a 2024 rate of 0.7%, suggesting about 350,000 problem gamblers.
Critics question the GSGB's methodology. Dan Waugh, a partner at consultancy Regulus Partners, explained that the GSGB consistently reports higher rates of problem gambling than other official surveys, including three conducted by the NHS. He attributes this discrepancy to "topic salience," where individuals interested in gambling are more likely to participate in the survey, thereby inflating numbers. Waugh noted that the GSGB's response rate of 18%-19% falls short of its 22% target, further questioning the reliability of its data. Academic Heather Wardle had alerted the commission in 2023 to the potential for over-reporting due to this bias, but this advice only surfaced through a freedom of information request.
The Gambling Commission defends the GSGB, asserting it was created and vetted by experts who maintain that respondents are truthful without an interviewer present. While Patrick Sturgis of the London School of Economics supports their approach, his 2024 review recommended caution due to the possibility of overstatement. The committee acknowledges this contention but suggests that older surveys may have underestimated the prevalence of problem gambling. Waugh remarked that the report acknowledges concerns about the GSGB yet largely operates under its findings as accurate.
Timing presents another area of dispute. The committee claims voluntary measures have not gone far enough; notably, the Premier League’s decision to remove gambling sponsors from the front of jerseys only took effect in August, after the committee gathered evidence on June 17. Although the committee posits that this change will only reduce visible gambling marketing by around 9%, Waugh counters that such a reduction is still significant, though this argument only receives a brief mention in the report.
The panel points to Manchester United’s training kit sponsorship with Betway as evidence that sponsorship is merely shifting rather than disappearing entirely. It suggests replacing recently introduced wagering caps and opt-in direct marketing rules with outright bans.
A key debate centers on the potential rise of the black market. Industry representatives argue that an advertising ban could drive consumers to unregulated operators. The committee rebuffs this claim as "insufficiently evidenced," prompting Hurst to express concern that the report disregards the growing threat of illegal gambling simply because it contradicts their conclusions.
To support its stance, the committee cites a study from Philip Newall, Allegra Whybrow, and Jamie Torrance, which indicates that state monopoly operators in Europe do not experience a consumer shift to illegal gambling due to advertising restrictions. However, this study does not directly address the black market issue.
Taking Finland as a case study, Veikkaus, the state operator, recently indicated that its monopoly is failing due to about half of online gambling spending occurring outside its jurisdiction. Chief executive Olli Sarekoski stated, "What is the point of the monopoly if this is the case?" Finland plans to open its online market to licensed competitors next July, highlighting that the structure of the market is complex and entwined with advertising strategies.
The BGC’s claim that unlicensed operators will spend £845 million on UK advertising in 2023 is contested by the Gambling Commission, which reports no continuous increase in illegal market engagement. Critics argue that the report's demand for causal proof of harm reflects a misunderstanding of social science, asserting confidence in the correlation between licensed operators and advertising volume while admitting to a lack of clear evidence.
The report highlights criticisms of industry narratives on displacement, referencing claims of a potential £1.25 billion boost to the economy and the creation of 22,000 jobs if gambling spending were to decrease by 10%. Waugh expressed concern that the committee seemed to have determined its conclusions before adequately addressing issues of data credibility and the potential rise in criminal activity.
Finally, the report discusses enforcement challenges regarding the black market. Hurst pointed out that countries like Italy, which instituted an extensive ban on gambling advertising, continue to deal with a significant illegal market. In the Netherlands, regulators caution against a total ban, noting that only about half of gambling spending is directed towards licensed operators.
While the report suggests that much of Italy's remaining advertising emerged from licensed companies exploiting loopholes, Hurst warns that a complete ban on advertising could undermine the competitiveness of licensed and regulated operators.
The committee, led by Lord Ponsonby of Shulbrede, conducted only one evidence session and solicited written submissions from what it characterized as a "small, balanced selection" of interested parties. Conflicts of interest were flagged, as Lord Smith of Hindhead leads an association affiliated with establishments hosting gaming machines, while Lord Foster of Bath declared connections to consultancy work funded by gambling critiques.
The government now has two months to answer to the committee's recommendations.
