Public health advocates have long sought to regulate bookmakers similarly to tobacco companies. On September 17, a report from the House of Lords Liaison Committee urged the government to implement a ban on gambling advertising "as soon as practicable." Additionally, it recommended that ministers abandon their goal of expanding the licensed industry and revert to the pre-2005 principle of tolerating but not promoting gambling. The committee asserted that there is "no evidence for the safety of gambling advertising."
However, the gambling industry has a different perspective. Grainne Hurst, the chief executive of the Betting and Gaming Council (BGC), described the report as "a deeply misguided document which risks weakening, rather than strengthening, consumer protection."
The report's initial claim states that between 1 million and 1.5 million adults in Great Britain exhibit behaviors associated with problem gambling. This figure stems from the Gambling Commission's Gambling Survey for Great Britain (GSGB), indicating that 2.4% of adults score eight or more on the Problem Gambling Severity Index. Contrastingly, the NHS Health Survey for England found a rate of 0.7% in 2024, translating to approximately 350,000 adults.
Discrepancies in harm measurement have emerged. Dan Waugh, a partner at Regulus Partners, highlighted that the GSGB has produced higher rates than all other official sources over the last two decades, including three NHS surveys. He attributed this to "topic salience"—where those with an interest in the survey topic are more likely to participate. Since the GSGB is identified as a gambling survey, it may "over-recruit gamblers and more engaged gamblers."
Waugh noted that a response rate of 18%-19% fell short of the survey’s 22% target, complicating the reliability of the findings. He cited concerns from academic Heather Wardle, who warned the commission in 2023 about the potential for over-reporting due to this bias, a warning only revealed through a freedom of information request.
In defense of the survey, the Gambling Commission stated it was "designed by experts, reviewed by experts and approved by experts," asserting that respondents tend to be more truthful without an interviewer present. The report cited Patrick Sturgis of the London School of Economics as supportive of this methodology; however, Sturgis had previously advised caution due to the risk of overstatement in his review for the commission in 2024. The committee juxtaposed the ongoing debate, suggesting that earlier surveys, including findings behind its own 2020 report, "may indeed have been underestimated."
Waugh criticized the committee for relying too heavily on the GSGB’s findings despite acknowledging concerns about its accuracy. The committee also reflects on the timing of the recommendations. It claims that voluntary measures to manage gambling advertising "have not gone far enough," even though the Premier League's significant step of removing gambling sponsors from the front of shirts only began in August.
When the committee gathered oral evidence on June 17, it had not yet seen the effects of this removal and still reported being "not confident" in the ban's effectiveness. It relied on an academic estimate suggesting that the ban would reduce visible gambling marketing by only about 9%. Waugh, who also presented evidence, argued that a 9% reduction is still meaningful, but his perspective was captured in just one brief paragraph.
The committee used Manchester United's reported training kit deal with Betway as an example of sponsorship changing rather than dissipating entirely. Further, it proposed replacing the wagering cap implemented in January and opt-in rules for direct marketing with outright bans.
A key point of disagreement remains the issue of the black market. The industry argues that a ban on advertising would leave room for illegal operators to thrive. The committee countered this by labeling the industry's concern as "insufficiently evidenced."
Hurst countered, stating, "Most concerning is the report’s willingness to dismiss the rapidly growing threat from the criminal gambling market simply because it does not fit its conclusions." The committee then outlined findings from the UKRI Gambling Harms Research UK's Evidence Centre, which included a study indicating that advertising restrictions did not lead to consumer shifts towards illegal operators, according to interviews with state monopoly operators across Europe.
However, the authors of this study, involving 11 representatives from ten state-owned operators, noted that it did not aim to answer that question directly. Hurst pointed out that Finland has begun to question the effectiveness of its monopoly, with Veikkaus, the state operator, calling for an end to its monopoly since 2022. The Finnish Competition and Consumer Authority estimated that about half of the online gambling funds are spent outside this monopoly.
The implications of these findings stretch across Europe, where many state monopolies are now reconsidering their structures. Hurst referenced Italy's experience, having banned nearly all gambling advertising years ago yet still contending with a significant illegal market. The committee has suggested that in Italy, much of the remaining gambling advertising came from licensed brands utilizing loopholes rather than merely displacing their presence.
The report's examination of the industry’s statistics is also under scrutiny. The BGC projects that unlicensed operators will invest £845 million in British advertising this year, based on research from WARC, while the Gambling Commission cites its data as showing no sustained growth in illegal market engagement. Critics have voiced concerns over the report's interpretation of the evidence, arguing that it mischaracterizes the sensitivity of social science inquiries and asserts that there is no doubt that licensed operators generate the majority of advertising volume, despite earlier admissions that clear evidence was lacking.
Moreover, the report highlighted Newall's reference to displacement as "a misleading industry talking point," further echoing modeling claims from the Coalition to End Gambling Ads that a 10% reduction in gambling spending could result in an increase of £1.25 billion for the economy and create 22,000 jobs.
Waugh expressed concerns about the committee's intentions, saying, "The overall impression is that the Lords committee decided at the outset what they wanted their inquiry to find and that any impediments to this – such as issues of data reliability or the threat of increased criminality – were arguments to be overcome rather than genuine issues to be understood and addressed."
Furthermore, he criticized the report’s lack of realistic approaches to enforcement against the black market, stating it reflected aspirations without a grasp of practical challenges involved. Hurst similarly referenced Italy and the Netherlands as examples where advertising bans still coexist with significant illegal gambling markets, suggesting a total ban could minimize the advantages provided by licensed regulation.
The committee, chaired by Lord Ponsonby of Shulbrede, conducted only one evidence session and solicited written input from a relatively small selection of participants they considered "balanced." Members had conflicts of concern; for instance, Lord Smith of Hindhead presides over the Association of Conservative Clubs, which run gaming machines, while Lord Foster of Bath, acting as the former committee's chair, declared a consultancy funded by Derek Webb, who notably supports anti-gambling advertising initiatives.
The Coalition to End Gambling Ads’ director, Will Prochaska, served as a prominent witness in the inquiry. When asked how the committee weighed the evidence about the shirt ban, monopolistic evidence, and the GSGB debate, a spokesperson for the Lords asserted that a "wide range of arguments" had been reflected in the report.
