Gambling Harm—Time for Action Contents

Chapter 3: The gambling industry: structure, development and current picture

Gambling industry

89.The Gambling Commission publishes annual statistics76 on the gambling industry, which show that in the year October 2018 to September 2019:

90.The remote betting, bingo and casino sectors have 38.6% of the gambling market share in Great Britain, with a GGY of £5.51 billion (October 2018–September 2019).

Size of the sector

91.The total GGY of £14.26 billion is broken down between the sectors as follows (all figures are from October 2018 to September 2019):

Table 5: GGY by sector



Arcades (non-remote)

£0.46 billion

Betting (non-remote)

£2.81 billion

Betting (remote)

£2.12 billion

Bingo (non-remote)

£0.67 billion

Bingo (remote)

£0.20 billion

Casino (non-remote)

£1.05 billion

Casino (remote)

£3.19 billion

Lotteries (non-remote and remote)

£0.54 billion

The National Lottery (non-remote and remote)

£3.18 billion

Source: Gambling Commission, Industry statistics: April 2015 to March 2019 updated to include October 2018 to September 2019 (May 2020) p 4: [accessed 15 June 2020]

Figure 1: GGY by Sector, October 2018 to September 2019

Donut chart of percentage CGY by sector from October 2018 to September 2019

Source: Gambling Commission, Gambling Industry Statistics: April 2015 to March 2019 updated to include October 2018 to September 2019 (May 2020) p 5: [accessed 15 June 2020]

Offline gambling

92.Land-based gambling has been a form of entertainment in Great Britain for centuries, with on-course betting on horseracing becoming increasingly popular since the 1700s. As explained in Chapter 278, bingo halls, betting shops and casinos gained a foothold in Great Britain in the 1960s and are now a common sight on high streets across the country. Despite enormous changes in the ways in which people gamble, betting shops, casinos, and bingo halls are often the most visible form of gambling, and still the first that come to mind for many people.

93.Certain aspects of offline gambling are discussed in other chapters, such as bingo halls in Chapter 279 which discusses the social benefits of gambling. On-course betting at horseraces is discussed in Chapter 680 on children and young people, and in Chapter 781 on advertising. In this section we discuss other specific issues in relation to the provision of offline gambling services.

Gaming machines

94.Most gaming machines are of the reel-based type also known as fruit, slot or jackpot machines. They are divided into categories according to the maximum stake and prize available.

Table 6: Gaming machine categories


Category of machine

Maximum stake

Maximum prize


No category A machines are currently permitted

No category A machines are currently permitted



















D-on-money prize



D-non-money prize (crane grab machines only)



D-money prize



D-combined money and non-money prize


£8 (of which no more than £5 may be a money prize)

D-combined money and non-money prize (coin pusher or penny falls machines only)


£20 (of which no more than £10 may be a money prize)

Source: Gambling Commission, Guidance to licensing authorities 5th edition (September 2015) Appendix B: [accessed 26 May 2020]

95.The total GGY for machine gaming was £2.47bn from October 2018–September 2019, a decrease of 11.8% from April 2018 - March 2019. This came from 185,203 gaming machines. In 2019 the largest number of machines were found in arcades (75,564) and bingo premises (74,199). Betting shops had 32,113 machines, but analysis of GGY up until March 2019 shows that machines in betting shops consistently account for the highest share of gaming machine GGY.

Figure 2: Machines GGY by sector location

Stacked bar chart showing machine CGY by sector location Apr 2008-Mar 2009 to Apr 2018 -Mar 2019

Source: Gambling Commission, ‘Industry Statistics’: [accessed 4 June 2020]

Triennial reviews

96.Prior to the Gambling Act 2005, the government undertook a triennial review of the maximum stake and prize limits for gaming machines. The review largely focused on whether stake and prize limits should be increased in line with inflation. The last such review before the 2005 Act was in 2001. In October 2005, when the 2005 Act had been enacted but before the regulation-making powers had been brought into force, Ministers used their still extant powers under the Gaming Act 1968 to increase some of these stake and prize limits.83 In July 2007 Ministers used their powers under section 236 of the 2005 Act, which by then was in force, to make the Categories of Gaming Machines Regulations 200784 which refined the definitions of the categories of gaming machines and set fresh (and higher) maximum stakes and prize limits from 1 September 2007, the date on which the Act came fully into force. These limits were further revised for some categories (again upward) in 200985 and 2011.86

97.In January 2012 John Penrose MP, then Minister for Tourism and Heritage at the DCMS, told the House of Commons Select Committee on Culture, Media and Sport that the Government were “launching a triennial review of stakes and prizes, which has been much called for”.87 A year later, in January 2013, the Government launched The Gambling Act 2005: Triennial Review of Gaming Machine State and Prize Limits, which stated that the Government had “decided to implement a more coherent approach to stake and prize regulation based on the previous triennial review system.”88 It took advice from the Gambling Commission, which in turn took advice from the Responsible Gambling Strategy Board.89 In line with that advice, some stakes and prizes were again increased.90

98.The reintroduction of the triennial review was supported by the majority of the consultation respondents, and the Government concluded that a triennial review was still appropriate; however, it qualified this by saying that “future reviews must be informed by evidence of impact, both socially and economically, of the changes recommended as part of this review.”91

99.In October 2016 the Government published a call for evidence for a broader review of gaming machines and social responsibility. In its advice to the Gambling Commission for this review in January 2017, the Responsible Gambling Strategy Board92 was clearly under the impression that this was the next in the series of triennial reviews.93 This was not the case. The consultation was not published until October 2017, with the Government’s response then published in May 2018. The executive summary set out the Government’s “focus on reducing gambling-related harm, protecting the vulnerable and making sure that those experiencing problems are getting the help they need.”94 For the first time, the review recommended a reduction in some of the stakes.95

100.Online gambling was also considered within the review; however the Government placed the onus upon the Gambling Commission and operators to reduce the risk of harm occurring.96 We believe the Government needs to go further to address the risk of harm posed by online gambling, and the rapid development of new games and technology. Since this review concluded in 2018, there has been no further indication of when the next phase will take place.

101.We recommend that the Government should reinstate the triennial reviews of maximum stake and prize limits, and they should be extended to include both gaming machines and online gambling products. Consultation for the next review should begin before the end of this year, with conclusions drawn and action taken by the middle of 2021.

Gambling venues

102.The total number of licensed gambling premises was 9,745 in September 2019, a 12% decrease from March 2018. Of these, 7,315 were betting shops. This is the fifth consecutive year of decline in the number of betting premises, with a fall of 14.5% in betting shops between March 2018 and September 2019. It might be anticipated that the number of betting premises, particularly betting shops, will continue to fall as the reduced stake limits on FOBTs impact their revenue. The number of active casino premises is stable, with 155 in September 2019.

Table 7: Licensed Gambling Premises in GB, 2011–2019
Active Premises as at 30 September 201997




























































Year-on -year change









Source: Gambling Commission, Gambling Industry Statistics: April 2015 to March 2019 updated to include October 2018 to September 2019 (May 2020): [accessed 15 June 2020]


103.The Hippodrome Casino’s evidence emphasised that the rate of problem gambling is lower among those who gamble at casinos, with a problem gambling rate of 7.1% for table games in 2016,98 stating that “by comparison with other forms of betting and gaming, casino gambling would appear to be a middle-ranking activity in terms of problem gambling prevalence.”99 While there are no harmless forms of gambling, we agree that casinos, and particularly table games, are not the most harmful and that this is largely due to the responsible way in which they are operated, and to the fact that they are more easily regulated.

104.Simon Thomas, Chief Executive and Chairman of the Hippodrome Casino London, explained some of the features of casinos that allow gambling to be tightly controlled:

“They are purpose-built for gambling. They have the correct levels of player protection and control; if you go to the Hippodrome, it says “Casino” above the door in big letters. It is not a surprise. You go in through manned door control and are checked to see whether you are sober and old enough. We have no issues with underage gambling. You then gamble across tables with trained and licensed employees, and even on the electronic side like the slot machines, there are people monitoring them at all times.”100

105.He then described in more detail the process of monitoring customers:

“It is about keeping an eye on player behaviour. Every one of our slot machines is linked to an electronic system. The operatives have an iPad and can see the level of activity on any machine. If anybody has been on a machine for excessive amounts of time, they will have an intervention. If people have spent above a certain level, they will have an intervention. It might just be a friendly chat, perhaps with somebody they know, perhaps with somebody they do not know …

if somebody were to spend £1,500 on buy-in or win or lose, we would need full photo ID under the anti-money laundering regulations. If somebody is approaching that, we will have interventions beforehand, just to let them know that they are approaching the limit. If somebody has been on the machine for a certain amount of time—an hour or two—we will be checking on them. ”101

106.We were impressed with the mechanisms in place at the Hippodrome to ensure that gambling is undertaken in a safe environment and that those showing possible signs of problem gambling are monitored. We would like to see best practice for monitoring customers and ensuring a safe gambling environment at casinos undertaken throughout the sector. We also note that the speed of play at land-based casinos is slower than on comparable online games; this is another important element in ensuring that casinos are safer environments for gambling.

107.The Hippodrome’s evidence suggested that “a number of changes are required to gambling legislation in Great Britain.”102 One of the changes that the Hippodrome would like to see is an increase in the number of gaming machines permitted in casinos. Their evidence set out the current situation in which the majority of casinos (145 out of 152103) operating in Great Britain are restricted to 20 gaming machines, “regardless of size or the volume of customer visits.”104 These 145 casinos have preserved the entitlements of their licences originally granted under the Gaming Act 1968. However, there are seven casinos established under, and regulated by, the Gambling Act 2005, which are entitled to offer a higher number of machines. Three “small” casinos established under the 2005 Act are entitled to offer up to 80 machines, and four “large” casinos established under the 2005 Act are entitled to offer up to 150 machines. Understandably, the Hippodrome believes that all casinos in Great Britain should be regulated in the same manner and allowed the same number of gaming machines.

108.The Hippodrome emphasised that the Government had planned to use the opening of new casinos (with greater numbers of gaming machines) under the Gambling Act 2005 “as a trial for the wider modernisation of casinos regulations”105, and in July 2008 the then Parliamentary Under-Secretary for Culture, Media and Sport, Gerry Sutcliffe MP, indicated that an assessment was scheduled for 2014. So far, no such assessment has been undertaken. We therefore remain in the strange position of having the number of gaming machines in any given casino decided by the date on which it was opened, and whether it is regulated by the preserved provisions of the 1968 Act or the 2005 Act, rather than its size, number of customers or demand. We are sympathetic to the call to increase the number of gaming machines available in casinos, but believe that the Government must undertake its assessment of casinos regulations before making any changes. We believe that the Government should undertake the assessment of casino regulations which should have been undertaken in 2014, and ensure that all casinos are regulated consistently.

109.The Government should forthwith undertake the assessment of casino regulations which it promised would take place in 2014, and apply the same regulations to all casinos, regardless of when they opened.

Clustering of betting shops

110.As we have explained,106 the liberalisation of the regulation of gambling has led to an increased presence of gambling services on the high street. This followed the recommendations of the Budd report:

“As with casinos and bingo halls, we think that demand is best assessed by potential operators on commercial grounds alone. The evidence we have received suggests that the demand test is currently employed by bookmakers to drive away competition. This restricts new trade and is not good for the punter. We recommend that the demand test should be abolished for betting shops.”107

111.The demand test for betting shops, bingo halls and casinos was therefore replaced by a duty for the Gambling Commission to “aim … to permit gambling in so far as the Commission think it reasonably consistent with pursuit of the licensing objectives.”108 Section 153(2) of the Act imposes a similar duty on local authorities: “In determining whether to grant a premises licence a licensing authority may not have regard to the expected demand for the facilities which it is proposed to provide.”109

112.Allowing operators to decide “on commercial grounds alone” where to locate new betting shops has resulted in betting shops being disproportionately located in places where people can least afford to gamble: what is referred to as “clustering” or “bunching”. The Estates Gazette’s evidence showed that “more than half of the nation’s 6,000 bookies are in the UK’s most deprived areas”110, and that 56% of all the big four’s betting shops are located in the top 30% most deprived areas in England.111 78% of the stores of Paddy Power are located in the top 40% most deprived areas.112 An article published in the Estates Gazette at the same time included the chart below showing that over 20% of betting shops are located in the top 10% most deprived areas, with only 2% in the 10% least deprived areas; in between there is a direct correlation.113

Figure 3: Percentage of bookmakers located by geographical decile, as defined by the MHCLG’s index of multiple deprivation

Bar chart showing the percentage of bookmakers in areas set out by MHCLG's index of multiple deprivation

Source: James Child, ‘All bets are off on the UK’s poorest high streets’, Estates Gazette (10 July 2019): [accessed 23 April 2020]

113.Research by Landman Economics and Geofutures for the Campaign for Fairer Gambling has found a clear relationship between the extent of deprivation in local areas and the number of betting shops in those areas114. The industry is not, however, merely responding to the demand, it is to some extent driving it. Ease of access to betting shops incites and encourages gambling. This is an important social issue, and one way of alleviating the problem would be to increase the regulatory powers of local authorities. We deal with this in the following chapter.115

Lone working in betting shops

114.Dr James Banks, Reader in Criminology at Sheffield Hallam University, raised concerns about the practice of lone working in betting shops. He stated that to prevent gambling from being a source of crime or disorder (one of the licensing objectives) “I would encourage LBO [licensed betting office] operators to abolish lone working, with a view to reducing the likelihood of robbery and the risk posed to retail staff.”116

115.His evidence explained that analysis of the robberies committed in betting shops showed that although crimes were committed across betting shop opening hours, “many of the robberies took place in the evening when neighbouring shops will have closed and fewer people will be present either in the shop or the surrounding vicinity.”117 Dr Banks then stated that lone working “typically occurs in evening, but also the early morning”118, the times at which the betting shops will usually have fewest customers and when other businesses in the area will be closed. To mitigate the risks for both lone-working staff and the individual betting shops involved, Dr Banks suggested:

“… previous research has demonstrated that greater numbers of ‘frontline’ staff or the introduction of specialised security personnel into retail environments where there is only a small volume of staff can serve to reduce the occurrence of violent crime.”119

116.Similar concerns were expressed in January 2017 by the Responsible Gambling Strategy Board.120 In its advice to the Gambling Commission for the 2017 DCMS review of gaming machines and social responsibility measures, it said:

“Appropriate staffing levels are key to the detection and mitigation of harmful play. There must be serious doubt about the extent to which a single member of staff on their own in a betting shop, even at less busy times of the day or night, can simultaneously look after the counter, remain alert to the possibility of under-age play and money laundering, and still be expected to identify potentially harmful play and make appropriate interventions. The Gambling Commission should ask all operators to review safe staffing levels. Larger operators should be required specifically to address staffing levels and safety (of employees as well as players) in their annual assurance statements.”121

117.We are not aware that the Gambling Commission followed this advice, or that operators have addressed this issue. We agree that it is undesirable that a betting shop should have only one member of staff at any time, but especially in the evening, or if the lay-out of the shop does not allow one member of staff to supervise the whole premises. We have considered whether to recommend that a condition should be attached to premises’ licences requiring at least two members of staff to be present whenever the premises are open to the public. However, we have not taken evidence on this from the industry, and we recognise that this would have financial consequences, particularly for smaller operators.

118.The Gambling Commission should work with bookmakers to create a protocol to ensure adequate supervision and staffing during opening hours, taking into consideration the size, lay-out and turnover of individual premises.

Fixed Odds Betting Terminals

119.FOBTs are electronic machines in betting shops on which customers can play a variety of games, including roulette. Each machine accepts bets for amounts up to a pre-set maximum, and pays out according to fixed odds on the simulated outcomes of games.

120.Changes to the taxation of gambling with the introduction of a gross profits tax regime came into effect in October 2001, and allowed the gambling industry to introduce new, lower margin products, such as roulette, to FOBTs. By April 2005, an estimated 20,000 terminals were in use,122 and this had increased to 30,000 by the time the Gambling Act came into force in September 2007.123 The latest statistics from the Gambling Commission show that there are 23,441 FOBTs in Great Britain.124

121.Concerns were raised by treatment providers about FOBTs and the relationship between FOBTs and problem gambling, as early as 2003.125 However, it took until October 2017 for the DCMS to announce a range of proposals to strengthen protections around gambling, including lowering the maximum stake on FOBTs to between £50 and £2.126 Following a public consultation127 on the appropriate level of the new stake limits, the DCMS announced in May 2018 that the maximum stake would be lowered to £2.128

122.In October 2018, the Budget report129 stated that the reduced stake would come into effect from October 2019, and the then Chancellor of the Exchequer told the Commons Treasury Select Committee that the Government had to implement the new stake “in a way that is balanced and fair and allows for an orderly transition”. However, amendments to the Finance (No. 3) Bill to bring the implementation date forward to April 2019 attracted cross-party support.

123.In December 2018, the Gaming Machine (Miscellaneous Amendments and Revocation) Regulations 2018130 were approved by both Houses, and on 1 April 2019 the Regulations came into force and reduced the maximum stake on a single bet to £2.

124.The Gambling Commission’s latest statistics131 show that between October 2018 and September 2019, the GGY for all non-remote gaming machines fell by 11.8% compared to the previous period. This decrease was driven by the reduced stake limits on B2 machines from £100 to £2. For the whole year from October 2018 to September 2019, which included 6 months with a maximum stake of £100 and 6 months with a maximum stake of £2, the GGY on these machines fell by 46.4% compared with the last whole year with a £100 maximum stake. It can safely be said that the GGY for a whole year with a £2 maximum stake will have been more than 90% lower.

Online Gambling


125.The rapid growth and development of online gambling is one of the primary reasons that all three main UK political parties, and the Scottish National Party, undertook pledges to reform gambling legislation. The Conservative Party manifesto pledge has become a slogan for the concern that “the Gambling Act is increasingly becoming an analogue law in a digital age.”132

126.The BGC does not agree, advocating that “it is difficult to envisage any technology that the Gambling Act 2005 would fail to cover”133 under its current provisions. They, among other operators, feel that a new Gambling Bill is not needed, and sufficient powers are already granted under the Act both to the regulator and the Government.

127.Other sectors of the industry, treatment providers and charities disagree, and argue that the way we gamble has changed dramatically and the 2005 Act has not adapted to the ever-evolving technology.134 As we have explained in Chapter 2, the 2001 Budd report recommended legalising online gambling. However, Sir Alan explained to us that as UK gambling companies could not legally provide online gambling at the time of the report, it was “difficult to appreciate the scale” of online gambling as the data was “scarce”.135 As a result of this, the full extent of online gambling being carried out in Britain was not fully reported. As Mr Waugh, told us:

“The prevalence survey in 1999 recorded online gambling participation as a rounding error, substantially lower than 1% whereas in 2016 it was 9%—excluding the National Lottery online, to put in context of how little was known about it at the time of the report.”136

128.The Government accepted the Budd report’s online gambling recommendation in the 2005 Act, and subsequently the Gambling (Licensing and Advertising) Act 2014 made it a requirement that remote operators hold a licence from the Gambling Commission.137 This legislation was perceived to have “closed a significant gap” in the regulation of online gambling, “meaning [the Gambling Commission] now regulate 100% of the legal British market.” 138

129.The technology available at the time of the Budd report, and even the Gambling Act 2005, was vastly different to the technology available today:

“In 2005, it was estimated 13.9% of the world population uses the internet. In June 2019, it was estimated 58.8% of the world population now uses the internet.139 In the UK, it was estimated in June 2019 that 94.6% of the population use the internet140.”141

130.Alongside the increasing accessibility of the internet, came greater internet speed and download capability. These developments continued to enhance the advancing capabilities of online gambling.

131.Technological advances have long since gone beyond the internet, and as Sir Alan told us, in 2001, “no one had even thought about the possibility that someone might be holding something in his or her hand and be allowed to gamble freely.”142 PCs were originally used for online gambling, but then a wider range of devices became available, from laptops and tablets to smart TVs and the rapidly increasing use of mobile phones, and the accompanying gambling apps. The Gambling Commission’s Gambling Participation in 2019: behaviour, awareness and attitudes report found that 50% of those gambling online were using a mobile phone, which is up from 23% in 2015.143 As Tony Parente, one of our witnesses with lived experience, told us, now “You can gamble 24 hours a day, seven days a week, and non stop.”144

132.Other advances such as social media, artificial intelligence and cryptocurrency have also contributed to the continued development of online gambling, both in terms of what we consider gambling to be, how we gamble and how gambling is monitored. Social media has created two new pathways to gambling; the first through social media’s role in advertising, which we discuss in Chapter 7, and social gaming which we discuss below and expand upon in Chapter 6.

133.Gambling operators have been accused by former gambling industry employees of “increasingly using artificial intelligence (AI) to predict consumer habits and personalise promotions to keep gamblers hooked.”145 Where offline gambling can be largely conducted with anonymity, due to customers holding an account online, gambling operators have access to vast amounts of data regarding their customers’ age, payment history, any patterns in play and the popularity of specific products. Gambling operators apply AI in order to assist in utilising and understanding this data. This data is a significant resource and operators told us they need to “ensure … that [they] use the data that [they] have as operators in a consistent and coherent way.”146

134.As technology has advanced so has the need for expert knowledge, and throughout our inquiry witnesses expressed concern that the Gambling Commission cannot keep up with this rapid progress. Susanna Fitzgerald QC, a barrister and former trustee of GamCare, told us that “there is no way that the Commission can possibly match” the level of expertise in the industry, and “it certainly does not.”147 Neil McArthur, Chief Executive of the Gambling Commission, accepted that “the industry has many more data scientists and game designers,” but argued that the Commission can “set the exam question.”148 This implies that the Commission could use its powers to utilise the skills that the industry possesses in order to better regulate developments in online gambling technology. The National Audit Office (NAO) report in February 2020 further confirmed that the Commission is aware of a “skills gap,”149 but highlighted the constraints it is under with regard to its budget. Our support for Commission budgetary reform is highlighted in Chapter 4.150

135.This brief outline demonstrates how dramatically technology has advanced, and the difficulty but necessity of anticipating and adapting to the impact that technology has on how we gamble, what we gamble on and the gambling-related harms experienced. In a Review of Online Gambling in 2018, the Gambling Commission acknowledged that “progress by the online industry to minimise harm has been significantly slower than we expected and required.”151 The rapid developments seen to date will only continue as new technologies are developed, and we agree with Dr Steve Sharman and Professor John Turner from the University of East London when they told us, “It is essential that any new legislation includes these newer types of gambling and retains the flexibility to evolve and to keep pace with the ever changing and developing gambling industry.”152


136.Technology has prompted the need for the reassessment of regulation, but it can also be utilised by gambling operators to advance player protection. Some operators have begun to do this, and the BGC told us their members “are investing substantial resources in developing and deploying a range of harm prevention initiatives. Building on independent research, our members have developed behavioural tracking systems, designed to identify harmful play and deliver a set of tiered and tailored interactions to encourage customers to stay in control of their gambling.”153

137.Professor Raian Ali and Dr John McAlaney from Bournemouth University submitted evidence setting out how technology such as Application Programme Interface (API) could be used to provide personalised real-time data to gamblers. Their research shows if “the data could be provided in an automated, real-time manner to players, it would enable them to visualise and understand their gambling behaviour, support them with budgeting and to identify potentially harmful behaviour.”154 However, in order to be effective any such technological aid would require operators to share more data than they have historically been willing to provide.155

The range of online gambling

138.Most formerly land-based gambling products have now also transferred onto online platforms; lotteries, bingo, casino style games and poker are all played online. However, online versions of gambling products are not subject to the same physical limitations as their land-based counterparts. For example, poker played in a casino is a relatively low-frequency gambling experience, as the speed of any individual hand is limited by how fast chips can be handled and cards dealt from a physical deck. In land-based poker, players must also travel to a card room, and often wait for a seat to open up at a game, whereas in online poker each new hand can be dealt to players instantaneously, making for a faster gambling experience. Furthermore, in online poker, players can play multiple games simultaneously. The greater speed and easy availability of online gambling products is relevant given that high-frequency gambling products are generally considered to be the most harmful.156

139.Operators are also providing an increasing number of gambling activities across their platforms. For example, online poker sites now generally offer sports betting and other casino games alongside their core product of online poker, with customers able to use a single account balance across multiple forms of gambling. This is relevant to consumer protection given that problem gamblers tend to engage in multiple gambling activities.157 The number of gambling activities is ever increasing, with new online games being developed all the time.

140.Online gambling has changed how very traditional forms of gambling are conducted; in horseracing for example, online gambling “now accounts for some 65.6% of turnover, and 50.4% of gross gambling yield.”158 What was once the domain of land-based bookmakers is now moving more and more onto digital platforms. The diversity of sports and activities that can now be bet on is vast, from football, which is fast becoming synonymous with gambling, to snooker, darts and hurling all played across the world. The frequency of football betting used to be limited by the frequency of the games, which in England was typically 3pm on Saturdays. However, now a football bet can often be placed on an upcoming game, such as a Brazilian third division match or in one of the many international summer competitions. As a result, sports bets can be placed more easily and more frequently than ever before.

141.The variety of sports on which a bet can now be placed is complemented by the increasing variety of the types of bet available. One form of bet which has been referenced repeatedly throughout our evidence is in-play betting. As Professor Orford explained, this creates “multiple betting opportunities,”159 as throughout the match, race or event players can bet quickly on a variety of different aspects of the event they are watching, or even bet on “multiple events simultaneously.”160 For example, in-play bets can be placed on the identity of the next goal scorer, which can create many additional gambling opportunities across the course of a high-scoring match. Gambling advertisements for next goal scorer bets have been observed to occur frequently during live high-profile football matches,161 a type of advertising that has not been entirely eliminated by the recent whistle-to-whistle ban. We address the role of advertising and discuss the whistle-to-whistle ban further in Chapter 7. Recent statistics show that 21% of online gamblers had bet in-play in the last four weeks, which is stable based on previous figures.162

142.Another recent development in betting is the ability to create custom bets. Many of the larger gambling operators offer custom bet options, such as Sky Bet’s RequestaBet tool or Bet365’s Bet Builder. Custom bets also utilise social media, as gamblers can tweet companies with the hashtag #RequestABet, and the companies will build the bet. Dr Elliot Ludvig, Dr Philip Newall and Dr Lukasz Walasek from the University of Warwick told us their research shows “sports betting products that allow gamblers to customise their own bets are especially attractive to problem gamblers. In one recent survey, 16.0% of participants who had placed at least one custom bet were problem gamblers, compared to 6.7% who had never placed a custom bet.”163

143.In Chapter 7 we discuss concerns about the ‘gamblification’ of sport, and in particular its potential impact on young people. A form of betting which may further exacerbate the impact gambling has on children is eSports, which are the competitive playing of video games. Researchers told us: “ESports represents the largest growth opportunity for sports gambling and presents a particular worry as its players and spectators are young.”164

144.Players can bet on eSports in a traditional sense, on events occurring in the game or the outcome, but video games in recent years have also started to incorporate gambling-like features which use virtual currencies and in game items such as loot boxes and skins. This has raised concerns about what should and should not be considered gambling, and what steps should be taken in order to protect the large number of young people playing video games. As Parent Zone told us, when children and young people are using these products “they do so without the protection of regulation, and it is because regulators do not recognise their value that parents do not consider their risk.”165 This is an area of pressing concern with “the blurring of boundaries between video games and gambling activities.”166 We address the regulation of gambling-like activities in Chapter 6.

145.Virtual currencies, or cryptocurrencies, are digital currencies that are secured by data encryption, allowing currency to be transferred and transacted. Some cryptocurrencies are widely known such as Bitcoin, and social media firms like Facebook have proposed cryptocurrencies of their own. Decentralised gambling, which is also known as blockchain or crypto-gambling, is a form of gambling which uses cryptocurrency technology. As this is an emerging technology and the variety of cryptocurrencies available is increasing rapidly, this area of gambling creates another area of risk. Oliver Scholten, PhD student, Dr James Walker, lecturer in Computer Science and Dr David Zendle, lecturer in Computer Science from the University of York told us that the “online and unrestricted nature of decentralised gambling applications means that there are no theoretical limitations to the use of these gambling services by minors.”167

146.Another development which continues to create confusion about what we consider gambling to be, is social gaming. Social gaming covers the wide variety of games that are available on social media platforms. These games contain gambling-like features, such as playing with cards or dice, or slot machine style games. In January 2015 the Gambling Commission stated in its Social Gaming report that it was accepted that winning additional spins/credits/tokens/chips in these games, despite the fact they could be purchased with real money, did not amount to a prize of money or money’s worth which would bring these games under the remit of gambling legislation. The Commission stated that this was untested in the courts (which to the best of our knowledge is still the position), and they added: “… the uncertainty, and associated commercial and regulatory risk, is a useful deterrent to those thinking of pushing the boundary.” Their conclusion was that “there is no compelling reason at the moment to impose additional regulation on the social gaming sector given that it is already subject to extensive consumer protection legislation.”168

147.However, the Gambling Commission does continue to monitor social gaming in its annual participation report, and the most recent survey found 20% of respondents had taken part in social gaming, and 44% of individuals who had gambled as well as played social games said they played social games first.169

148.What we understand online gambling to be has changed dramatically, and it is imperative that the recommendations we make help protect players against the potential harms that might be felt from products that are both available now and new products which might be created in the future.

Unregulated online gambling

149.When considering online gambling, we must bear in mind online gambling sites which are unregulated in the UK. Ulrik Bengtsson, Chief Executive of William Hill, told us “the UK regulation, which broadly keeps 98% of play within the licensed regime, is very successful.”170 However, Professor Julia Hörnle, Professor of Internet Law at Queen Mary, University of London, believes “the extent of foreign unlicensed gambling by punters in Great Britain is unknown and therefore its impact (in terms of harmful effects) is unknown.”171 Nevertheless gambling operators say they remain concerned about the risk of excessively stringent regulation driving people into unregulated online markets. 172

150.The Gambling Commission, though aware of the potential risk, think “this could not possibly be an argument for lowering standards in the licensed community” and believe “there is no great sense of a burgeoning illegal market.”173

Prevalence of online gambling

151.As would be expected given the growth of this sector, the Gambling Commission’s Annual Participation Survey published in 2020 found that 21% of survey respondents had gambled online in the past four weeks, an increase from 18% in the previous year.174 The survey also found online gambling participation was higher among men than women—25% men and 17% women.175

152.Online gambling has changed how gambling activities are carried out. The table below shows how each gambling activity was accessed by survey participants, and whether they conducted the activities in person, online or both. As the table sets out, in 2019 the majority of all forms of betting were carried out online. Sports betting, football betting and betting on horseracing have all seen a decrease in the number of individuals participating in person, as opposed to online.

Table 8: Online and in person participation in the past four weeks by activity (telephone survey, n=4,003)

Online %

In person %

National Lottery draws



Another lottery






Football pools






Sports betting



Football betting



Other sports betting



Betting on other events



Casino games



Source: Gambling Commission, Gambling Participation in 2019: behaviour, awareness and attitudes, Annual report (February 2020) p 12: [accessed 6 April 2020]

153.The changing nature of how we gamble, also has an impact on where we gamble. As Figure 4 shows the majority of online gambling is carried out at home.

Figure 4: Location of online gambling in the past four weeks

A bar chart showing the different locations where respondents had gambled online. 
Home 95%
Work 15%
Commute 12%
Pub or club 7%
Sports venue 4%

Source: Gambling Commission, Gambling Participation in 2019: behaviour, awareness and attitudes, Annual report (February 2020) p 17: [accessed 6 April 2020]

154.Many forms of offline gambling are perceived as social activities, as discussed in Chapter 2; however, the fact that online gambling is largely conducted at home highlights how the online gambling sector differs from traditional forms of gambling. Michelle Singlehurst, one of our witnesses with lived experience, explained to us that one of the issues with online gambling is that it “so easy and isolating.”176 The BGC acknowledged that it “may be a reasonable assumption that a large part of gambling at home is solitary. But that does not mean that other people are not present (which may be a critical mediating factor).”177 However, as discussed in more detail in Chapter 2, Mr Cronin of Tombola, emphasised the importance of community in online bingo, particularly interactive chat communities where players can chat, interact and make friends.

155.Until the day before this report was agreed, betting shops and sports venues were still closed and there was little possibility of betting offline; for many people confined to their homes, that is still the case. Estimates of the figures will not be available for many months, but it is to be expected that there is a large though unquantified increase in online betting. When betting shops re-open and the public can again attend sports venues, there will be a resurgence of offline betting, but it remains to be seen whether the relationship between offline and online betting will be anything like it was six months ago.

Young people and online gambling

156.Online gambling has also had an impact on the numbers of young people gambling. There has been “a small, but significant increase in online gambling between 2017 and 2019; from 1% of 11–16 year olds gambling online in the past seven days in 2017 and 2018, to 3% in 2019.”178 These figures suggest more work needs to be done in order to prevent underage teenagers from gambling online.

157.CLOSER’s evidence drew on the Avon Longitudinal Study of Parents and Children (ALSPAC), which follows the lives of 14,500 people and their children. This research found that the only gambling activity which was “showing a consistent increase is online gambling and betting.”179

Online problem gambling

158.The NatCen report on gambling behaviour found the prevalence of problem gambling in online gambling or betting is 3.5%180, in comparison to the prevalence of 0.7% of problem gamblers across the population.181 The prevalence rate for online gambling on slots, casino or bingo games is considerably higher at 9.2%.182

159.We must also consider the rate of low and moderate risk gambling occurring in online gambling, as although this does not meet the threshold of problem gambling, gamblers may be experiencing lower levels of gambling-related harm. The rate of low risk gambling across any online gambling or betting is 16.1%, with the rate of moderate risk gambling at 8.4%. As we saw in the rate of problem gambling, the prevalence rates for online gambling on slots, casino or bingo games is markedly higher with 21.9% of low risk gambling and 13.7% of moderate gambling.183

160.The prevalence for low risk, moderate risk and problem gambling increases significantly if more types of gambling are participated in, and gambling is undertaken at a higher frequency.184 The Royal College of Psychiatrists told us that “problem gamblers are impulsive and need instant gratification,”185 and the vast array of products available and their 24 hours a day seven days a week availability online has the capacity to exacerbate this.

161.Dr Sharman and Professor Turner told us, “Our recent data looking at trends in treatment seeking gamblers suggests steep increases in online gambling as a clear preference for problematic behaviour.”186 The Gordon Moody Association have also found that “having engaged in online gambling prior to admission was among one of several factors that predicted an increased risk of service users leaving the treatment programme before completion.”.187 The Alberta Gambling Research Institute found that online gambling poses higher risks for harm due to its greater convenience, 24-hour access, ability to play when intoxicated, and solitary nature of play,188 and the concern is that under current regulation “online and mobile operators can develop games without controls that would help to protect the vulnerable and ensure that those games are fair and safe.”189

Building safer online gambling

162.Due to the clear and increasing prevalence of online gambling and its related harm, it is no surprise that there is continuing debate regarding the disparity found between the regulation of online gambling and that of offline gambling. Many witnesses told us that they felt online gambling was “relatively free from regulation compared with land-based gambling.”190 This begs the question: why this is the case.

163.Novomatic UK Limited told us that gaming machines are “subject to strict regulation,”191 which includes technical standards and, for some categories of machine, external testing. They argued that whereas the regulation for gaming machines prohibits a number of characteristics that encourage a player to continue gambling, such as deliberately creating a series of losing or winning games, the regulation for online games does not. And, in addition, gaming machines have limits on stakes and prizes, where online gambling does not.192 The most notable example of the implementation of limits on land-based gambling is the reduction of maximum stake limits on FOBTs from £100 to £2, as set out above.

164.There has been significant research into the various features of FOBTs which made them more appealing to users and encouraged play, in some cases, to the point of creating harm. These features are present across gambling products and are known as structural characteristics. These characteristics include:

165.We heard very convincing evidence from Dr Luke Clark, Professor in the Department of Psychology and Director of the Centre for Gambling Research at the University of British Columbia, regarding these characteristics and the research being carried out to determine their effect on behaviour. His research into near misses found that:

“gamblers typically find near misses to be exciting events that motivate continued play. With gambling machines and even scratchcards, it is quite straightforward for the game to be designed in a way that more near misses can be delivered than we would expect by chance. We have done a number of brain imaging studies in which we have seen that people with gambling problems show a stronger brain response to near misses in the parts of the reward system.”194

166.As players chase that psychological reward system response, certain game characteristics can plainly bring about damaging behavioural responses from gamblers. It is clear that game design and the application of structural characteristics play a key role in the impact different games will have and the potential harm they could create.

167.Dr Ludwig, Dr Newall and Dr Walasek pointed out since the introduction of limitations on FOBTs “the industry has an incentive to create new products which leverage similar psychological mechanisms as FOBTs, but which are sufficiently different enough to not be defined as a FOBT.”195 We agree that the regulator needs to be aware of the ever-changing techniques used in game design and new products and the potential harms that they create, in order to remain responsive and effectively regulate the online market.

168.Dr Clark brought to our attention the fact that the research on structural characteristics is limited, as “they are very difficult to study.”196 The source code involved in creating games and building in the characteristics is very complex, and without access to real games and to the code used, their impact is difficult to assess. “There are so many of these variables acting at once that the perfect research designs to figure out exactly which dimensions are most important in determining harm are very challenging.”197

169.Due to the complexity of the research in this area, Dr Clark pointed out that there is an alternative view, that the immersiveness of a game as a whole cannot be isolated to one particular characteristic.198 We are starkly aware of the complexity of determining which games pose the most risk of addictiveness, but the research available shows that there is clearly an impact on players which needs to be addressed. We have shown how long it took the Government to acknowledge the link between FOBTs and gambling-related harm; it is key that the link between game design and potential harm continues to be addressed in order to bring about change and protection for both problem gamblers and for those who will experience gambling-related harm.

170.Although difficult to study, Dr Clark made clear that as the game designers are aware of each piece of code that creates the game, and the structural characteristics included, “The industry could be mandated to share gambling products and the associated code.”199 We believe this demonstrates there is a way of creating a test for gambling products which can assess games for their addictiveness. As Josephine Holloway from Gambling with Lives told us, gambling products “need to be properly tested and given a kitemark.”200

Assessment of new games

171.Camelot told us that it has already introduced a “responsible game design process”201 to assess the risk posed by the characteristics used, such as jackpot size and speed of play. This tool, called Gamgard, was developed by Dr Richard Wood, a Chartered Psychologist, and Dr Mark Griffiths, a Chartered Psychologist and Professor of Behavioural Addiction at Nottingham Trent University. It is “based upon the known risks of specific game features for people who are vulnerable to develop gambling problems.”202

172.Under the current standards, new games are submitted to the Gambling Commission for testing,203 and the testing process is outsourced to external companies.204 Astonishingly, the testing criteria do not consider the addictiveness or potential harm that could be caused by each game; instead the weight of testing is simply to establish “fairness” to the consumer.

173.In January 2020, the Gambling Commission announced that they were establishing three working groups to tackle three key challenges faced by the industry in order to reduce gambling-related harm. One of these working groups, which will be led by SG Gaming and Playtech, is focusing on responsible product design and aims to produce an Industry Code for Product Design.205 Although this is a step forward, we believe the Commission should go further.

174.The Commission believes that “focusing on individual game design and approval would be a very significant challenge for any regulator.”206 So it would, but as things stand, “if one operator designs a new gambling product which successfully exploits problem gamblers’ biases, then this product can be mimicked by rival operators.”207

175.The gambling industry continually offers a variety of products to consumers, including some which can be highly addictive. The Gambling Commission should establish a system for testing all new games against a series of harm indicators, including their addictiveness and whether they will appeal to children. A game which scores too highly on the harm indicators must not be approved.

Online stake limits

176.Under current regulations there are no restrictions on stakes and prizes, or speed of play for online gambling. Derek Webb, the founder of the Campaign for Fairer Gambling, a group involved in lobbying for FOBT stake limit reduction, told us that “there is no justification for the same content online to not be subject to stake limits.”208 Many witnesses agreed, arguing that the fact that the implementation of stake limits has not occurred across online products demonstrates a failing in regulation and legislation.209

177.Professor Hörnle, however, told us there is a “fundamental difference” between online and offline, as “in the online world, you have so much more data and so you should and can control spending in other ways than by having a minimum in terms of the stakes.”210

178.The Gambling Commission online gambling review in 2018 echoed this view, stating:

“online operators have the ability to collect significant amounts of data on their consumers and do not have the challenge of dealing with anonymous activity as is generally the case in land-based gambling … We expect online operators to use the data available to them to identify and minimise gambling-related harm.”211

179.Some operators have already taken the decision to implement stake limits across the gambling products they offer online. Tombola has put in place a £2 maximum stake on bingo, £1 on arcade games and 40p on bingo Lite. Mr Parente told us that, as a result of this decision, Tombola “will probably not cause half as much harm as the others”212 who have not implemented limits.

180.Tombola told us they were “in favour of stake limits for machine style games online”213, suggesting that stakes across gaming machines and machine style online products could be equalised.

181.Although the various categories of gaming machine are now subject to stake and prize limits214, this was not originally the case. At their inception, FOBTs were not categorised as gaming machines as the random number generation involved happens remotely, rather than on the premises. This is despite the fact that in terms of the user’s experience, they are to all intents and purposes gaming machines. This technical distinction between categories meant that FOBTs were regulated differently.

182.Currently, there is no categorisation of the numerous online products available. If a comparison to gaming machines was utilised to establish online stake limits, there is a potential that new online products could be designed which were not considered equivalent to a gaming machine format, and so would not be subject to a prescribed stake limit. For example, a high stakes online gaming game could be devised that is technically a “betting” transaction, in order to evade an online stake limit, much in a similar way that FOBTs exploited a loophole in what products are allowed on a Licensed Betting Office (LBO) premises.

183.It is not only technical differences between offline and online games that must be considered in implementing a stake limit, but the risk of harm. Online products and the harms they create are not necessarily mirrored in the offline, land-based market. As set out in paragraph 138, the risk of harm created by the online format of a game differs to that of its offline counterpart. It may be that the risk of harm caused needs to be considered alongside any technical distinctions in online products.

184.The Gambling Commission are now clearly aware of the increasing pressure and evidence for action in this area, as on 12 February 2020 Mr McArthur gave evidence to the All-Party Parliamentary Group on Gambling Related Harm and “confirmed for the first time that the Gambling Commission would be reviewing online stakes within six months.”215 We have recommended in paragraph 101, that online stake limits are brought within the remit of the triennial review of stake and prize limits, alongside gaming machines.

185.We recommend that the Government should work with the Gambling Commission to establish a category system for online gambling products.

186.The Government and the Gambling Commission should use the online product categories to set stake limits for online gambling products.

187.The Chief Executives of the five largest gambling operators raised concerns that although gaming machines have stake limits “there is not a black market for playing these, but if you were to apply that limit online you would transfer a lot of potentially vulnerable players to offshore sites, where they cannot be protected.”216 Despite this apprehension, we have not received evidence which supports this view. We understand this concern however, we are far from convinced that this risk outweighs the need for the regulation and restriction of stake limits.

188.Alexandra Frean, the Head of Corporate Affairs at Starling Bank, told us that there “needs to be a much wider conversation between the banks”217 regarding what role they can play in assisting the Gambling Commission and customers in preventing gambling on unregulated, offshore online sites. Lloyds Banking Group informed us they had not been approached by the Gambling Commission regarding blocking unregulated, offshore gambling operators.218

189.To ensure that the implementation of online stake limits does not lead to increased unregulated offshore gambling, the Government and Gambling Commission must work with payment providers and banks to establish a scheme to block payments to such operators.

Speed of play limits

190.Associate Professor Charles Livingstone from Monash University, Australia, told us that alongside consideration of the other structural characteristics, “From a harm prevention perspective, gambling products with slower event frequencies are likely to be less addictive.”219 Speed of play is widely recognised as a factor in gambling-related harm, but as with the other structural characteristics research is limited. Despite this, it is clear that “rapid and continuous forms of gambling are often associated with gambling-related harm.”220

191.Tombola have again led the way in applying their own speed restrictions on their games:

“It is right that we run it more slowly, because it is 24-hours a day. Land-based bingo is run on a session basis of morning, afternoon and evening, whereas online it is available 24/7. We slow it down partially to slow down the rate of spend.”221

192.Further to this Tombola told us “that there is no commercial detriment to our approach: we feel that it makes our commercial model stronger because we slow down and limit the amount of spend.”222

193.We recommend the equalisation of speed of play and spin, so that no game can be played quicker online than in a casino, betting shop or bingo hall.

77 Gross Gambling Yield (GGY) is used to represent the income of a gambling operator, and is calculated by looking at the money taken in bets or stakes minus the money paid out in prizes or winnings.

78 Chapter 2, paragraphs 39–40

79 Chapter 2, paragraphs 77–78

80 Chapter 6, paragraphs 474–476

81 Chapter 7, paragraphs 519–522

82 With the option of a maximum £20,000 linked progressive jackpot on premises basis only.

83 The Gaming Machines (Maximum Prizes) Regulations 2005 (SI 2005/2775), and The Gaming Act 1968 (Variation of Monetary Limits) Order (SI 2005/2776)

84 The Categories of Gaming Machine Regulations 2007 (SI 2007/2158). For a full explanation of the changes made in 2005 and 2007 see the Department for Culture, Media and Sport, Explanatory Memorandum to the Categories of Gaming Machine Regulations 2007: [accessed 25 May 2020]

85 The Categories of Gaming Machine (Amendment) Regulations 2009 (SI 2009/1502)

86 The Categories of Gaming Machines (Amendment) Regulations 2011 (SI 2011/1711)

88 Department for Culture, Media and Sport, Gambling Act 2005: Triennial Review of Gaming Machine Stake and Prize Limits, Proposals for Changes to Maximum Stake and Prize Limits for Category B, C and D Gaming Machines (15 January 2013) p 4: [accessed 21 May 2020]

89 Now the Advisory Board for Safer Gambling.

90 The Categories of Gaming Machine (Amendment) Regulations 2014 (SI 2014/45)

91 Department for Culture, Media and Sport, Gambling Act 2005: Triennial Review of Gaming Machine Stage and Prize Limits, Government Response to Consultation on Proposals for Changes to Maximum Stake and Prize Limits for Category B, C and D Gaming Machines (October 2013) p 9: [accessed 21 May 2020]

92 Now the Advisory Board for Safer Gambling.

93 Responsible Gambling Strategy Board, Advice in relation to the DCMS review of gaming machines and social responsibility measures (31 January 2017): [accessed 23 May 2020]

94 Department for Digital, Culture, Media and Sport, Government response to the consultation on proposals for changes to Gaming Machines and Social Responsibility Measures (May 2018) p 5: [accessed 21 May 2020]

95 The Gaming Machine (Miscellaneous Amendments and Revocation) Regulations 2018 (SI 2018/1402) For a further discussion of the reduction of the maximum stake for category B2 machines from £100 to £2, see paragraphs 119–124.

97 The figures in Table 7 are for March in the given year, other than 2019 which is for September. This means that any change from 2018 to 2019 is for 18 months.

98 Written evidence from The Hippodrome Casino (GAM0070)

99 Ibid.

100 Q 89 (Simon Thomas)

101 Ibid.

102 Written evidence from The Hippodrome Casino (GAM0070)

103 Written evidence from The Hippodrome Casino (GAM0070) dated 6 September 2019, states that there are 152 casinos currently in operation. The Gambling Commission’s latest statistics on the gambling industry states that as of September 2019, there are 155 casinos in operation: Gambling Industry Statistics: April 2015 to March 2019 updated to include October 2018 to September 2019, p 8.

104 Written evidence from The Hippodrome Casino (GAM0070)

105 Ibid.

106 Chapter 2, paragraph 66

107 Gambling Review Report, para 20.13. This however is not entirely consistent with their recommendation in paragraph 21.13, to which we refer below in paragraph 259.

108 Gambling Act 2005, section 22

109 There is no similar provision in the Licensing Act 2003 in relation to the licensing of premises for the sale of alcohol. The Gambling Act 2005, section 166 exempts casino licensing from this provision.

110 Written evidence from Estates Gazette (GAM0005)

111 Ibid.

112 Ibid.

113 James Child, ‘All bets are off on the UK’s poorest high streets’, Estates Gazette (10 July 2019): [accessed 23 April 2020]

114 Written evidence from Landman Economics (GAM0039)

115 Chapter 4, paragraphs 255–261

116 Written evidence from Dr James Banks (GAM0033)

117 Ibid.

118 Ibid.

119 Ibid.

120 Now the Advisory Board for Safer Gambling.

121 Responsible Gambling Strategy Board, Advice in relation to the DCMS review of gaming machines and social responsibility measures (31 January 2017): [accessed 23 May 2020]

122 Europe Economics, Fixed Odds Betting Terminals and the Code of Practice: a report for the Association of British Bookmakers Limited: Summary Only (April 2005) para 1.2.5: [accessed 18 May 2020]

125 Joint Committee on the Draft Gambling Bill, Draft Gambling Bill (Report of Session 2003–04, HC 139-I, HL Paper 63–I) p 130

126 Department for Digital, Culture, Media and Sport, ‘Government to take action on Fixed Odds Betting Terminals’ (31 October 2017): [accessed 23 April 2020]

127 Department for Digital, Culture, Media and Sport, Consultation on proposals for changes to Gaming Machines and Social Responsibility Measures (October 2017): [accessed 23 April 2020]

128 HC Deb, 17 May 2018, cols 444–456

129 HM Treasury, Budget 2018 (October 2018): [accessed 23 April 2020]

130 The Gaming Machine (Miscellaneous Amendments and Revocation) Regulations 2018 (SI 2018/1402)

132 The Conservative and Unionist Party, The Conservative and Unionist Party Manifesto 2019: Get Brexit Done, Unleash Britain’s Potential (November 2019) p 20: [accessed 31 March 2020]

133 Written evidence from Betting and Gaming Council (GAM0068)

134 Written evidence from Gordon Moody Association (GAM0032) and BACTA (GAM0050)

135 Q 43 (Sir Alan Budd GBE)

136 Q 43 (Dan Waugh)

137 Gambling (Licensing and Advertising) Act 2014, section 1

138 Written evidence from the Gambling Commission (GAM0071)

139 Internet World Statistics, ‘Internet growth statistics’: [accessed 18 May 2020]

140 Internet World Statistics, ‘Internet in Europe Stats’: [accessed 18 May 2020]

141 Written evidence from East Riding of Yorkshire Council (GAM0028)

142 Q 43 (Sir Alan Budd GBE)

144 Q 58 (Tony Parente)

145 Mattha Busby, ‘Revealed: how bookies use AI to keep gamblers hooked’, The Guardian (30 April 2018): [accessed 13 April 2020]

146 Q 130 (Dan Taylor)

147 Q 44 (Susanna Fitzgerald QC)

148 Q 141 (Neil McArthur)

150 See our recommendation in paragraph 201.

151 Gambling Commission, Review of Online Gambling (March 2018) p 4: [accessed 13 April 2020]

152 Written evidence from Dr Steve Sharman and Professor John Turner (GAM0037)

153 Written evidence from Betting and Gaming Council (GAM0068)

154 Written evidence from Bournemouth University (GAM0001)

155 We discuss the availability of data for research in Chapter 8, paragraphs 595–598.

156 Natasha Dow Schüll, Addiction by design: Machine gambling in Las Vegas, 1st Edition (Princeton University Press, 2014)

157 Debi A LaPlante, Sarah E Nelson and Heather M Gray, ‘Breadth and depth involvement: Understanding Internet gambling involvement and its relationship to gambling problems’, Psychology of Addictive Behaviors, vol 28(2), (2014), pp 396–403: [accessed 18 May 2020]

158 Written evidence from the British Horseracing Authority (GAM0065)

159 Written evidence from Professor Jim Orford (GAM0019)

160 Written evidence from Associate Professor Charles Livingstone (GAM0108)

161 Philip Newall, Ankush Thobhani, Lukasz Walasek and Caroline Meyer, ‘Live-odds gambling advertising and consumer protection’, PLOS One, vol 14(6), (2019): [accessed 18 May 2020]

163 Written evidence from Dr Elliot Ludvig, Dr Philip Newall and Dr Lukasz Walasek (GAM0089)

164 Written evidence from Ipsos MORI, Professor Agnes Nairn and Josh Smith (GAM0069)

165 Written evidence from Parent Zone (GAM0056)

166 Joseph Macey and Juho Hamari, ‘Esports, skins and loot boxes: Participants, practices, and problematic behaviour associated with emergent forms of gambling’, New Media and Society, vol. 21 (1), (2019), pp 20–24: [accessed 13 April 2020]

167 Written evidence from Oliver Scholten, Dr James Walker and Dr David Zendle (GAM0074)

168 Gambling Commission, Social gaming (January 2015) pp 2 and 9: [accessed 15 April 2020]

170 Q 129 (Ulrik Bengtsson)

171 Written evidence from Professor Julia Hörnle (GAM0034)

172 Q 130 (John Coates)

173 Q 146 (Neil McArthur)

175 Ibid.

176 Q 58 (Michelle Singlehurst)

177 Written evidence from the Betting and Gaming Council (GAM0129)

178 Gambling Commission, Young people and gambling survey 2019, A research study among 11–16 year olds in Great Britain (October 2019) p 33: [accessed 31 March 2020]. They note that when comparing data over time it is important to bear in mind changes in methodology and sample frame, alongside adaptations to the question structure.

179 Written evidence from CLOSER, the home of longitudinal research (GAM0060)

180 NatCen Social Research prepared for the Gambling Commission, Gambling behaviour in Great Britain in 2016, evidence from England, Scotland and Wales (September 2018) p 73: [accessed 4 April 2020]

185 Written evidence from The Royal College of Psychiatrists (GAM0091)

186 Written evidence from Dr Steve Sharman and Professor John Turner (GAM0037)

187 Supplementary written evidence from the Gordon Moody Association (GAM0133)

188 Written evidence from Alberta Gambling Research Institute (GAM0017)

189 Written evidence from Gauselmann Group (GAM0096)

190 Q 43 (Sir Alan Budd GBE)

191 Written evidence from Novomatic UK Ltd (GAM0051)

192 Ibid.

193 Garry Smith, David Hodgins and Robert J Williams, Research and Measurement Issues in Gambling Studies, (New York: Elsevier, 2007), Jonathan Parke and Mark Griffiths, ‘The role of structural characteristics in gambling’, pp 211–243: [accessed 14 April 2020]

194 186 (Dr Luke Clark)

195 Written evidence from Dr Elliot Ludvig, Dr Philip Newall and Dr Lukasz Walasek (GAM0089)

196 Q 187 (Dr Luke Clark)

197 Ibid.

198 Q 196 (Dr Luke Clark)

199 Q 188 (Dr Luke Clark)

200 Q 182 (Josephine Holloway)

201 Written evidence from Camelot UK Lotteries Limited (GAM0040)

202 Ibid.

203 Gambling Commission, Remote gambling and software technical standards (June 2017): [accessed 12 April 2020]

204 Q 156 (Neil McArthur)

205 Gambling Commission, ‘Commission sets industry tough challenges to accelerate progress to raise standards and reduce gambling harm’: [accessed 12 April 2020]

206 Q 156 (Neil McArthur)

207 Written evidence from Dr Elliot Ludwig, Dr Philip Newall and Dr Lukasz Walasek (GAM0089)

208 Written evidence from Derek Webb (GAM0027)

209 Written evidence from Gauselmann Group (GAM0096) and Gambling with Lives (GAM0098)

210 Q 49 (Professor Julia Hörnle)

211 Gambling Commission, Review of online gambling (March 2018) p 4: [accessed 22 May 2020]

212 Q 63 (Tony Parente)

213 Supplementary written evidence received from Tombola (GAM0105)

215 Gambling Related Harm All Party Parliamentary Group, ‘Latest News: PRESS RELEASE: Gambling Related Harm All Party Parliamentary Group questions Neil McArthur, CEO of the Gambling Commission’ (14 February 2020): [accessed 2 April 2020]

216 Q 130 (Kenny Alexander)

217 Q 226 (Alexandra Frean)

218 Written evidence from Lloyds Banking Group (GAM0120)

219 Written evidence from Associate Professor Charles Livingstone (GAM0108)

220 Jonathan Parke, Adrian Parke and Alex Blaszczynski, prepared for the Responsible Gambling Trust, Key Issues in Product-Based Harm Minimisation: Examining theory, evidence and policy issues relevant in Great Britain (2016): [accessed 13 April 2020]

221 Q 100 (Phil Cronin)

222 Ibid.

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