Gambling Harm—Time for Action Contents

Chapter 6: Children and young people

Young people and gambling prevalence

414.It is illegal for any child under 16 years old to take part in any form of commercial gambling, other than using Category D gaming machines. However, the Gambling Commission’s Young People and Gambling Survey 2019436 found that 11% of young people between 11–16 years old had spent their own money on a gambling activity in the seven days prior to the study. This suggests a decrease in gambling participation since 2018, when 14% indicated that they had gambled in the past week. This is consistent with the downward trend in gambling since 2011, when 23% of 11–16 year olds in England and Wales stated that they gambled. The decline in young people having gambled in the last week is reflected in the reported trends of gambling participation in the past 12 months, decreasing from 39% in 2018 to 36% in 2019.

415.The 11% of young people in 2019 who said that they had gambled in the past week equates to approximately 350,000 young people in England, Scotland and Wales. Participation in gambling remains higher among boys (13%) than girls (7%), and older children (12% of 14–16 year olds compared to 9% of 11–13 year olds). The rates of gambling in the past week (11%) are lower than drinking alcohol (16%), but higher than using e-cigarettes (7%), smoking (6%) or taking illegal drugs (5%).

416.The most common gambling activities that young people had spent their own money on in the previous week were placing a private bet for money (5%) and fruit/slot machines (4%). 3% of young people had bought a National Lottery scratchcard from a shop, played cards for money with friends or placed a bet at a betting shop. There has been a small increase in online gambling among young people from 1% in 2018 to 3% in 2019.

Table 10: Types of gambling in the past week by gender



Gambling with friends



Gambling on premises



Any National Lottery games



Any online gambling



Source: Gambling Commission, Young People and Gambling Survey 2019: a research study among 11–16 year olds in Great Britain (October 2019): [accessed 6 April 2020]

417.The first experience of gambling for most young people is playing on fruit/slot machines, which was mentioned by 23% of 11–16 year olds who have ever gambled. This is followed by placing a private bet for money (e.g. with friends), mentioned by 13% of young people.

Table 11: First gambling activity

First gambling activity

Fruit or slot machines


Placing a private bet for money


Playing cards for money with friends


Bingo somewhere other than a bingo hall


National Lottery scratchcards


Betting at a betting shop




Bingo at a bingo club


Source: Gambling Commission, Young People and Gambling Survey 2019: a research study among 11–16 year olds in Great Britain (October 2019): [accessed 6 April 2020]

418.These figures combine the proportion of young people who indicated that they gambled in the past week, and/or four weeks and/or 12 months.

Young people and problem gambling

419.The DSM-IV-MR-J screen is one of the most widely used mechanisms for identifying adolescent problem gamblers. It contains nine questions which can help to decide if an individual is a problem gambler, an at-risk gambler, or non-problem gambler437. The Gambling Commission has applied the DSM-IV-MR-J screen to the Young People and Gambling Survey dataset to assess the relationship between young people and problem gambling.

420.The Gambling Commission’s analysis438 shows that 1.7% of 11–16 year olds, which equates to 55,000 young people, are classified as problem gamblers, 2.7% as at risk gamblers, and 31.5% as non-problem gamblers. It also suggests that there is a variation by gender, with boys more likely to be defined as either problem gamblers or at-risk gamblers, than girls.

Table 12: Gambling classification by gender



Non-problem gambler

At-risk gamblers

Problem gamblers

Boys aged 11–16





Girls aged 11–16





Source: Gambling Commission, Young People and Gambling Survey 2019: a research study among 11–16 year olds in Great Britain (October 2019): [accessed 6 April 2020]

421.The analysis also shows that there is very little variation in the rates of problem and at-risk gambling, among different ages.

Table 13: Gambling classification by age



Non-problem gamblers

At-risk gamblers

Problem gambler

11–13 years





14–16 years










Source: Gambling Commission, Young People and Gambling Survey 2019: a research study among 11–16 year olds in Great Britain (October 2019): [accessed 6 April 2020]

Loot boxes

422.In video games, a loot box is a virtual item which can be redeemed to receive a further randomised virtual item, such as a customisation option for a player’s character or additional weapons and armour. Typically, players pay for the loot box itself or receive the box during the game and later buy a ‘key’ to redeem it. Dr David Zendle, lecturer in Computer Science at the University of York, referred to the Commons Digital, Culture, Media and Sport Select Committee’s definition of loot boxes as “things in video games where you are handing over money and you are getting something uncertain that is determined randomly in some way”. 439

423.This definition encompasses not only loot boxes, but also skins, player packs and all other mechanisms by which a player pays money for a randomised item. Skins are virtual items which change the appearance of the player’s character in a game, but have no impact on performance or gameplay. Skins can be purchased with real money, won during the course of playing a game, and are sometimes obtained by opening loot boxes.

424.As the quality of skins in video games improved over time, demand increased, creating a market for skins as an online currency. Players can now buy and sell skins for real money, as well as using skins as a virtual currency to gamble on other activities, such as professional video gaming, known as eSports. Using skins as a currency to gamble online is considered gambling, and is already regulated by the Gambling Commission under the Gambling Act 2005. The regulation of skins gambling has no impact on skins in video games, it is still possible for players to purchase skins with real money, obtain them by opening loot boxes, or win them while playing a game. Any reference to skins in this report refers to skins as an element in video games, not skins gambling.

425.In this chapter, ‘loot boxes’ will be used to refer to all mechanisms by which a player pays money for a randomised item.

426.Loot boxes have been a feature of video games since the early 2010s, but came to prominence with the release of Star Wars Battlefront 2 in November 2017. This game was subject to widespread criticism440 as some of the main characters in the franchise were not automatically available, but had to be purchased in-game with real money or purchased with in-game currency earned by playing the game for a prolonged period.

427.In April 2018, the Belgian Gaming Commission concluded that loot boxes met the legislative definition of a “game of chance”, and are therefore a form of gambling and illegal under Belgian law441. The director of the Gaming Commission, Peter Naessens, stated:

“Paying loot boxes are no innocent component of video games which present themselves as a game of skill. Players are tempted and misled by them and none of the protective measures for games of chance are applied. Now that it has become clear that children and vulnerable persons in particular are being exposed to this without any protection, the game producers, and also the parties involved, are called upon to put a stop to this practice.” 442

428.In April 2018, the Netherlands Gaming Authority declared that some loot boxes would be classed as legal and others as illegal, depending on whether the content was transferable443. It stated that loot boxes where the content was non-transferable were seen as games, and therefore legal, while loot boxes where the content was transferable were seen as gambling, and therefore illegal.

429.As mentioned in Chapter 3444 when considering online gambling, another development that blurs the boundaries between video gaming and gambling is social gaming. Traditionally, social gaming was used to refer to video games that allow or require social interaction between players, rather than games played in solitude. Over time social gaming has become the term to describe games played on online social media platforms, often with other players. Some social games include gambling-like features such as playing with cards or dice, or slot machine style games.

430.The Gambling Commission explained that:

“Some of the games you can play online might look like gambling but do not meet the legal definition. They may involve a game of chance for a prize and may use gambling mechanics such as cards or dice but, crucially from a narrow legal perspective, if the prize is not money or money’s worth, they are not gambling under UK legislation.”445

431.The Commission commissioned a scoping review of social gaming to assess the potential risks. Based on this review, it concluded that there was no “persuasive case”446 to move from its present position of keeping a ‘watching brief’ on social gaming. The Commission gave two reasons for this decision:

“While the data suggests that, in general, the vast majority of people who play social games spend very modest amounts of time and money, there is clearly a very small group who spend significant amounts. However, it is likely that this group is not sufficiently large to justify any form of additional regulatory intervention.

While playing social games does not appear to be harmful in itself (for the vast majority of players) we are much less clear on whether in some circumstances it leads on to, or causes, more harmful behaviours.”447

Loot boxes and problem gambling

432.Dr Zendle’s written evidence448 referred to his research which shows that loot box spending is linked to problem gambling in both adults and adolescents. Dr Zendle has undertaken various studies which found that spending money on loot boxes is linked to problem gambling, and that the more money individuals spent on loot boxes, the more severe their problem gambling. Dr Zendle emphasised that “in every single one” 449 of these studies, there was a link between spending on loot boxes and problem gambling. Moreover, “all effects observed were of a clinically important magnitude.” 450 Dr Zendle expanded on this point in oral evidence, stating that the link between problem gambling and loot boxes is “extraordinarily robust. It is of a magnitude that is uncommon in the social sciences. You see it every time you measure how much people are spending on loot boxes and their problem gambling. It has been replicated across the world, from Canada to Finland to the UK”.451 These observed links between loot box spending and problem gambling were much stronger in adolescents than adults.

433.Dr Zendle’s research suggests that either loot boxes cause problem gambling, or they exploit problem gambling among gamers to generate profits:

“It may be the case that these things are linked because spending on loot boxes causes problem gambling. This is a credible explanation because loot boxes are very similar in many ways to gambling, and therefore may provide a gateway to it. However, it may alternatively be the case that this relationship exists because people who already have gambling problems are drawn to spend significantly more on loot boxes. This also makes sense. Problem gambling is characterised by uncontrolled excessive spending on gambling. Loot boxes share many similarities with gambling. It therefore makes sense that this uncontrolled spending may transfer to loot boxes too.” 452

434.In oral evidence, Dr Zendle explained that some more recent research “found that young people who spend money on loot boxes are more than 10 times as likely to be problem gamblers than those who do not”.453 However, Dr Zendle also emphasised that the research does not show that loot boxes are a gateway into gambling, just that the two coincide.

435.Dr Zendle suggested that as loot boxes share many features with gambling, and that spending on loot boxes is linked to problem gambling in both adults and children, they should be regulated. He explained:

“The ideal thing to have happened would have been industry self-regulation. It would have been some sort of big commitment from the video games industry to find out what is happening and do something about it. That has not happened. Therefore, I am not against the proposals… that some form of regulation external to the games industry is necessary.” 454

436.Concerns about the relationship between loot boxes and problem gambling have also been raised by organisations working with children and young people. In October 2019, the Children’s Commissioner published a report Gaming the System, 455 which looked at the relationship between video gaming and children. The report raised concerns about loot boxes specifically, as well as the wider role that money plays in video games.

437.The Children’s Commissioner’s report made various recommendations about limiting the role of money in video games aimed at children, such as introducing maximum daily spend limits and introducing features to allow players to track their historic spend. The report also made specific recommendations to ensure that loot boxes would be regulated as a form of gambling:

“The Government should take immediate action to amend the definition of gaming in section 6 of the Gambling Act 2005 to regulate loot boxes as gambling.

The Government must also undertake a wider review into the current definition of gambling in the Gambling Act, to ensure that it accurately reflects new forms of gambling, including those forms found in online games.” 456

438.Simone Vibert, the Senior Policy and Public Affairs Analyst from the Children’s Commissioner’s Office, explained the importance of children’s perceptions of loot boxes. She said that the most important point to come out of the Commissioner’s research was that children themselves describe buying loot boxes as a form of gambling, without being prompted. As a result, the Children’s Commissioner believed that loot boxes should be treated as a gambling product “If it looks like gambling and it feels like gambling in children’s eyes, our message is very simple: that it should be regulated and recognised as such.” 457

439.Ms Vibert also explained in more detail the Commissioner’s concerns about the Gambling Act, and how its definitions fail to reflect the way in which children are thinking about video gaming and gambling:

“In our view, the fundamental stumbling block here is the Gambling Act’s definition of gambling. In particular, the definition of a prize, “money or money’s worth”, does not reflect the way children spend and, in our eyes, gamble money online. Some of these items in games do not have monetary value. Some of them do because you can trade them illegally on other sites, but let us park that for now. They have immense value to the children who are spending money to get them, whether that is to take part in the game all their friends are playing or whether it is to not be bullied, in some cases. That is where we feel the Gambling Act is not working in the way it should in the modern world.” 458

440.While witnesses, including Dr Zendle and Ms Vibert, emphasised the need to regulate loot boxes, the Gambling Commission was rather more hesitant about bringing such products into its remit. Mr McArthur stated that he was concerned about the “blurring of the lines” 459 between gambling and video gaming, and that some video games “look and feel like gambling, but are not”.460 However, Mr McArthur refused to comment on any possible legislative amendment to bring loot boxes within the remit of the Gambling Commission, merely stating that “a change of the law is a matter for Parliament. If that decision was taken, we would regulate it.” 461

441.Mr McArthur described various options for dealing with loot boxes: “One possibility is the Gambling Commission regulating this; one is these products not existing; one is somebody else regulating it.” 462 However he seemed reluctant to see the Gambling Commission taking on the regulation of loot boxes and told us “I am not making a land grab to regulate the gaming industry. I would rather they stayed away from the perimeter in the first place.” 463

442.The Government’s evidence stated that its review of the Gambling Act 2005 would “focus on issues around loot boxes464”. While we welcome the Government’s intention to consider the relationship between gambling and video gaming, we believe that this issue requires more urgent attention. The Government emphasises that “it is important that gambling legislation is applied to activities in a proportionate manner, and any changes should be informed by evidence and after a full consideration of the unintended consequences that may result465”. We agree that it is vital that any legislative changes are based on evidence; the evidence we have heard has stressed the urgency of taking action, and has not drawn attention to any unintended consequences.

443.The House of Commons Digital, Culture, Media and Sport Committee’s report on Immersive and Addictive Technologies466 recommended that the Government should bring forward regulations under section 6 of the Gambling Act 2005 to specify that loot boxes are a game of chance. The Government’s response467 to the report, published in June 2020, stated that to support the review of the Gambling Act 2005, the Government will be launching a call for evidence on loot boxes. The call for evidence will examine:

“The size and variation of the market, the design of mechanisms, the context in terms of other types of in-game spending, the impact on consumers and particularly young people including links to problem gambling, and the effectiveness of the current statutory and voluntary regulation.”468

444.The Government’s response emphasises that the results from the call for evidence will be considered alongside the review of the Gambling Act 2005, and “the Government stands ready to take action should the outcomes of the call for evidence support taking a new approach to ensure users, and particularly young people, are protected”.469

445.There is academic research which proves that there is a connection, though not necessarily a causal link, between loot box spending and problem gambling. We echo the conclusions of the Children’s Commissioner’s report, that if a product looks like gambling and feels like gambling, it should be regulated as gambling. We also agree with the House of Commons Digital, Culture, Media and Sport Committee’s recommendation that loot boxes should be regulated as a game of chance.

446.We recommend that Ministers should make regulations under section 6(6) of the Gambling Act 2005 specifying that loot boxes and any other similar games are games of chance, without waiting for the Government’s wider review of the Gambling Act.

Redefining gambling

447.As stated above470, loot boxes first appeared in video games in the early 2010s, and despite growing concerns about their impact on children and young people, action has yet to be taken to regulate them in Great Britain. It is crucial that any future developments in gambling, video gaming or other products that may contain gambling-like elements, which would not currently fall within the definition of gambling, should be brought within the remit of the Gambling Act as they appear. It is too late to regulate a product as gambling, when it has already caused harm to children and young people. Neither the Government nor the Gambling Commission can afford to wait years before bringing new ‘gambling-like’ products within the remit of the Act.

448.The recommendation above will deal with the immediate issue of loot boxes, but gambling operators or gaming companies may develop new products which blur the distinction between video gaming and gambling. If these products cannot be brought within the legislative definition of a ‘game of chance’, they will not be regulated as gambling. Children and young people should be protected from all gambling and gambling-like products, not merely those that can be defined as a ‘game of chance’. To ensure that all future gambling-like products are regulated as gambling, Ministers must have a power analogous to section 6(6) of the Act to specify that any activity which has the characteristics of gambling, even if not similar to a game of chance, should be brought within the purview of the Act.

449.We recommend that section 3 of the Gambling Act 2005 should be amended to give Ministers a power, analogous to that in section 6(6), to specify by regulations that any activity which in their view has the characteristics of gambling should be treated as gambling for the purposes of the Act.

Underage gambling and problem gambling

450.We received conflicting evidence about the links between early-onset gambling and problem gambling. In oral evidence in September 2019 Mr Waugh stated:

“I think it was a finding from the British Gambling Prevalence Survey that problem gamblers have, on average, an age of initiation in gambling about two years younger than non-problem gamblers, so we ought to be concerned about youth gambling not simply for what happens to children when they are children but what happens when they grow up.” 471

451.The British Gambling Prevalence Study also found that problem gambling prevalence was significantly higher among those who reported that they were 15 or under the first time that they ever gambled (1.6%) than those who were 22 or over (0.6%).472 However, Mr Waugh also referred to research that questioned the link between childhood gambling and problem gambling:

“There was one study in 2011 around problem gambling among adolescents in Great Britain by Professors Forrest and McHale. They looked at whether there was any correlation between problem gambling among children and seaside towns and they found no correlation. They found if you lived in a seaside town, children were more likely to gamble but not any more likely to be problem gamblers.” 473

452.John White, Chief Executive of BACTA, also questioned the evidence for believing that there is a link between early-onset gambling and problem gambling:

“Your next question was about the association between gambling when you are young and potential problems later on in life… I do not think the evidence is as clear as people have suggested on that. Some of the longitudinal studies say that people come in and come out… I do not think the evidence is quite as clear-cut as might be suggested.”474

453.We note the lack of consensus in the academic research about a link between early-onset gambling and problem gambling in later life, but we ourselves heard of the repeated experiences of families whose sons started gambling underage and subsequently took their own lives. The families were from different areas of the country, different socio-economic backgrounds, with sons who died at different stages of life, but they were all united by the fact that their sons had started to gamble underage. Charles Ritchie told us: “That is pretty much the case for all the Gambling with Lives families. Most people we have come across who have developed a gambling disorder generally started very young, certainly under 18.”475 This correlation cannot be ignored until the academic research is unequivocal. Stronger enforcement action is required to ensure that young people cannot gamble underage.

454.The Gambling Commission and local trading standards officers should undertake regular age test purchases and visits in all land-based gambling venues such as betting shops, amusement arcades and National Lottery retailers, and develop an appropriate age testing scheme for online gambling operators.

Minimum age for gambling

455.Most commercial gambling in Great Britain is legal only for those aged 18 and over. However, there are two exceptions:

National Lottery

456.In July 2019, the UK Government launched a consultation476 seeking views on whether the minimum age for some, or all, National Lottery games and products should be increased from 16 to 18.

457.The consultation asked for views on three possible options:

458.At the time, the then Minister for Sport and Civil Society, Mims Davies MP, said: “ … we also need to make sure that the National Lottery is fair and safe. That is why we are looking to raise the minimum age for instant win games so children and young people are protected … ”478

459.The written evidence we received was unequivocal in recommending that the minimum age for playing all National Lottery products should be increased from 16 to 18. Dr Frank Atherton, Chief Medical Officer for Wales, stated that “the age of national lottery participation should be increased from 16 to 18 year olds”479, while the European Lotto Betting Association emphasised that its members believe “that the legal age for access to all forms of commercial gambling should be 18”480 and these restrictions should also apply to National Lottery products. Professor Orford noted that “consideration should be given to having a minimum age of 18 years for all gambling”481 and the Royal College of Psychiatrists stated that “young people between 16 and 18 should not be able to purchase National Lottery products”.482

460.Even Camelot had no opposition, with Nigel Railton, the Chief Executive of Camelot stating:

“To be honest with you, we are reasonably relaxed about it. For 25 years the age has been 16 so it is probably a good time to look at it. We do not have that many people playing at 16 or 17 online … Our position is that it is ultimately a matter for Government and if Government want to raise the age to 18, we will support that.”483

461.The minimum age at which an individual can buy any National Lottery product should be raised to 18.

Category D gaming machines

462.In evidence given to us, Sir Alan Budd discussed the UK’s anomalous position in allowing children to play certain types of gaming machines, and stated that “the Review Body spent a long time discussing this specific issue because we were aware that nowhere else in the western world were children allowed to play on gaming machines.” 484 There are many countries that prohibit gambling below the age of 18, including Italy, Germany, Portugal, and Denmark.

463.BACTA’s evidence argued that “the legal availability of certain forms of commercial gambling is not unusual by international standards” 485 and that “penny fall machines can be found across the globe”. However, as described below, the concerns about Category D gaming machines centre on fruit machines, rather than penny fall machines or cranes.

464.Research by Dr Wardle486 showed that in 2017 an increasing proportion of children who gamble did so on fruit machines, with 40% gambling on fruit machines in 2017, compared to 23% in 2011. Research published by Cardiff University in October 2019 also emphasised the popularity of fruit machines among children:

“The gambling activity most frequently reported was fruit/slot machines… This may be particularly problematic given their availability and potential to become habitual due to high operant conditioning processes, high event frequencies, near miss opportunities and short intervals to pay out.” 487

465.Dr Philip Newall and colleagues488 investigated links between recollected usage of legal gambling under the age of 18 and current problem gambling symptoms among a group of British gamblers aged 18 to 40.489 This research found that adult gamblers with more problem gambling symptoms tended to have engaged more often with Category D fruit machines (when aged below 18), and the National Lottery and National Lottery scratchcards (when aged 16 or 17). While this does not show a causal link between the use of these products and later life outcomes, the research does indicate that the children who tend to use these gambling products frequently are more likely to become problem gamblers as adults.

466.These concerns about fruit machines and childhood gambling are not confined to academic research. Three of our four witnesses with lived experience explained how fruit machines had played a part in introducing them to gambling. Owen Baily, one of our witnesses with lived experience, stated: “When I look back at my entry point to gambling, on reflection, I developed a very unhealthy attachment to a fruit machine, which grew and developed.”490 Tony Parente, another lived experience witness, also pointed to fruit machines as a gateway into gambling: “When I was 17 or 18, I slowly started on the fruit machines in pubs and service stations,”491 As did Alex Macey:

“I live in a seaside resort, and probably at age 10 I started to go into town with friends on the weekend and into the arcades—there were plenty of them, and still are. My friends would go on the normal games, perhaps putting a little bit of money in a fruit machine, but I was compelled to lose everything on the fruit machines.”492

467.The Gambling Commission’s evidence also raised concerns about Category D machines:

“The Commission does have concerns about Category D fruit machines which are typically found in premises catering for children and young people—it is confusing for children and parents when products for children look and feel exactly like those which are limited to adults, and we do not know enough about the long-term impacts.”493

468.The European Lotto Betting Association’s written evidence goes further than merely raising concerns about Category D gaming machines, it suggests that children should not have access to “any type of gambling products regardless of their perceived risk profile494.” It goes on to state that “Category D games machines could act as gateway gambling products for young children.”495

469.BACTA responded to some of these concerns about children accessing Category D gaming machines, with Mr White explaining that the Category D fruit machines in arcades are there “for the adult members of the family”496 and that Category D machines at the seaside should be “legally able to be in the same room as the other machines”497 that children use. Mr White acknowledged that it is “undoubtedly a fact that for some of the people you have had before this Committee that their gambling problems are associated with their early exposure to gambling. ”498 He suggested that “the vast majority of people have very similar or the same experiences and do not end up with the same issues.”499

470.BACTA also emphasised the likely impact of banning children from playing Category D machines on seaside arcades, and on the wider economy of seaside towns:

“[ … ] these types of games formed the backbone of Britain’s family seaside arcades. We know from our PWC report that approaching a third of the British population enjoys visiting these arcades each year. They provide local jobs and economic activity in towns up and down the country that have little in the way of other economic activity. Without them these towns would fall into further decline… the private investment provided by seaside amusement arcade operators has added considerably to the amenity value of towns up and down the country. It is also true that it is the income from the seaside arcades that keeps Britain’s Piers from falling into the sea.”500

471.We acknowledge that allowing children to play on Category D machines in Britain is an international anomaly, and that if we were starting from scratch in creating a new gambling industry it is unlikely that children would be allowed to play on such machines. However, we are considering the gambling industry as it is, and as it has been in Britain, and as BACTA has explained, family amusement arcades are an integral part of seaside resorts. Banning children from playing on Category D machines could well have a devastating impact on individuals, businesses and communities501.

472.We heard powerful evidence from those with lived experience that they initially started gambling on fruit machines as children, before developing severe gambling issues. We cannot deny that historically fruit machines have been a gateway for some children into gambling, and ultimately, problem gambling. However, as gambling practices have changed, particularly with the massive growth in online gambling and video games with gambling-like elements, we must ensure that we are tackling the current gateways into gambling for children and young people, not those of 10, 15 or 20 years ago.

473.The minimum age at which an individual can take part in any online gambling should be raised to 18.

Children at racecourses

474.On-course bookmakers at racecourses have historically performed badly at age verification checks and have allowed underage customers to place bets. In July 2019 the Gambling Commission announced that seven bookmakers were having their licences reviewed after allowing a 16-year old to place a bet at Royal Ascot.502 Officers from the Royal Borough of Windsor and Maidenhead, alongside the Gambling Commission and Trading Standards, conducted age verification test purchases at Royal Ascot. Of the 17 bookmakers tested, seven allowed a 16-year old to place a £5 bet.

475.Richard Watson, Executive Director of the Gambling Commission, stated that:

“Despite various educational attempts to raise standards, by ourselves and the trade bodies, the on-course sector has historically performed poorly in both underage gambling test purchase exercises and Think 21 testing. Pass rates have failed to meet the standards expected and the sector has consistently performed to levels below those we see in other gambling and age restricted products. By way of example, over the past four years, the on-course sector has a pass rate of around 35% for Think 21 testing.”503

476.During a similar test purchasing exercise at Royal Ascot in 2014, all bookmakers tested allowed a 16 year old to place a bet, without asking for proof of age.504

477.The Gambling Commission and local trading standards officers should undertake more frequent age verification tests, and should do so at all racecourses across the country, not merely at large meetings. The Gambling Commission should use the full range of enforcement action available to it, including large fines, licence reviews and revocation for those bookmakers repeatedly allowing underage individuals to place a bet.

437 The individual is asked whether they undertake nine particular behaviours or actions ‘never’, ‘once or twice’, ‘sometimes’ or ‘often’. The individual will score a point for each of the nine criteria that they meet. If the individual has undertaken four or more of the behaviours listed, they receive a score of four or more and will be classified as a ‘problem gambler’. A score or two or three identified the individual as an ‘at-risk gambler’, and a score of zero or one indicates a ‘non-problem gambler’.

439 Q 199 (Dr David Zendle)

440 ‘Star Wars Battlefront II game faces further backlash’, BBC News (15 November 2017): [accessed 16 April 2020]

441 Belgian Gaming Commission, ‘Belgian Gaming Commission rules after analysis: “Paying loot boxes are games of chance”’: [accessed 16 April 2020]

442 Ibid.

443 Netherlands Gaming Authority, A study by the Netherlands Gaming Authority has shown: Certain loot boxes contravene gaming laws (19 April 2018): [accessed 16 April 2020]

444 Chapter 3, paragraphs 146–147

445 Gambling Commission, ‘Social Gaming’: [accessed 22 April 2020]

446 Ibid.

447 Ibid.

448 Written evidence from Dr David Zendle (GAM0022)

449 Ibid.

450 Ibid.

451 Q 199 (Dr David Zendle)

452 Written evidence from Dr David Zendle (GAM0022)

453 Q 199 (Dr David Zendle)

454 Ibid.

455 Children’s Commissioner, Gaming the System (October 2019): [accessed 14 April 2020]

456 Ibid.

457 Q 200 (Simone Vibert)

458 Q 202 (Simone Vibert)

459 Q 158 (Neil McArthur)

460 Ibid.

461 Q 159 (Neil McArthur)

462 Ibid.

463 Ibid.

464 Supplementary written evidence from HM Government (GAM0135)

465 Ibid.

466 Digital, Culture, Media and Sport Committee, Immersive and addictive technologies (Fifteenth Report, Session 2017–19, HC 1846)

467 HM Government, Government Response to the Digital, Culture, Media and Sport Select Committee Report on Immersive and Addictive Technologies (June 2020):–001_Gov_Resp_DCMS_Committee_Report_CP_241_Web_Accessible__1___1_.pdf [accessed 8 June 2020]

469 Ibid.

470 See paragraph 426.

471 Q 39 (Dan Waugh)

472 NatCen Social Research prepared for the Gambling Commission, British Gambling Prevalence Survey 2010 (2011): [accessed 15 April 2020]

473 Q 39 (Dan Waugh)

474 Q 81 (John White)

475 Q 174 (Charles Ritchie)

476 Department for Digital, Culture, Media & Sport, ‘Consultation on the minimum age for playing National Lottery games’, 16 July 2019: [accessed 16 April 2020]

477 Ibid.

478 Department for Digital, Culture, Media & Sport, ‘National Lottery scratchcard minimum age could be increased to 18’, 16 July 2019: [accessed 16 April 2020]

479 Written evidence from Dr Frank Atherton, Chief Medical Officer for Wales (GAM0006)

480 Written evidence from the European Lotto Betting Association (GAM0007)

481 Written evidence from Professor Jim Orford (GAM0019)

482 Written evidence from the Royal College of Psychiatrists (GAM0091)

483 Q 120 (Nigel Railton)

484 39 (Sir Alan Budd GBE)

485 Written evidence from BACTA (GAM0050)

486 London School of Hygiene & Tropical Medicine, Trends in Children’s Gambling 2011–2017:–2017.pdf [accessed 16 April 2020]

487 G J Melendez-Torres, Rebecca Anthony, Gillian Hewitt, Simon Murphy and Graham Moore, ‘Prevalence of gambling behaviours and their associations with socio-emotional harm among 11–16 year olds in Wales: findings from the School Health Research Network survey’, European Journal of Public Health, ckz176, (3 October 2019): [accessed 11 June 2020]

488 Dr Alex Russell, Dr Steve Sharman and Dr Lukasz Walasek

489 Philip Newall, Alex Russell, Steve Sharman, Lukasz Walasek, ‘Frequency of engagement with legal UK youth gambling products is associated with adult disordered gambling’, PsyArXiv, (March 2020): [accessed 16 June 2020]

490 Q 51 (Owen Baily)

491 Q 52 (Tony Parente)

492 Q 52 (Alex Macey)

493 Written evidence from the Gambling Commission (GAM0071)

494 Written evidence from the European Lotto Betting Association (GAM0007)

495 Ibid.

496 Q 81 (John White)

497 Ibid.

498 Ibid.

499 Ibid.

500 Written evidence from BACTA (GAM0050)

501 The report of the Select Committee on Regenerating Seaside Towns and Communities, The future of seaside towns (Report of Session 2017–19, HL Paper 320) discusses in greater detail the economic links between seaside communities and seaside amusement arcades.

502 Gambling Commission, ‘On course bookies face licence reviews’: [accessed 16 April 2020]

503 Ibid.

504 Gambling Commission, ‘Twenty bookmakers at Ascot allowed 16-year-old to bet: operators warned they must improve underage gambling controls’: [accessed 16 April 2020]

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