The Government is reviewing the laws that regulate gambling in Great Britain. Introduced in 2005, the Gambling Act reformed how casinos, betting shops and arcades are allowed to operate and created the Gambling Commission to regulate this activity.

While there have been some changes to regulations during the intervening years, this is the most substantive review of the law since it was passed. It provides an opportunity to encourage the Government to update key areas and address where vulnerable people need better protection.

Gambling needs robust regulation. It is an industry that is predicated on the pursuit of profit paid for by customers losing. In no other industry is the purpose of customers so diametrically opposed to that of the company: the customer wants to win; the company wants them to lose. It therefore cannot be treated as just another form of recreation or entertainment. Many may choose to gamble knowing that they will lose money but do so for the thrill and the added excitement, but many customers frequently cannot afford to lose what they are gambling.

The review touches on a wide variety of gambling regulation and calls for quite detailed evidence in some areas. We would encourage you to respond on a few key issues, to which you may have relevant evidence and points to make. The areas that we would suggest you respond to are: online gambling, advertising, gambling by under-18s, and funding for research, treatment and education about problem gambling.

How to respond

To respond to the review you have to send your responses in a document format such as a PDF or MS Word. This is to be emailed to gamblingactreview@​dcms.​gov.​uk by midnight on Wednesday, 31 March.

Online gambling

With the rise of technology and smartphones, operators have a platform that allows people to gamble 24/7. More and more money is spent on online gambling and advertising each year. There have been various examples of how gambling operators have been able to undermine the intentions of the Gambling Act through features like loot boxes (consisting of randomised in-game purchases that often specifically appeal to children) and personalised email offers (that vulnerable people are particularly susceptible to). 

The first UK lockdown demonstrated the harm of online gambling as people had much more free time, and gambling operators did put extra protections in place. While we welcome widespread use of GAMSTOP (an online self-exclusion service), various studies have demonstrated it is inadequate for problem gamblers as there are ways around the system. 

Legislation is often on the backfoot, meaning the Government is being reactive instead of proactive, which is concerning given the rise of online gambling. 

We encourage you to tell the Government about how online gambling has impacted your church and your communities. In particular share stories of people who have developed gambling problems to highlight the insufficiency of current online protections. 

Advertising

Gambling advertising was widely deregulated through the 2005 Act. With our screens bombarded by gambling advertising, it seems like this change has been exploited ever since and the prevalence of gambling advertising normalised the activity. The Advertising Standards Agency (ASA) has proposed stricter rules on gambling advertising so that it does not appeal in any way to under-18s or vulnerable people. However, the prevalence of gambling advertising is becoming too big of a problem to ignore. 

The gambling industry is spending hundreds of billions of pounds on advertising (and the figures exponentially increase each year), and there is only a minute percentage of under-18s who have not seen gambling adverts (Ipsos Mori 2020). Some aspects of gambling will appeal to under-18s no matter how it is framed, as gambling often looks like a game. The sports industry is not accountable to the ASA for sponsorship deals, so a vast array of gambling advertising in sport goes unregulated, which sets a worrying precedent for children’s exposure to it. 

We are asking the Government to hold the sports industry to the same standards as other gambling advertisers, as there should not be an exemption for this industry. Children are a significant audience for sporting events, and it creates an environment where children become accustomed to gambling brands and operators. As gambling is being recognised as a significant source of harm to individuals and communities, we suggest target regulation is insufficient and gambling advertising in sport should be banned. We also recommend wider measures are considered to reduce the risk of harm (potentially as far reaching as the all-out ban on advertising in Italy in 2019).

Funding research, education and treatment into problem gambling

We are asking the Government to impose a mandatory levy on the gambling industry. The levy would require gambling operators to give a much larger percentage of their income towards gambling research, education and treatment (RET) programmes. This is one of the ways the gambling industry can mitigate the harm they’ve caused. 

Currently, the industry is operating under a voluntary levy which has proven ineffective for the societal costs (including mental health problems, family breakdown, benefits claimants, loss of life). Even this voluntary system fails to raise the recommended 0.1 per cent of gross gambling yield towards RET programmes per year (with funding often totalling less than £10m).

By 2023/24 the NHS is committing to spending £15m towards gambling-related health issues. This is only the tip of the iceberg regarding the cost of gambling to society. This review presents the opportunity to introduce a mandatory levy on the gambling industry that puts people before profit. We echo suggestions that this should be targeted at a much higher level, closer to one per cent of gross gambling yield.

Under-18s

We are asking the Government to ban the use of category D machines (such as cranes and toy capsule machines) for under-18s. The UK is the only country in Europe where it is legal for minors to gamble. This is inconsistent with the raising of the National Lottery minimum age to 18. The age of 18 has generally been considered the legal age of adulthood, where people are legally allowed to purchase alcohol and tobacco. Given the harm that gambling is known to cause, both to individuals and society, people should be of age if they are going to participate in this kind of activity. Many studies have demonstrated how early introductions to gambling creates a propensity for the activity, so it should be illegal for children to gamble in any form. 

Please contact info@​eauk.​org if you have any queries about the review or the work the Evangelical Alliance is doing in this area.