Correspondence with Everton Football Club

Request

Under the freedom of information act please can you provide me all correspondence between the Gambling Commission and Everton Football Club, between 1st February 2025 and 23rd November2025, that concerns gambling sponsorship.

Response

Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).

In your email you have requested all correspondence between the Gambling Commission and Everton Football Club, between 1 February 2025 and 23 November 2025, that concerns gambling sponsorship.

In February 2025, the Gambling Commission published a consumer information notice, advising that Stake.uk.com will no longer be a licensed website from March 2025.

In this notice, the Commission stated that it would be writing to Everton (along with two other football clubs with unlicensed sponsors) warning of the risks of promoting unlawful gambling websites.

As such, I am able to confirm that the Commission does hold information falling within the scope of your request, however, the Commission is of the view that information held in relation to specific details of information reported, other than what is made publicly available, is exempt from disclosure under section 31(1)g of the FOIA (‘law enforcement’) and therefore will not be released.

Section 31

Section 31(1)(g) exempts information whose disclosure would, or would be likely to, prejudice the exercise by any public authority of its functions for any of the purposes specified in subsection (2).

The Commission considers the subsections below apply and therefore the information is exempt from disclosure:

i. Subsection 31(2)(a) refers to the purpose of ascertaining whether any person has failed to comply with the law,

ii. Subsection 31(2)(b) refers to the purpose of ascertaining whether any person is responsible for any conduct which is improper,

iii. Subsection 31(2)(c) refers to the purpose of ascertaining whether circumstances which would justify regulatory action in pursuance of any enactment exist or may arise,

Public interest test

The factors the Commission has considered when applying the public interest test have been detailed below.

Arguments in favour of disclosure:

• The Commission is a public body which is required to regulate the gambling industry in the public interest. There is therefore a public interest in members of the public having confidence the Commission is being open and honest with the information it holds so that it can be held to account.
• Disclosure of the requested information could demonstrate to stakeholders and relevant parties the work that the Commission is undertaking in relation to the information it receives.
• Furthermore, this disclosure may encourage stakeholders to work with us and contribute to our programme of work, increasing confidence in the Commission as a regulator and its ability to uphold the law.

Arguments in favour of maintaining the exemption:

• There is an expectation of confidence in much of the Commission’s work, particularly regarding the external conversations that take place between the Commission and stakeholders, providing this information would impact on the openness of stakeholders when sharing important information with us or other law enforcement agencies. It is the impact on this work of the Commission which is more likely to be affected by disclosure.
• Sharing specific information which makes specific individuals or events identifiable could alert individuals involved to the fact that the Commission was/is or alternatively wasn’t/isn’t conducting particular regulatory enquiries. This would provide them with an opportunity to alter their behaviours or evade detection. This would result in making it more difficult for the Commission to achieve its regulatory aims.
• Further to this, sharing this information would impact on the openness of stakeholders when sharing important information with us or other law enforcement agencies. The amount of information released is carefully considered in order to protect the integrity of the Commissions regulatory work and individuals or stakeholders from being unfairly associated with unsubstantiated allegations. Disclosure of this information would be likely to lead to reluctance from stakeholders to provide information to the Commission in the future, which would have a substantial adverse effect on the Commission’s ability to carry out its regulatory functions.

Weighing the balance

The Commission acknowledges that there is a public interest in promoting the accountability and transparency of public authorities and the importance of having sufficient information in the public domain. However, disclosure of the information would be damaging to the Commission as a regulatory body which ultimately serves to protect the wider public interest. We consider that the public interest is better served by withholding this information.

Review of the decision

If you are unhappy with the service you have received in relation to your Freedom of Information request you are entitled to an internal review of our decision. You should write to FOI Team, Gambling Commission, 4th floor, Victoria Square House, Victoria Square, Birmingham, B2 4BP or by reply to this email. 

Please note, internal review requests should be made within 40 working days of the initial response. Requests made outside this timeframe will not be processed.

If you are not content with the outcome of our review, you may then apply directly to the Information Commissioner (ICO) for a decision. Generally, the ICO cannot make a decision unless you have already exhausted the review procedure provided by the Gambling Commission. 

It should be noted that if you wish to raise a complaint with the ICO about the Commission’s handling of your request for information, then you are required to do so within six weeks of receiving your final response or last substantive contact with us.

The ICO can be contacted at: The Information Commissioner’s Office (opens in a new tab), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Information Management Team
Gambling Commission

Internal Review Request

I would like to request an internal review of this decision. There is evidence in the public domain, including in this article by Philippe Auclair of the Guardian -

Premier League clubs turn to hidden gambling partners to beat sponsorship ban (opens in a new tab)

That the Gambling Commission's correspondence with Everton Football club does not concern law enforcement. Elements of the Commission's correspondence to Everton and other clubs is already in the public domain. It is clearly in the public interest for the remainder of that correspondence to be published.

Internal Review Response

I am writing to you further to your Freedom of Information request dated 24/11/2025 which we responded to on 22/12/2025, and your subsequent request for an internal review received on 22/12/205.

We have now concluded our review, and our findings are detailed below.

This internal review was conducted by someone who was not involved in the processing of your original request.

In your initial email you requested the following information:

Under the Freedom of Information Act please can you provide me all correspondence between the Gambling Commission and Everton Football Club, between 1 February 2025 and 23 November 2025, that concerns gambling sponsorship.

In our initial response we advised that in February 2025, the Gambling Commission published a consumer information notice, advising that Stake.uk.com will no longer be a licensed website from March 2025. In this notice, the Commission stated that it would be writing to Everton (along with two other football clubs with unlicensed sponsors) warning of the risks of promoting unlawful gambling websites.

As such, confirming that the Commission does hold information falling within the scope of your request. However, the Commission was of the view that information held in relation to specific details of information held was exempt from disclosure under section 31(1)g of the FOIA (‘law enforcement’) and therefore would not be released.

After reviewing your request and our response, I uphold our original decision to engage the section 31(1)g exemption. Our considerations for this decision are detailed below.

In our initial response it was sited that the subsections below applied and therefore the information was exempt from disclosure:

i. Subsection 31(2)(a) refers to the purpose of ascertaining whether any person has failed to comply with the law,

ii. Subsection 31(2)(b) refers to the purpose of ascertaining whether any person is responsible for any conduct which is improper,

iii. Subsection 31(2)(c) refers to the purpose of ascertaining whether circumstances which would justify regulatory action in pursuance of any enactment exist or may arise,

In reviewing this decision, I have considered if disclosing the requested information would, or would be likely to, prejudice any matter directly related to correspondence with Everton Football Club, or any other regulatory work by the Commission into similar matters, and would therefore engage these subsections.

The Commission is a regulatory body with licensing, compliance, and enforcement functions and through our regulatory activity, the Commission aims to protect consumers and the wider public, and to raise standards in the gambling industry.

Although the Commission does have powers to require information, the cooperation of those it regulates, and others from whom it requires information, remains essential to its ability to conduct its statutory functions. Without that cooperation the Commission is minded that its ability to obtain information and therefore to make sound regulatory decisions, based on a firm facts, would be hindered.

The use of statutory powers to obtain information can at times be unwieldly and the efficient conduct of an investigation will often depend on the voluntary cooperation of the parties involved. We recognise the value in regulatory work being conducted with the cooperation of both those who are being regulated and others with contributions to make. It is arguable that if the information provided during discussions was later made public, people may be more reluctant to volunteer information or be less candid in the responses they did provide, during future investigations.

The Commission takes steps to publish information, ensuring the transparency and accountability of its regulatory work. Specific details of correspondence between third parties does not contribute to the overall understanding of the gambling industry. We use evidence from a range of places, including various stakeholders, to build cases against gambling businesses. Information provided to us helps inform our work to raise gambling industry standards and make gambling fairer and safer.

We take care to present as much information as possible. However, we must also be careful not to reveal any information that could hinder our ability to conduct investigations or enable those we may investigate to avoid detection.

As stated in our original response, the Gambling Commission does not provide comment on any regulatory work we may or may not be undertaking, unless it is in the public interest to do so.

We acknowledge that there is a legitimate public interest in promoting the accountability and transparency of the Commission. There is a public interest in members of the public having confidence the Commission is being open and honest with the information it holds so that it can be held to account.

However, there is an expectation of confidence in much of the Commission’s work, particularly in conversations being undertaken. It is the impact on this which is more likely to be affected by disclosure.

After consideration of the above arguments, I consider that fulfilling this request would be likely to, prejudice the exercise by the Commission of its functions for any of the purposes specified in subsections (2)(a), (b) and (c). Therefore, I uphold the decision that the public interest is better served by withholding this information.

If you are not content with the outcome of your review, you may apply directly to the Information Commissioner (ICO) for a decision. Generally, the ICO cannot make a decision unless you have exhausted the complaints procedure provided by the Gambling Commission.