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Request date: 12 August 2026
This version was printed or saved on: 15 September 2026
Online version: https://www.gamblingcommission.gov.uk/about-us/freedomofinformation/powerball
1.The economics of the UK Powerball ticket
What assessment did the Commission undertake of the allocation of the balance of the £4 ticket price and the resulting return to UK good causes?
In particular, did the Commission review: the amount contributed to the international jackpot; UK lower-tier prize provision; Lottery Duty; operator and distribution costs; any MUSL, Powerball or US participation/licensing costs; and the residual contribution to UK good causes? Maximisation versus incremental contribution
The Commission's decision notice states that Powerball "could increase contributions to good causes". That appears materially different from establishing that the product maximises National Lottery net proceeds. Please explain how the Commission satisfied itself that the statutory maximisation duty was met.
Was the expected good-cause return per £1 of Powerball sales compared with the equivalent return from Lotto, EuroMillions and other National Lottery games? If so, I would ask that those comparisons be disclosed.
This appears particularly important given the scale of advertising surrounding the launch. If an existing game produces a higher return to UK good causes per £1 spent than Powerball, substitution between products could potentially reduce aggregate good-cause proceeds even if Powerball itself generates an incremental contribution.
The Multi-State Lottery Association has publicly described UK entry into Powerball as increasing the player base, accelerating jackpot growth and strengthening the long-term sustainability of Powerball. It is therefore clear that UK participation provides an economic benefit to the broader US Powerball system. That does not automatically make the arrangement inappropriate. It does, however, raise a legitimate question as to how the Commission balanced that international benefit against its specific statutory obligations relating to the UK National Lottery.
I am also concerned about whether UK participants have sufficient information to understand the economics of the game. The National Lottery has historically enjoyed a distinctive public position because players understand that participation supports good causes in the UK. When a National Lottery product now pools part of the ticket consideration with an overseas lottery, I believe participants should be able readily to understand what proportion of their £4 remains within the UK National Lottery system and what proportion reaches UK good causes.
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have referred to the Commission's published decision which states that Powerball "could increase contributions to good causes" and on that basis concluded that approval was consistent with its statutory duty.
You have requested the following information relating to whether the Commission established that the arrangement would maximise UK good-cause proceeds rather than simply increase them in absolute terms. Specifically:
Request
1.The economics of the UK Powerball ticket
What assessment did the Commission undertake of the allocation of the balance of the £4 ticket price and the resulting return to UK good causes?
In particular, did the Commission review: the amount contributed to the international jackpot; UK lower-tier prize provision; Lottery Duty; operator and distribution costs; any MUSL, Powerball or US participation/licensing costs; and the residual contribution to UK good causes? Maximisation versus incremental contribution
The Commission's decision notice states that Powerball "could increase contributions to good causes". That appears materially different from establishing that the product maximises National Lottery net proceeds. Please explain how the Commission satisfied itself that the statutory maximisation duty was met.
Was the expected good-cause return per £1 of Powerball sales compared with the equivalent return from Lotto, EuroMillions and other National Lottery games? If so, I would ask that those comparisons be disclosed.
This appears particularly important given the scale of advertising surrounding the launch. If an existing game produces a higher return to UK good causes per £1 spent than Powerball, substitution between products could potentially reduce aggregate good-cause proceeds even if Powerball itself generates an incremental contribution.
The Multi-State Lottery Association has publicly described UK entry into Powerball as increasing the player base, accelerating jackpot growth and strengthening the long-term sustainability of Powerball. It is therefore clear that UK participation provides an economic benefit to the broader US Powerball system. That does not automatically make the arrangement inappropriate. It does, however, raise a legitimate question as to how the Commission balanced that international benefit against its specific statutory obligations relating to the UK National Lottery.
I am also concerned about whether UK participants have sufficient information to understand the economics of the game. The National Lottery has historically enjoyed a distinctive public position because players understand that participation supports good causes in the UK. When a National Lottery product now pools part of the ticket consideration with an overseas lottery, I believe participants should be able readily to understand what proportion of their £4 remains within the UK National Lottery system and what proportion reaches UK good causes.
Response
Firstly, for context, it should be noted that the Gambling Commission (the Commission) is the UK's independent statutory body responsible for awarding the licence to run the National Lottery and regulating its activities to ensure safe and fair play.
As part of our responsibility as a regulator, we have three overriding statutory duties which underpin the fourth licence competition:
Under Section 11 of the National Lottery etc. Act 1993 the Secretary of State for Culture Media and Sport issues directions to us in relation to the exercise of our licensing functions, which we must comply with.
Under the Fourth National Lottery Licence, National Lottery regulation is outcomes focused. This places greater responsibility on the operator (Allwyn Entertainment Limited) to fulfil its obligations, whilst ensuring the Commission retains the ability to intervene if they do not.
As set out on the Commission’s website and in the Regulatory Handbook (available on our website), the Commission’s approach to National Lottery regulation is outcome focused under the Fourth licence, giving the Licensee greater responsibility to fulfil its obligations, whilst retaining the ability to intervene if they do not.
The new incentive mechanism ensures that the Licensee’s incentives and delivery are better aligned with contributions to Good Causes. The mechanism is structured to align the interest of Good Causes and the Licensee by ensuring that any profits made in the operation of the National Lottery are shared between the Licensee and Good Causes.
In addition, the Licensee must pay a ‘fixed contribution’ per Licence year to Good Causes. This approach enables greater flexibility for the Licensee to adapt and innovate, so long as they meet the licence obligations. We have sought to ensure the alignment continues to be achieved irrespective of changes that may arise during the Term of the Fourth Licence, including for example in relation to the range and mix of Games provided, and the relative intensity of play. The Licensee still needs to obtain our approval before launching and/or promoting new Games or Game changes during the Fourth Licence (that are not covered by its existing Section 6 Licences). However, we limit the scope of the approvals process as follows:
In-line with this approach, the Commission therefore focused on the two primary duties of propriety and Participant protection when assessing the Powerball application.
Question One - The Economics of the UK Powerball ticket
All Powerball participating lotteries contribute a fixed, non-negotiable USD amount to the shared jackpot from each ticket sale. This information was provided to the Commission by the Licensee, along with information on lower-tier prizes.
Lottery duty payable on Powerball tickets aligns to the approach for all other National Lottery Games.
The operational costs specifically associated with the running of the Powerball Game were considered by the Licensee as part of the Powerball application and appropriate assurances on the long-term strategic and commercial benefits were provided to the Commission as part of the approval process. Over 30% of the price of each ticket is returned to UK Good Causes and none of the entry price paid by UK consumers goes to US good causes.
As part of the Powerball application, the Licensee conducted research, including advice from third-party statisticians, on incremental returns to Good Causes in various scenarios. The Gambling Commission can confirm that information is held falling within the scope of your request. However, this information is exempt from disclosure as section 41 (Information provided in confidence) and 43 (Commercial interests) of the FOIA are engaged. The amount returned to UK Good Causes from each ticket sale is greater than for other games.
Question Two - Substitution and cannibalisation
We can confirm that as part of the Powerball application, the Licensee conducted quantitative research to determine likely cannibalisation of existing National Lottery Games across various scenarios, and this was factored into their assessment of returns to Good Causes. However, this information is exempt from disclosure as section 41 (Information provided in confidence) and 43 (Commercial interests) of the FOIA are engaged.
Question Three - Benefit accruing outside the UK
All Powerball participating lotteries contribute a fixed, non-negotiable USD amount to the shared jackpot from each ticket sale. Apart from this amount, all UK ticket sale monies remain in the UK. Accounting for this fixed jackpot contribution, lotteries participating in Powerball can then set their own ticket prices and lower-tier prizes.
The Licensee conducted research into UK ticket price options and the decision to set the price at £4 in the UK was a commercial decision that allowed for increased odds of winning any prize of 1 in 14 in the UK compared to about 1 in 25 in the US. The UK game features an extra ‘Match 2 main numbers’ prize tier, which is only available to UK players and offers a fixed prize of £8. The ‘Match 5 main numbers’ tier also offers a fixed prize of £1 million, while all other UK prize tiers offer estimated prizes – which vary depending on the balls drawn, the number of winners in each tier and currency exchange rates.
As part of the Powerball application, the Licensee provided information on the distribution of the ticket price via the expected prize payout percentage per prize tier. In-line with our regulatory approach set out in the Regulatory Handbook, the Commission did not assess the commercial merits in detail and focused on consideration of the volatility of lower-tier fixed prizes and the likelihood of capping and the impact this could have on Participant protection. The Licensee pays a Participation Fee to the Multi-State Lottery Association. This is calculated as a % of UK sales, up to a capped amount. This fee forms part of the operational costs of the Game, and it was therefore factored into the Licensee’s assessment of returns to Good Causes. Question Four - Transparency to participants
The Licensee must obtain the Commission’s approval before launching new Games during the Fourth Licence. The Commission’s role is to test whether the proposed game is capable of being lawfully licensed as part of the National Lottery and whether the proposed game should be licensed. The Commission therefore assessed the proposed S6 application for the Powerball game in line with our assessment framework, primarily focussing on ensuring risks to Participant protection, propriety and harm to National Lottery brand and reputation are suitably mitigated.
Other than the responses provided and addressed above, the specific data requested and clarified within your email, is considered commercially sensitive and is therefore exempt from disclosure as section 41 (Information provided in confidence) and 43 (Commercial interests) of the FOIA are engaged.
Exemptions
Our considerations for engaging these exemptions throughout your request are detailed below.
Information Provided in Confidence – Section 41
Section 41 provides an exemption under the FOIA from the right to know, where the information was provided to the public authority in confidence. Information will be covered by section 41 if:
i. it was obtained by the Commission from any other person (including another public authority),
ii. its disclosure would constitute a breach of confidence actionable by that or any other person.
When deciding if disclosure would constitute a breach of confidence, the Commission has to consider:
i. Whether the information has the quality of confidence,
ii. Whether it was imparted in circumstances imparting an obligation of confidence, and
iii. Whether disclosure would be an unauthorised use of the information to the detriment of the confider.
Section 41 is designed to give those who provide confidential information to public authorities, a degree of assurance that their confidences will continue to be respected, should the information fall within the scope of a FOIA request.
The information requested was provided to the Commission in circumstances imparting an obligation of confidence and has the necessary quality of confidence. For the avoidance of doubt, Allwyn have made clear that in their view the information was provided to the Commission on the basis that it was confidential and would remain confidential until such point as corresponding information has been made public by the operator.
Having considered your request and the information falling within scope of the request, the Commission has concluded that disclosure would constitute a breach of confidence.
The Commission considers that the public interest in disclosing this information is outweighed by the wider public interest in preserving the principle of confidentiality, and the impact that disclosure would have on third-party organisations and our working relationships.
The Commission depends and relies on the free flow of confidential information from operators that it regulates more generally to perform its statutory functions. The Commission’s ability to undertake its statutory functions would be significantly fettered if disclosure occurred.
Therefore, in light of the above, and on balance, the requested information will not be disclosed and the section 41 exemption is engaged.
Commercial Interests – Section 43
Section 43(1) provides an exemption from disclosure for information which is a trade secret. A trade secret is the property of its owner.
To be a trade secret, information should:
Based on the nature of the information requested and the definition outlined above, the Commission’s view is that this exemption is engaged. Section 43(1) is a class-based exemption and therefore there is no additional requirement to consider whether its disclosure would result in harm or prejudice, for us to engage the exemption.
Section 43(2) then exempts information whose disclosure would, or would be likely to, prejudice the commercial interests of any legal person (an individual, a company, the public authority itself or any other legal entity). A commercial interest relates to a legal person’s ability to participate competitively in a commercial activity.
The Commission views that the disclosure of this information would, or would likely to be, prejudicial to Allwyn, the Commission and / or the National Lottery itself.
The Commission considers that the public interest in disclosing this information is outweighed by the wider public interest in protecting the commercial interests of Allwyn, the Commission and the National Lottery.
Our full public interest consideration for the section 43(1) and section 43(2) exemptions is set out below.
Public interest test
The factors the Commission has considered when applying the public interest test have been detailed below and our view is that the public interest lies in favour of applying the exemption.
In favour of disclosure
The Gambling Commission is the statutory body responsible for awarding licences to run the National Lottery.
As such, there is a public interest in members of the public having confidence that the Commission and Allwyn are being open and honest with the information it holds so that we can be held to account.
It is important that the public are assured that the Commission is carrying out its functions in ensuring that the successful applicant awarded the licence to run the National Lottery and therefore providing the facility to partake in the National Lottery to the public, is upholding the statutory obligations associated with the National Lottery.
Disclosure may encourage stakeholders to work with us and contribute to this programme of work, increasing confidence in the Commission as a regulator and its ability to uphold the law.
In favour of maintaining the exemption
Disclosure of this information could create an opportunity for other market participants to adapt their future commercial behaviour and strategies on the basis of information which is not in the public domain. This could impact competitive market dynamics to the detriment of The National Lottery and consequently, negatively impact on Allwyn’s ability to meet its Good Causes forecasts.
We also consider that disclosing the information at this point in time could discourage licensees from providing information to the Commission in future, which would likely prejudice the Commission’s ability to monitor and regulate the National Lottery.
Weighing the balance
Whilst the Commission aims to be open and transparent, there is a need to preserve the confidentiality of information submitted on that basis and to be mindful of the commercial sensitivities of information that is held.
Looking at all the circumstances of the case and the nature of the request, there is more than a 50% chance that prejudice would be likely to be caused to one or more of the parties by disclosure. Public knowledge of the information requested is unlikely to contribute to a proper understanding of the performance of the National Lottery and would potentially cause prejudice to Allwyn, the Commission, and the National Lottery itself.
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