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Request date: 6 May 2026
This version was printed or saved on: 4 June 2026
Online version: https://www.gamblingcommission.gov.uk/about-us/freedomofinformation/regulatory-settlement-funding-awarded-to-gambling-with-lives
Regulatory Settlement Funding Awarded to Gambling With Lives
Request 1: Assessment of GWL's Activities Against Permitted Use Criteria
Please disclose all documentation, correspondence,assessments, minutes, and internal communications in which the Commission assessed, considered, or discussed whether GWL's activities including its lobbying and parliamentary advocacy work, its media activities, and its partnership with Leigh Day solicitors in pursuing litigation and judicial review directed at gambling operators fell within or outside the permitted use of regulatory settlement funds.
Request 2: Audit and Compliance Monitoring Framework
Please disclose:
(a) all documentation describing the audit mechanism, monitoring process, or compliance framework applied by the Commission to verify that each of the three tranches of settlement funding awarded to GWL was used for the stated and permitted purposes;
(b) any reports, reviews, or assessments produced under that framework in respect of GWL's use of the funds; and
(c) any correspondence with GWL in which the Commission sought assurances regarding, or raised concerns about, the use of settlement funds for lobbying or campaigning purposes.
Request 3: Approval Process for Each Tranche
Please disclose, in respect of each of the three funding tranches identified above:
(a) the application or proposal submitted by GWL;
(b) the Commission's internal assessment of that application;
(c) all communications within the Commission Executive Team regarding the approval decision; and
(d) all communications between the Commission and GWL in connection with the application, approval, and disbursement of funds.
Request 4: Available Penalties for Misuse of Settlement Funds
Please disclose:
(a) the Commission's published and internal policy on penalties or consequences available where a recipient of regulatory settlement funding is found to have used funds for campaigning or lobbying contrary to the permitted use conditions;
(b) whether any investigation, review, or inquiry into GWL's use of settlement funds has been initiated; and
(c) the outcome or current status of any such investigation, review, or inquiry.
If the Commission considers that complying with any part of this request would exceed the appropriate cost limit under section 12 of the Freedom of Information Act 2000, I ask that the Commission:
Identify precisely which request or requests it considers exceed the limit and provide its cost estimate for each.
Provide all information that can be disclosed within the cost limit, prioritising the most specific and bounded requests.
Provide advice and assistance under section 16 of the Act as to how I may refine any request that exceeds the limit so as to bring it within scope.
I also ask that any refusal notice under section 17 of the Act be provided in full, identifying each exemption relied upon and addressing the public interest test where applicable.
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have requested information relating to the regulatory settlement funding awarded to Gambling with Lives. Specifically:
Request 1: Assessment of GWL's Activities Against Permitted Use Criteria
Please disclose all documentation, correspondence, assessments, minutes, and internal communications in which the Commission assessed, considered, or discussed whether GWL's activities including its lobbying and parliamentary advocacy work, its media activities, and its partnership with Leigh Day solicitors in pursuing litigation and judicial review directed at gambling operators fell within or outside the permitted use of regulatory settlement funds.
Request 2: Audit and Compliance Monitoring Framework
Please disclose:
(a) all documentation describing the audit mechanism, monitoring process, or compliance framework applied by the Commission to verify that each of the three tranches of settlement funding awarded to GWL was used for the stated and permitted purposes;
(b) any reports, reviews, or assessments produced under that framework in respect of GWL's use of the funds; and
(c) any correspondence with GWL in which the Commission sought assurances regarding, or raised concerns about, the use of settlement funds for lobbying or campaigning purposes.
Request 3: Approval Process for Each Tranche
Please disclose, in respect of each of the three funding tranches identified above:
(a) the application or proposal submitted by GWL;
(b) the Commission's internal assessment of that application;
(c) all communications within the Commission Executive Team regarding the approval decision; and
(d) all communications between the Commission and GWL in connection with the application, approval, and disbursement of funds.
Request 4: Available Penalties for Misuse of Settlement Funds
Please disclose:
(a) the Commission's published and internal policy on penalties or consequences available where a recipient of regulatory settlement funding is found to have used funds for campaigning or lobbying contrary to the permitted use conditions;
(b) whether any investigation, review, or inquiry into GWL's use of settlement funds has been initiated; and
(c) the outcome or current status of any such investigation, review, or inquiry.
The Gambling Commission can confirm as follows:
Request 1 and Request 3:
When the Gambling Commission takes regulatory action against a gambling operator, an outcome of that action can include a payment in lieu of the financial penalty the Commission might otherwise impose for breach of a licence condition. This is set in accordance with the Statement of Principles for Determining Financial Penalties.
A regulatory settlement can include payment to an organisation for socially responsible purposes; the Commission reserves the power to approve the destination of monies paid as part of a regulatory settlement.
Projects that have been approved historically by the Commission are listed on our destinations of regulatory settlements to be applied for socially responsible purposes page.
The Commission can confirm that the information you are requesting in relation to the assessment of Gambling with Live’s activities against the permitted use criteria, along with the approval process for each tranche, includes application-level details of specific requests for funding. We consider that disclosing this level of detail of individual applications and our assessment of such applications to be of a commercially sensitive nature. This level of detail is not otherwise in the public domain; therefore, we are of the view that this information is exempt under Section 43 Commercial Interests.
Section 43(2) of the FOIA provides that information is exempt information if its disclosure under the FOIA would, or would be likely to, prejudice the commercial interests of any person (including the public authority holding it).
Public Interest Test
Having acknowledged that some of the information within the scope of your request is exempt from disclosure; Section 43 FOIA requires that we consider a public interest test to identify whether there is a wider public interest in fulfilling this request opposed to maintaining the exemption.
Arguments in favour of disclosure:
Arguments in favour of maintaining the exemption:
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.
Having weighed these issues, the Commission is of the view that the public interest is best served through maintaining this exemption. There is very little that providing this information would do in terms of the public interest whilst disclosure would be likely to impact on the commercial interests of the organisations.
For information, we can advise that the application and approval criteria for projects previously approved for regulatory settlement funding is set out in our guidance for submitting a proposal for regulatory settlement funding.
Request 2 and Request 4:
The Commission did not oversee the delivery of projects funded in the past through regulatory settlements, nor did it have a role in monitoring the governance of the recipient organisation. In approving destinations of regulatory settlements, the Commission considered a number of factors as set out on our website.
In particular, we considered it appropriate that the organisations who deliver the projects retain oversight and responsibility and that there was appropriate governance oversight of the organisations via their relevant standards or regulatory bodies. This avoided duplication of governance and oversight and ensured that the Commission was focussed on delivering its own regulatory roles with appropriate use of its resources. We also considered whether there would be meaningful evaluation and whether research and evaluation would be published to allow wider stakeholder review.
The Commission can therefore confirm that no information is held falling within the scope of request 2 and request 4 of your request.
Additional information
The Commission has always been clear – for example in its advice to Government on the role of a statutory levy - that it is far preferable that all research, prevention and treatment activity is funded through a statutory levy to ensure appropriate commissioning processes, avoid duplication or gaps in provision and to enable consistent evaluation processes. You may be interested to see the Commission’s advice which is published on our website.
The Commission has recently concluded a consultation on the destination of regulatory settlements that may arise in the future, taking account of the introduction of a statutory levy. We will be issuing a response to this consultation in due course, but you can access the consultation on our website in the meantime.
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