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The Commission’s approach to Artificial Intelligence

The Gambling Commission recognises that Artificial Intelligence (AI) presents an opportunity for us as an organisation, the gambling industry, gambling consumers and the public as a whole. This appendix to our corporate strategy draws on the Government’s AI Opportunities Action Plan (opens in new tab), initial guidance to regulators on Implementing the UK’s AI Regulatory Principles (opens in new tab), and the AI Playbook for the UK Government (opens in new tab) to identify the possibilities for improvement and efficiencies offered by AI, and the appropriate controls to mitigate its risks.

We welcome Government’s clear expectations that regulators should be proactive and open to AI innovation, as set out in the UK’s AI regulatory principles1. This strategy is our first step in setting out our approach to the use of AI in the gambling sector and within the Commission.

Definition

The Commission has adopted the OECD countries definition of AI (opens in new tab):

“An AI system is a machine-based system that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments. Different AI systems vary in their levels of autonomy and adaptiveness after deployment.”

Principles

As a public body, our use of AI should be underpinned by principles. There are several sets of principles laid out in government documentation, including those we should apply as a regulator to support the gambling industry innovate safely2 and those we should use to manage our own AI use as part of government and the public sector3.

We have distilled these principles to the Commission’s own set of AI principles. The Commission’s use of AI must be:

  1. Lawful, appropriately transparent, and responsible.
  2. Consistent with our licensing objectives or the principles of Managing Public Money.
  3. Subject to appropriate human intervention, governance and assurance.
  4. Used by those who have the necessary skills and expertise to apply these principles.

Risk Appetite

The Commission has adopted a low and/or minimal risk appetite in relation to the use of AI. The risk appetite is reviewed annually.

AI Areas for development

The Commission expects to encounter AI in the following ways:

  1. Understanding and regulating (where appropriate) the use of AI by the gambling industry. This means understanding how the industry we regulate is using AI to ensure it is consistent with the licensing objectives, but also maximises opportunities to enhance consumer protection. This links to our strategic objective to use data and analytics to make gambling regulation more effective.
  2. Using AI to regulate better. This means taking opportunities to use AI to enhance our abilities to undertake compliance assessments, identify breaches, target illegal gambling, and/or improve the efficiency of our regulatory processes and quality assurance for the benefit of licensees and consumers. This links to our strategic objective to enhance our core operational functions.
  3. Using AI to better understand the gambling market and consumers. This means using data science techniques to improve our understanding of the wider environment, the impact of regulation and consumer behaviour through the acquisition and analysis of datasets. This links to our strategic objective to use data and analytics to make gambling regulation more effective.
  4. Using AI to make us a more efficient organisation. This means using AI capabilities within general software packages to improve organisational efficiency and potentially generate savings. This links to the cross-cutting enablers that underpin our strategy.
  5. Using AI to enhance our service delivery. This means exploring opportunities to increase personalisation for people accessing our services and resources. This links to our strategic objective to set clear, evidence-based requirements for licensees.
  6. Hostile use of AI against the Commission or those we license. This means actively managing and mitigating risk to Commission assets and reputation arising from AI technology, and maintaining awareness of risks to licensees.

The prioritisation and development of activity within these areas will be defined through business planning processes.

Next steps

Development of policies and processes, including use case templates and appropriate governance structures to make decisions, monitor performance and provide assurance.

References

1 Implementing the UK’s AI Regulatory Principles: Initial Guidance for Regulators, Department for Science, Innovation and Technology, February 2024.
2 A pro-innovation approach to AI regulation - GOV.UK: (opens in new tab) 1. Safety, security and robustness, 2. appropriate transparency and explainability, 3. Fairness, 4. Accountability and governance, 5. Contestability and redress.
3 Artificial Intelligence Playbook for the UK Government (HTML) - GOV.UK. (opens in new tab) 1. Know what AI is and what its limitations are, 2. Use AI lawfully, ethically and responsibly, 3. Know how to use AI securely, 4. Meaningful human control at the right stage, 5. Understand how to manage the AI life cycle, 6. Use the right tool for the job, 7. Open and collaborative, 8. Work with commercial colleagues from the start, 9. Have the skills and expertise needed to implement and use AI, 10. Use these principles alongside your organisation’s policies and have the right assurance in place.

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Last updated: 5 January 2026

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