How we embed vulnerability within our regulatory approach
General principles
Our Statement of principles for licensing and regulation specifies that the Gambling Commission expects licensees to, amongst other things:
- conduct their business with integrity
- act with due care, skill, and diligence
- have due regard to the information needs of consumers and communicate with them in a way that is clear, not misleading, and allows them to make a properly informed judgment about whether to gamble.
To embed these principles, the Gambling Commission builds consideration of vulnerability into regulatory measures that apply at each stage of the customer journey or the Path to Play framework.
The intention of the Path to Play framework is to explore this journey specifically from the gambler’s perspective, which may be different to a gambling business or regulator’s perspective. This will allow us to better understand how consumers experience gambling, what factors influence them, where there may be greater risks for some gamblers, and identify opportunities for intervention. It builds on our earlier work to understand why people gamble and typologies, and our wider Consumer Voice research.
Examples of building vulnerability into regulatory measures
Some key examples of building vulnerability into regulatory measures are as follows.
Children, young people and young adults
We set requirements relating to age verification and test purchasing which uphold the legal age of gambling, and we consider the role of additional protections for young adults.
Advertising and marketing
We work with government and other regulators to reduce visibility of advertising to those who are too young to be able to use advertised products and services, and to individuals or groups identified as being at risk of harm.
Provision of information
Consumers in a vulnerable situation may be significantly less able to understand the risks of gambling and the terms and conditions. It is particularly important that gambling businesses reduce this risk through meeting all of the requirements relating to provision of information. These include:
- enabling consumers to make informed decisions about whether to gamble based on their chances of winning
- the way the game, lottery or event works
- the prizes or payouts on offer
- the current state of multi-state games or events
- safer gambling messaging.
Consumer-led tools
Consumers have access to a range of tools to help them control their time and money spent gambling and there are rules governing the availability of these tools and their use.
Customer interaction
Recognising that it will at times be appropriate for gambling businesses to take proportionate action for customers who they know are in a vulnerable situation, we set requirements on how gambling businesses must identify customers at risk of harm and take action to minimise the risk. This includes assessing the information available to them on vulnerability and taking appropriate action.
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Vulnerability statement - Our internal approach to vulnerability
Last updated: 18 July 2023
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