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What do we mean by vulnerability?

Key documents

One of the licensing objectives set out in the Gambling Act 2005 (opens in new tab) is to 'protect children and other vulnerable persons from harm'. Children are therefore considered to be vulnerable by the legislation.

The Gambling Commission has set out in corporate documents, such as our Strategy plan: 2018 to 2021, what we consider to be vulnerability, which is similar to the approaches taken by other regulators.

'A customer in a vulnerable situation is somebody who, due to their personal circumstances, is especially susceptible to detriment, particularly where a business is not acting with appropriate levels of care.'.

Although not an exhaustive list, our Statement of principles for licensing and regulation sets out that for regulatory purposes we consider that the group of 'other vulnerable persons' will include:

  • people who spend more money and/or time gambling than they want to
  • people who gamble beyond their means
  • people who may not be able to make informed or balanced decisions about gambling, for example because of health problems, learning disability, or substance misuse relating to alcohol or drugs.

We know that adults may be in a vulnerable situation at any age, but young adults may be particularly vulnerable to gambling related harms due to a combination of biological, situational and environmental factors.

Anybody can be vulnerable to harm and there are many reasons a person may be in a vulnerable situation. Changes to an individual consumer’s circumstances may mean that a person becomes more or less vulnerable to experiencing gambling harms. A vulnerable situation can be permanent, temporary or intermittent, and may be related to health, capability, resilience, or the impact of a life event.

Those circumstances could include bereavement, loss of income, illness, divorce or other factors. This does not mean that everyone who is in these circumstances is automatically vulnerable - they may not be a representation of vulnerability in any given situation. Importantly, it also does not mean that the Gambling Commission seeks for set responses to every consumer in these same circumstances - vulnerabilities differ, they may not always be visible and the appropriate response will depend on the situation.

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Vulnerability statement - What do we know about vulnerability in the gambling context?

Last updated: 20 July 2023

Show updates to this content

Updated the definition for a customer in a vulnerable situation.

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