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Evidence gaps and priorities 2023 to 2026

The themes we are focusing on over the next three years to improve the evidence base for gambling in Great Britain.

Published: 23 May 2023

Last updated: 10 July 2023

This version was printed or saved on: 20 May 2024

Online version: https://www.gamblingcommission.gov.uk/about-us/guide/evidence-gaps-and-priorities-2023-to-2026

Overview: Evidence matters. We all make decisions based on how we understand the world around us, what the evidence is telling us. The bigger the decision and the wider it’s impact, the more likely we all are to want more information before we act. Before the big choices, we all want to fill in the gaps in our understanding.

What’s true for us all in our daily lives is just as true for our understanding of gambling.

At the Gambling Commission we are a people focussed and evidence-led regulator. That means we recognise that better data, better research and better evidence will lead to better gambling regulation and better outcomes for consumers who gamble, their communities and the gambling sector itself.

And that’s what makes identifying evidence gaps and priorities for further data and research so important. In the following chapters, you will read about the themes and issues that require the development of further evidence and focus over the next three years if we are to usefully and significantly improve the evidence base for gambling in Great Britain. As you would expect, they all relate to our role as regulator to keep gambling safe, fair and crime free. It builds on the discussions and feedback we received at our very successful conference - Setting the Evidence Agenda - and also draws on what we have learned as we developed our gambling typologies and Path to Play research.

However, I think it’s important also to be clear that this document is not only about the Commission and what we need to do. Similarly, it does not argue that you should only act when the evidence base is completely conclusive. This paper is about highlighting the challenges ahead and asking the questions that need answering. Answering those questions is something we can all play a part in.

We have identified six themes that, whilst we already have evidence and data, we think are a priority to make a concerted effort to strengthen the evidence base. They are:

Each area has key points where we want to know more, each area has clear actions that the Commission can lead on but equally, they each have work for others: researchers, third sector bodies and the gambling sector itself.

We are building on a strong foundation, but with the Gambling Act Review White Paper now published, it’s clear that the next few years give a real opportunity to make decisive progress towards gambling in Great Britain being safer, fairer and crime-free. If we can all play our part in addressing the evidence gaps identified, I know we will have the tools to make the most of that opportunity.

Tim Miller, Executive Director of Research and Policy

Glossary of terms used in our evidence gaps and priorities

Affected others
Somebody harmed by the gambling of another person. This can include the gambler’s partner, their children, their wider family and friends and other social contacts.
Consistent with the Gambling Act 2005 (opens in new tab), a 'child' is an individual less than 16 years old, and a 'young person' is an individual who is not a child but is less than 18 years old.
When we refer to data, we mean digital information about people, companies and systems. While the legal definition of data covers paper and digital records, the focus of this document is on digital information. Depending on context, this could be administrative, operational and transactional data as well as analytical and statistical data.
Early gambling experience
These could occur at any age and on any gambling activity, including the gambling – and gambling-adjacent – activities that are legal for children under British legislation. They are most likely to be experienced in childhood, as a young person or a young adult, but that is not always the case.
Gambling experiences
Any experience with a gambling activity, whether it is regulated - such as gambling with licensed operators for betting, casino, bingo, arcade or lottery products - or unregulated gambling such as private betting or poker games with friends.
Gambling harm
Gambling-related harms are the adverse impacts from gambling on the health and wellbeing of individuals, families, communities and society.

These harms are diverse, affecting resources, relationships and health, and may reflect an interplay between individual, family and community processes. The harmful effects from gambling may be short-lived but can persist, having longer-term and enduring consequences that can exacerbate existing inequalities.
Gateway products
This refers to the product on which an individual initially gambles or gambling-adjacent activity that makes it more likely that they gamble in the future. Gateway products are likely to be different for different people, and can be encountered at a variety of ages.
Operator practices
This term covers any actions by operators that impact upon consumers, including decisions related to gambling environments and communications with consumers.
Problem gambling
Gambling to a degree that compromises, disrupts or damages family, personal or recreational pursuits. We currently measure problem gambling prevalence rates via a number of screening tools including the Problem Gambling Severity Index (PGSI).
A customer in a vulnerable situation who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of actions they should take as a result.

Although not an exhaustive list, we do for regulatory purposes consider that this group will include people who spend more money and/or time gambling than they want to, people who gamble beyond their means, and 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).
Young adult
Individuals aged between 18 and 24 years old.

Background to our evidence gaps and priorities

The Gambling Commission uses a range of data, research and insights to inform the decisions that we make and provide advice to the Government about gambling behaviour and the gambling market. We are responsible for the production of official statistics on the size and shape of the gambling industry, rates of participation in gambling, and the prevalence of problem gambling, in both adults and children. In addition, we track wider trends in consumer behaviour, listen to the full breadth of consumer voices, and deep dive quantitatively and qualitatively on key issues, impacts and emerging areas of interest.

We are a people focussed and evidence-led regulator. To be the most effective regulator possible, however, we require a robust evidence base - and the current evidence base still has many gaps. A lack of conclusive evidence does not necessarily mean that action shouldn’t be taken (for example, we sometimes apply the precautionary principle where we are satisfied that there is sufficient risk of harm), but we should aim to have as much reliable evidence as possible on which to base our decision.

Here, we present our ambitions and vision for developing the evidence base over the next three years and outline the gaps that we believe can and should be filled. We have gone through an extensive process to identify these gaps and priorities for improving the evidence base, all of which relate to our regulatory duty under the Gambling Act 2005 (opens in new tab) to:

And under the National Lottery etc Act 1993 (opens in new tab) to:

and subject to those two requirements:

This forward look demonstrates where we intend to focus our efforts in the next three years, within the parameters of our existing resources and remit, in line with the contents of DCMS’s White Paper following the review of the Gambling Act. It also identifies where we feel there is a wider evidence need, but where the Commission is not the right organisation to lead on delivery.

We have identified six overarching themes which cover the full range of gaps and research questions that we need to be able to fill and answer within our regulatory scope. Whilst we have a set a direction of travel, we will continually revisit and refresh these priorities as we react to progress and emerging findings from across the gambling research ecosystem.

Our approach to evidence-based regulation and evidence assurance

The approach that we have taken to identify evidence gaps and priorities is underpinned by the principles of Evidence Assurance. Evidence Assurance is a process we use that ensures that decisions we make are underpinned by the best available data and evidence and is based on recognised principles.

We use a rigorous, consistent, and transparent process to collate, interpret and weigh up the overall strength of the evidence base for a given issue or topic. Where there are gaps in the evidence base, we are transparent about that and identify what ideal evidence would look like, and how those gaps could be filled.

Our evidence assurance process is underpinned by a five-phase approach:

  1. What is the question, issue or problem?
  2. What would the ideal evidence base look like?
  3. What do we have in reality, and what are the evidence gaps?
  4. What is our assessment (quality and quantity) and interpretation of the evidence base?
  5. How does this inform our advice, position and or next steps?

Our role in the evidence ecosystem

We work with a variety of stakeholders and interested parties to gain insight and perspective about gambling behaviour in Great Britain. This helps to support our own commissioned research, statistics, regulatory casework and operator data analysis, to build a large volume and diverse range of evidence. We also have ready access to the widest range of experience and perspectives through our expert panels.1

Our forward plans also include developing our capacity to be a proactive, data led regulator, using the power of data and advanced analytics to make us more efficient and effective in carrying out our regulation.

The Commission contributes to the wider ecosystem by:

There are five key groups of stakeholders that make up the wider evidence ecosystem:

Gambling Commission five key research stakeholder groups.


1 The Advisory Board for Safer Gambling (ABSG), Digital Advisory Panel (DAP) and Lived Experience Advisory Panel (LEAP).

The gambling landscape – what we already know

According to recent figures, approximately 23.6 million people aged 16 and over gamble on products in Great Britain every four weeks, with approximately 15.5 million doing so on products licensed under the Gambling Act 2005.2

It is important not to always consider the gambling sector as a uniform sector – from an industry or consumer perspective.

The gambling sector we regulate comprises a diverse range of products used by a wide range of consumers. Consumers play on different products, for different experiences, and in different environments (in-person or online) which offer differing levels of anonymity and availability. Our research into why people gamble shows it can be an opportunity to socialise or a moment of ‘me time’. It can be a niche activity, or something engaged in by the mainstream.

It is also impacted by the context around it. Sometimes this is by highly visible products that are classed as gambling, like the National Lottery. Sometimes, it could be products that have gambling-like mechanics, such as loot-boxes. It could even be the macro trends that impact everything around us, such as the Covid-19 pandemic or the ongoing pressure on the cost of living. This can make it a complex landscape to unpick or generalise.

The biggest change in the gambling landscape over recent years is a shift to online play, reflecting our lifestyles in general. Technology and globalisation have meant that gambling is no longer confined to opening hours and largely local events, but instead a 24/7 opportunity and global event-driven marketplace.

With 94 percent of UK adults having access to the internet in 2021 it is not surprising that our industry statistics show a long-term trend of increasing online gambling participation and a decrease in land-based gambling. This matches changes seen in other sectors such as the increase in online grocery shopping or the rising popularity of digital-only banks.

Whilst the popularity of gambling in person has declined over time, retail remains a significant part of the sector and is showing signs of recovery following the pandemic.

Against this backdrop of changing trends, our data shows that although the vast majority do not experience gambling-related harms, there are still significant numbers of people who do encounter issues with their gambling.

The precise measurement of problem gambling and harms is complex, and needs continual development, however, we do know that hundreds of thousands of gamblers are suffering negative consequences from their gambling.

Despite the gambling landscape changing fundamentally since the 2005 Act, the headline rates for problem gambling have been static in recent years.

Within those numbers we know that some people are more likely to experience harm than others, including those who engage in multiple activities, men, those with probable mental health issues and players with the highest gambling expenditure. We also know that those suffering gambling-related harms are not a static group, so understanding the individual better and appreciating what works to help those avoid or recover from harm is a key part of advancing our understanding.


2Gambling behaviour in 2022: Findings from the quarterly telephone survey, Gambling Commission, 2023: 44.4 percent engaged in all gambling in the past four weeks, with 29.2 percent excluding National Lottery only.
Estimates of the population for the UK, England, Wales, Scotland and Northern Ireland (opens in new tab), Office for National Statistics, 2022: mid-year estimates for June 2021 shows a British population for those aged 16 and over as 53,195,320.

Our evidence themes and how they link to the Path to Play framework

Evidence theme 1

Early gambling experiences and gateway products

Theme 1 details for early gambling experiences and gateway products

Evidence theme 2

The range and variability of gambling experiences

Theme 2 details for the range and variability of gambling experiences

Evidence theme 3

Gambling-related harms and vulnerability

Theme 3 details for gambling-related harms and vulnerability

Evidence theme 4

The impact of operator practices

Theme 4 details for the impact of operator practices

Evidence theme 5

Product characteristics and risk

Theme 5 details for product characteristics and risk

Evidence theme 6

Illegal gambling and crime

Theme 6 details for illegal gambling and crime

The Path to Play framework identified stages that are present in each gambling journey:

Each of the six evidence themes we have identified can be mapped to the Path to Play and shows the need for further research covering the breadth of the customer journey.

There is significant crossover across some of the evidence themes and the stages of the Path to Play, however, we have highlighted the primary areas of overlap as follows:

Early gambling experiences and gateway products

These primarily contribute to the ‘passive influences’ stage of the Path to Play.

The range and variability of gambling experiences

As suggested by the name, the topics of this theme impact every stage of the Path to Play: ‘passive influences’, ‘external triggers and internal impulses’, ‘active search’, ‘play experience’ and ‘play outcome’.

Vulnerability, in particular, is significant for the ‘external triggers and internal impulses’ stage of the Path to Play, with the topics in this theme also affecting the ‘play experience’ and ‘play outcome’ stages.

The impact of operator practices

As detailed in the relevant section, the impact of operator practices stretches from ‘external triggers and internal impulses’, the ‘active search’ stage and impacts the ‘play experience’.

Product characteristics and risk

These factors are most likely to have an impact on the ‘active search’ and ‘play experience’ stages of the Path to Play.

Illegal gambling and crime

Aspects of this theme relate to the ‘external triggers and internal impulses’ and ‘active search’ stages, with the theme also linked to the ‘play outcome’ stage.

Each of the priority themes is explained in more detail in the following sections, along with our rationale for their inclusion as priorities and some indicative, aspirational questions. The Commission is not in a position to deliver a research programme to address all of these questions – some of which are extremely complex – so a brief note outlining steps that we will be prioritising as part of our own research delivery is included for each theme.

Evidence theme 1 - Early gambling experiences and gateway products

Evidence theme 1 - Early gambling experiences and gateway products

This theme is about:

  • understanding the gambling behaviours of children (under 16 years old), young people (those aged 16 and 17 years old) and young adults (18 to 24 years old) and what their journeys into gambling look like
  • how other consumers such as adults, including those with vulnerabilities, are introduced to gambling and how this influences their behaviour
  • how consumers engage with new products and activities that are not gambling but have similarities to gambling.

The Commission’s Path to Play research highlighted the impact of ‘passive influences’ on people’s gambling, with underlying attitudes and perceptions of gambling having an overarching impact on consideration and experience of play. These passive influences evolve gradually over time, starting with people’s early gambling experiences.

Young people have increased vulnerability to gambling-related harm due to their evolving biological and neurological development.3 This state of increased risk is recognised through age restrictions that limit access to activities within the regulated gambling market such as betting, attending casinos and playing National Lottery products. However, there are also activities which are assessed as being lower-risk and do not have age restrictions, such as ‘penny-push’ machines in arcades. Our young people and gambling research found that these products (which have been associated with adult gambling4) and activities that cannot be regulated, such as placing bets with friends or family, are often an individual’s first interaction with gambling.

The impact of activities that are gambling-adjacent or blur the line between gambling and gaming – an example of which may be loot box features in computer games, are also relevant factors, especially given fast-paced changes in consumer behaviour.5 There is also an interest in the long-term impact of gambling advertising, our young people and gambling research shows that it is widely seen, and concerns have been raised about a ‘normalising’ effect.6

Within Great Britain, our research with children up to the age of 16 shows that informal gambling participation, such as picking numbers for a lottery ticket and sweepstakes with family or friends for events such as the Grand National is common. We also know that any participation in regulated gambling activities predominantly occurs with the supervision of a parent or guardian.

Although we know that passive influences can impact somebody’s decision to gamble, it can be difficult to determine the extent of early gambling experiences within those influences compared to more recent gambling experiences of themselves and others, or the impact of advertising, for example. Longitudinal evidence in Britain suggests that gambling activity can increase or decrease significantly in early adulthood (between the ages of 17 and 21) when many individuals experience greater social and financial freedoms.7, 8 Observations in other jurisdictions show that recovery from gambling problems occurs frequently.9

Getting an understanding of commonalities in early gambling experiences, especially where it might be associated with risky or harmful gambling, could be extremely impactful for strengthening harm-reduction measures for different, identified groups, or for targeting educational activities.

Research with a longitudinal aspect that establishes patterns in gambling behaviour over time would aid our understanding of this theme, as would linked operator data with a focus on younger gamblers for the exploration of patterns in remote, regulated gambling.

Example research questions within this theme

These are the type of questions that could be considered in relation to this theme:

Evidence theme 1 - What the Gambling Commission will focus on

To better understand early gambling experiences and gateway products, the Commission will focus on:


3 Neurodevelopment, impulsivity, and adolescent gambling (opens in new tab), R A Chambers and Marc N Potenza, Journal of Gambling Studies, volume 19, 2003, pages 53 to 84.

4 Childhood use of coin pusher and crane grab machines, and adult gambling: A conceptual replication of Newall et al. (2021) (opens in new tab), A Parrado-González and P W Newall, Journal of Behavioral Addictions, 2023.

5 Video game loot boxes are linked to problem gambling: Results of a large-scale survey (opens in new tab), D Zendle and P Cairns, PloS one, 13(11), e0206767, 2018.

6 What is the evidence that advertising policies could have an impact on gambling-related harms? A systematic umbrella review of the literature (opens in new tab), E McGrane, H Wardle, M Clowes, L Blank, R Pryce, M Field and E Goyder, Public Health, 2023.

7 Gambling and problem gambling among young adults: Insights from a longitudinal study of parents and children (opens in new tab) (PDF), D Forrest and I G McHale, report for GambleAware, 2018.

8 A longitudinal study of gambling in late adolescence and early adulthood: Follow-up assessment at 24 years (opens in new tab) (PDF), Alan Emond, Mark D Griffiths and Linda Hollén, report for GambleAware, 2019.

9 Recovery from problem gambling: Results from the in-depth Swelogs study (opens in new tab) (PDF), Folkhälsomyndigheten, 2016.

Evidence theme 2 - The range and variability of gambling experiences

Evidence theme 2 - The range and variability of gambling experiences

This theme is about:

  • understanding the different experiences that people have with gambling – every gambler is different
  • acknowledging how gambling fits into people’s lives and overlaps with other behaviours and experiences
  • exploring consumer journeys and motivations
  • how gambling habits and behaviours change over time.

Gambling participation figures estimate that over 23 million people engaged in some form of gambling activity in the last four weeks. The majority of these people gamble without experiencing harms. Our research to understand why people gamble found that most people gamble to win money and that enjoyment is prevalent, but secondary.

Our role as a regulator is to licence and regulate the gambling industry and this includes a requirement to protect children and vulnerable people from being harmed by gambling. The focus of a large proportion of the research into gambling activities has been on those experiencing gambling-related harms, and the need for ongoing research in these areas is reflected in some of the other themes. Within this theme, we highlight the need to better understand the range of gambling experiences, including positive consequences of gambling, reflecting the range of our regulatory duties.

Previous Commission research has identified gambling typologies and the Path to Play which helps to highlight the range of influences – but they also highlight that experiences are not the same for all people. It is important to continue to build on this model to understand policy interventions at different steps along this path by hearing from a range of voices.

A greater understanding of low risk, as well as high risk play could be beneficial. We know that people move in and out of gambling-related harm (discussed further as part of the gateway products theme), but it may be helpful to know more about the range and variability of experiences, how they contribute to harmful gambling behaviours and any common indicators that could help others.

It is also valuable to understand the aspects of gambling that can be improved from a regulatory perspective that ensure gambling remains fair and open for everyone. This could include identification and consideration of the ‘average’ consumer, and their views and priorities on various topics, including – for example – bonus offers and their understanding of products to make informed consumer choices.

There are a wide range of potential questions within this theme, and it’s likely that it will need a mixture of data sources to explore them, with qualitative research necessary to understand gambling experiences and quantitative research to better understand the scale of those experiences. Access to a wide range of anonymised datasets could offer the opportunity to see accurate play information and interaction between products within a gambling operator.

Example research questions within this theme

These are the type of questions that could be considered in relation to this theme:

Evidence theme 2 - What the Gambling Commission will focus on

To better understand the range and variability of gambling experiences, the Commission will focus on:

  • using the new Gambling Survey for Great Britain to improve our understanding of gambling participation at a national level and in sub-groups of interest
  • building on our work on consumer journeys, by zooming in to key parts of the Path to Play framework to add depth and insight
  • developing strong foundations for future research, for example establishing recontact samples for longitudinal research.

Evidence theme 3 - Gambling-related harms and vulnerability

Evidence theme 3 - Gambling-related harms and vulnerability

This theme is about:

  • gaining a better understanding of the different ways that consumers can experience harms
  • being able to identify these consumers who may be more vulnerable or at risk of experiencing harms.

It is one of the Gambling Commission’s three licensing objectives to protect children and other vulnerable persons from being harmed or exploited by gambling and this has been at the heart of many regulatory changes in recent years, informed by a wealth of research on the topic. However, even defining vulnerability can be challenging, as a consumer’s vulnerability is not necessarily static.

The Commission has a commitment to collect robust, timely insights for a range of gambling behaviours, including the extent to which gambling harms are experienced, with the pilot methodology review report published last year. The range of gambling experiences and product risks are considered in different themes. There are many more situational and demographic factors linked to gambling-related harms, however, as well as evidence of inequalities in the way that harms are experienced. This justifies more in-depth research requiring different research tools and partnerships with other agencies that may inform policies for the prevention of harms.

Early gambling experiences are considered in evidence theme 1 but, among adults, research has shown links between gambling and harms such as financial losses10, depression11, intimate partner violence12 and others. At its most extreme, gambling-related harms have been linked with increased suicidal ideation, suicide attempts and completed suicides.13 The limitation with much of the research into these factors is related to data quality – many of these factors are associated with each other without the influence of gambling, which makes it difficult to look beyond correlation to establish whether there is a causational link and, if so, how strong it is.

Similarly, factors that increase an individual’s vulnerability to gambling-related harm have been identified as including events which can happen to anybody at any stage of life, including bereavement, relationship breakdown, poor health and impulsivity.14 A greater understanding of the impact of these factors – which a gambling operator is unlikely to know about - and how best to offer timely protections against increased risks is important.

Other demographic characteristics of interest that may be experiencing harm in a different manner include gender, age and socio-economic groups. Other factors that remain under-researched in relation to their association with gambling-related harms include marginalised and hard-to-reach groups, those with neurodiversities (such as autism or ADHD) and the experiences of different ethnic groups. As well as harms experienced by gamblers, more could be done to understand the impact on 'affected others', former gamblers who are still impacted by the consequences of their gambling and exposed to gambling advertising, and the impact on society as a whole.

This theme, perhaps more than any of the others, has the widest range of potential questions associated with it, and this synopsis is far from exhaustive. Even with a period of three years, it will take significant resources to investigate many of these sub-topics and it is likely to require a blend of evidence from longitudinal, co-produced research with people with lived experience of gambling-related harms, account data and in-depth qualitative sources to gain a better understanding.

Example research questions within this theme

These are the type of questions that could be considered in relation to this theme:

Evidence theme 3 - What the Gambling Commission will focus on

To better understand gambling-related harms and vulnerability, the Commission will focus on:

  • using the Gambling Survey for Great Britain to produce robust statistics on who is experiencing gambling-related harms, and how
  • conducting qualitative research with consumers with experience of gambling-related harm
  • using our datasets and wider evidence to identify groups that may be at greater risk of harm.


10 Gambling-related harms evidence review: an abbreviated systematic review of harms (opens in new tab) (PDF), Public Health England, 2021.

11 The impact of gambling on depression: New evidence from England and Scotland (opens in new tab), Sefa A Churchill and L Farrell, Economic Modelling, volume 68, 2018, pages 475 to 483.

12 Intimate partner violence in treatment seeking problem gamblers (opens in new tab), Amanda Roberts, Stephen Sharman, Jason Landon, Sean Cowlishaw, Raegan Murphy, Stephanie Meleck and Henrietta Bowden-Jones, Journal of Family Violence, volume 35, 2020, pages 65 to 72.

13 Problem gambling and suicidal thoughts, suicide attempts and non-suicidal self-harm in England: evidence from the Adult Psychiatric Morbidity Survey 2007 (report 1) (opens in new tab) (PDF), Heather Wardle, Simon Dymond, Ann John, Sally McManus, report prepared for GambleAware, 2019.

14 Gambling-related harms evidence review: risk factors (opens in new tab) (PDF), Public Health England, 2021.

Evidence theme 4 - The impact of operator practices

Evidence theme 4 - The impact of operator practices

This theme is about:

  • understanding how common operator practices influence consumer behaviour
  • assessing the effectiveness of interventions designed to detect and reduce gambling harms.

Gambling operators – along with gamblers and the gambling product – are part of the trio which make up gambling experiences. They have a significant ability to influence gambling activity through the environment that they provide and their behaviours.

Although operators are reliant upon their customers for revenue, they are also obligated to protect their customers from harm through regulatory requirements such as customer interaction requirements - and the largest gambling industry trade bodies have also made harm reduction commitments. Given the inherently risky activity of gambling, and the unusual adversarial relationship between gambler and operator, our research into exploring the information needs of consumers found that gamblers feel a tension around trust which risks undermining safer gambling messages.

Operator practices that impact upon consumers can include communications that encourage gambling such as advertising that is visible to everyone and targeted marketing to selected groups. It also includes communications that encourage gambling mitigation through the provision of tools and safer gambling messaging, whether targeted or otherwise and conducted through a range of different channels.

Other practices that could be considered include the presentation of information about products or offers, the way that the game functions and the location of gambling opportunities in-person or through online choice architecture. Remote operators often rely upon harm detection algorithms to identify consumers at increased risk of experiencing harms, and the effectiveness of those is also a topic of interest.

Amongst operator practices that are visible universally, research has examined the relationship between operator advertising practices, consumer awareness and consumer activity.15 There is the potential to understand more about directed advertising practices, how they fit into a complex online advertising ecosystem and their potential impact on selected groups. A particular group of interest are people living in disadvantaged communities who are more likely to be in the vicinity of land-based gambling premises16 and whether there is a link with other demographic characteristics identified in the previous theme as being associated with an increased risk of experiencing harms.

Regarding the more direct relationship, rules relating to VIP schemes were strengthened in 2020 and a significant reduction of consumers considered to be VIPs was reported by one industry body following the publication of their code of conduct.17 For telephone contact, there is indicative evidence of an impact on subsequent gambling activity of telephone calls to gamblers18, including high-spending gamblers19- and market impact data suggests that direct interactions have increased. However, there are still a lot of unknowns regarding the impact on subsequent experience of harms and of safer gambling messaging on different groups of people. Methods of increasing uptake of safer gambling tools have been identified20 but the subsequent impact of doing so remains unclear and it is uncertain whether behaviours observed in jurisdictions with few regulated operators would be replicated in Great Britain.

To feed into harm-detection algorithms, research has been conducted that seeks to identify potential indicators of higher-risk gambling21 and it remains an area of great interest and debate, with differences between products, platforms and the amount of gambling activities likely. An improved understanding of customer journeys amongst those that once seemed on a trajectory towards more harmful activity but did not progress to that level could be insightful in identifying protective operator practices. An additional unknown relates to the varying implementation approaches for algorithms, machine learning, artificial intelligence or other technological solutions applied by operators.

To explore this research theme, various sources of data are likely to be required, including operator-held account-level data suitable for detailed analysis, qualitative data, and potentially longitudinal data.

Example research questions within this theme

These are the type of questions that could be considered in relation to this theme:

Evidence theme 4 - What the Gambling Commission will focus on

To better understand the impact of operator practices, the Commission will focus on:

  • gaining greater access to operator-held account-level data to further explore the impact of operator practices
  • conducting consumer research to understand the role that operators practices play in the wider consumer journey
  • using our consumer voice research to understand the factors that influence consumer trust.


15The effect of gambling marketing and advertising on children, young people and vulnerable adults (opens in new tab) (PDF), Ipsos MORI, 2020.

16Geography of gambling premises (opens in new tab) (PDF), Jamie Evans and Katie Cross, University of Bristol, 2021.

17BGC welcomes new rules on VIP schemes (opens in new tab), Betting and Gaming Council, 2020.

18Patterns of Play Technical Report 2: Account Data Stage (opens in new tab) (PDF), David Forrest and Ian McHale, NatCen, 2022.

19Reaching out to big losers: Exploring intervention effects using individualized follow-up (opens in new tab), Jokob Jonsson, Ingrid Munck, David Hodgins and Per Carlbring, Psychology of Addictive Behaviours, 2023.

20Can behavioural insights be used to reduce risky play in online environments? (opens in new tab) (PDF), The Behavioural Insights Team, 2018.
Safer Gambling Messaging Project Phase Two An impact evaluation from the Behavioural Insights Team (opens in new tab) (PDF), report commissioned by GambleAware and completed by the Behavioural Insights Team.

21Examples include: Using artificial intelligence algorithms to predict self-reported problem gambling with account-based player data in an online casino setting (opens in new tab), Michael Auer and Mark D. Griffiths, Journal of Gambling Studies, 2022.
Predicting online gambling self-exclusion: An analysis of the performance of supervised machine learning models (opens in new tab), Christian Percy, Manoel França, Simo Dragičević and Artur d’Avila Garcez, International Gambling Studies, Volume 16, 2016, pages 193 to 210.

Evidence theme 5 - Product characteristics and risk

Evidence theme 5 - Product characteristics and risk

This theme is about:

  • improving our understanding of which products and behaviours carry greater risk of harm, for whom, and why
  • gaining a deeper understanding of how consumers interact with different products and links to gambling harms
  • identifying areas of new or emerging risk and building a strong understanding of changes in the market.

Gambling risk is formed from many factors that are integral to the gambling experience, these include the gambling product, place and provider. The gambling product is often the most complex element of this trio, with many characteristics combining in a single product which add or mitigate riskiness for different types of gamblers. Although different problem gambling rates are recorded for different products22, their complexity can make it difficult to assess any individual product’s composite risk and also to isolate the impact of each characteristic within different products.

However, some research has been conducted over the years into characteristics of gaming products such as slots games, identifying factors such as frequency, audio-visual factors, rewards and information provision.23 There have also been tools developed to assess the risk of gambling products which are based on this research and identified additional characteristics. Consideration has also been given to the structural characteristics of sports betting products.24

A further complexity arises when considering the way that individuals interact with different gambling products at different times, and how well they understand the products as well as concepts such as probability and randomness. The ability to make informed choices is relevant to the ‘fair and open’ objective, which is one reason why the focus on products needs to be considered alongside the other themes rather than in isolation.

The existing research has led to regulatory developments that include the long-standing requirements in the remote gambling and software technical standards (updated over time) for remote products, and reductions in the maximum stake levels for B2 gaming machines25 and scratchcards.26 They also informed the changes to online slots games that impact the speed-of-play, illusion of control and removal of losses-disguised-as-wins.

However, there is no single homogenous gambling journey. This is why further research is required to establish the connection between product characteristics and increased risk of experiencing gambling-related harms. Research that identifies markers of harm and increased risk is important and can be utilised to develop appropriate mitigation methods. Examples of this type of research could include examining real-time account activity data, especially when combined with survey data in the manner of NatCen’s Patterns of Play research (opens in new tab) (PDF), opportunities created through data linkage, or robustly evaluated product trials in live environments.

Example research questions within this theme

These are the type of questions that could be considered in relation to this theme:

Evidence theme 5 - What the Gambling Commission will focus on

To better understand product characteristics and risk, the Commission will focus on:

  • gaining greater access to operator-held account-level data to further explore patterns of play
  • using secondary analyses of existing datasets to further our understanding of product risk.


22Gambling behaviour in Great Britain in 2016: Evidence from England, Scotland and Wales (PDF), prepared by NatCen for the Gambling Commission, 2018.

23Key issues in product-based harm minimisation: Examining theory, evidence and policy issues relevant in Great Britain (opens in new tab), Jonathan Parke, Adrian Parke and Alex Blaszczynski, 2016.

24Structural characteristics of fixed-odds sports betting products (opens in new tab), Philip Newall, Alex Russell and Nerilee Hing, Journal of Behavioral Addictions, Volume 10, Issue 3, pages 371 to 380.

25Government to cut Fixed Odds Betting Terminals maximum stake from £100 to £2 (opens in new tab), Department for Culture, Media and Sport, 2018.

26Rationale for agreeing the withdrawal of £10 scratchcard games, Gambling Commission, 2022.

Evidence theme 6 - Illegal gambling and crime

Evidence theme 6 - Illegal gambling and crime

This theme is about:

  • understanding how gambling is linked to criminal activity
  • understanding crime as a dimension of gambling-related harm
  • improving our knowledge of the extent and impact of the unregulated market.

Another one of the Gambling Commission’s three Gambling Act licensing objectives (opens in new tab) is to prevent gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime. This can relate to crimes committed in connection with gambling activities (whether illegal gambling or funding gambling through crime), crimes that affect society or gambling operators, crimes committed by gambling operators, or connections between gambling and the criminal justice system.

Research by the Howard League has found links between problem gambling and crime, including financial crimes27 – with a Swedish study finding that fraud and embezzlement were the most common crimes to go to court.28 Other crimes are addressed through the Commission’s clear anti-money laundering rules for regulated operators, assessment and updates of the risks of different gambling sectors29 and the work of the Sports Betting Intelligence Unit to deal with reports of betting-related corruption and protect the integrity of sports and betting.

However, establishing causality for individual crimes can be difficult when there are many contributory factors or when solely correlational data is available. There is likely to be a sizeable impact upon others (particularly direct victims) as a result of criminal activity, and establishing the scale of this is particularly difficult when acquisitive crimes against friends or family may go entirely unreported. Some police forces have trialled screening for gambling addiction30 and that is being extended to more areas in 202331, which has the potential to provide greater insights.

We are also interested in the extent and impact of the illegal gambling market in Great Britain as part of this theme. Research into channelisation has been conducted in other nations but further research is required to confidently estimate the extent of illegal gambling within Great Britain, the people who are engaging with it and the impact that it is having. It is also important for the safeguarding of consumers to get an understanding of their recognition of when they are gambling with a company licenced in Great Britain and when they are gambling on the illegal, unlicensed market. We also need to understand why consumers are doing so, and consider the risks and impact of forms of gambling created by new technology, such as gambling with cryptocurrencies.32

As well as the research being done with those entering the criminal justice system, the extent of gambling within prisons has been unknown in Great Britain due to official participation surveys requiring postal addresses. There are reports of gambling being prevalent whilst incarcerated33 and a greater requirement for support for many upon release.

Given the secretive nature of criminal activity, research into this theme may need more specialised and focused research methods, with greater reliance upon new and existing partner organisations and new tracking techniques identified within the gambling landscape section.

Example research questions within this theme

These are the type of questions that could be considered in relation to this theme:

Evidence theme 6 - What the Gambling Commission will focus on

To better understand illegal gambling and crime, the Commission will focus on:

  • research into consumers’ understanding and use of unlicensed illegal gambling operators
  • using the Gambling Survey for Great Britain to develop our understanding of how people commit crime or are a victim of crime as a dimension of gambling-related harm.


27Crime and Problem Gambling: A Research Landscape (opens in new tab) (PDF), Sarah Ramanauskas, Prepared for the Howard League’s Commission on Crime and Problem Gambling, 2020.

28Criminogenic problem gambling: a study of verdicts by Swedish courts (opens in new tab), Per Binde, Jenny Cisneros Örnberg and David Forsström, International Gambling Studies, volume 22, issue 3, 2022, pages 344 to 364.

29Such as: The money laundering and terrorist financing risks within the British Gambling industry 2020 and the updates relating to Emerging money laundering and terrorist financing risks.

30Arresting Problem Gambling in the UK Criminal Justice System: Raising Awareness and Screening for Problem Gambling at the Point of Arrest (opens in new tab) (PDF), GamCare and Beacon Counselling Trust, 2017.

31Police in England and Wales to screen suspects for signs gambling addiction is driving crime (opens in new tab), The Guardian, 2022.

32Safer gambling and consumer protection failings among 40 frequently visited cryptocurrency-based online gambling operators (opens in new tab), Maira Andrade, Steve Sharman, Leon Y Xiao, Philip W S Newall, Psychology of Addictive Behaviors, volume 37, issue 3, 2023.

33Gambling and crime: An exploration of gambling availability and culture in an English prison (opens in new tab), Lauren Rebecca Smith, Steve Sharman, Amanda Roberts, Criminal Behaviour and Mental Health, volume 32, issue 6, 2022.

Our role in delivery

Whilst our six evidence themes cover a broad and diverse range of topics and issues, we are aware that there are key principles that should be inherent in the delivery of robust, good quality evidence across the wider ecosystem. These principles apply to the collection and development of evidence, and the communication and dissemination of the evidence base. We will continue our efforts to strengthen our approach to these principles over the course of the next three years.


As a regulator, one of our key areas of interest is in what works, for whom, and why. This relates to both evaluating the effectiveness of our own work and efforts to meet our licensing objectives, and also to the part that evaluation in the wider evidence ecosystem plays in improving our understanding and informing regulation.

There is a collective need for a better understanding of the impact of interventions and programmes aiming to prevent or reduce harm, across all the themes and issues we have identified. We recognise however that there are challenges, not least in the complexity of the interventions that require evaluation and the contexts in which they occur.

There is also a need to be proportionate, and to consider how we can be pragmatic and realistic (both in terms of resource and time) in delivering good evaluations. However, an increase in the use of evaluative approaches to tackle some of the gaps we have identified will be pivotal in developing a richer and more informative evidence base.

The role of lived experience

An essential part of the evidence base is the direct input of people with lived experience of gambling harms. The Commission’s Lived Experience Advisory Panel (LEAP) provides us with advice and perspectives based on its members own experiences of a wide range of gambling harms.

We will be working with LEAP and the wider lived experience community going forward to get their input into the scoping and development of new research projects, as well as when we have emerging findings and data to explore. This will be hugely beneficial and will improve the quality of the research that we conduct and the insights that we can tap into. This will take place alongside our wider consumer voice research programme, which will ensure that the views of all gambling consumers are taken into account when developing our evidence base.

Governance and transparency

Strong research governance is vital in building a robust and impactful evidence base. As a body that commissions research it is important that we conduct work in a way that is authoritative and trusted, and we are committed to ensuring that our processes are in line with best practice.

When we collect data that is reported as official statistics, we follow the Code of Practice for Statistics (opens in new tab). This ensures that the statistics we provide meet the needs of all users, are produced, managed and published to high standards, and are well explained.

We also follow best practice standards when procuring and delivering our wider research programme, and going forward we will be paying even greater attention to the way that we conduct our work. This includes strengthening our peer review processes, ensuring that our approaches are ethically sound, and working with partners who have robust procedures in place.

Linked to research governance is the issue of transparency, and the expectation that high quality research and evidence is transparent about methodological and analytical approaches, provides full disclosure and discussion of limitations, and allows others to replicate the work themselves. The development of our six evidence themes is itself an effort to be transparent about what drives our thinking, and we will strive to increase the transparency of our work going forward.


Lastly, we also recognise the need for good research and evidence to be accessible to all. There are two facets to this:

  1. allowing greater access to our research and evidence by making datasets available for wider analysis
  2. making sure that all of our research outputs are accessible to all users and that everyone can access the same information regardless of barriers or ability.

We already make several of our research datasets available for wider use via the UK Data Archive, and will be continuing to upload raw data from our core research projects as and when this is available.

As a public sector body it is a legal requirement that our website meets accessibility requirements, and we have been working for some time on ensuring that this is the case – not least in our Statistics and Research Hub, which is where all of our research, data and evidence is published and stored. We require all of our research partners to provide accessible content and we will be continuing to develop accessible ways to share our work.

Monitoring and improving the evidence base

Given the breadth and diversity of the questions and themes we have identified, it is clear that what we have set out here is an aspirational programme. There are significant challenges with regard to making progress in an ethical, robust manner and with pace. Some of the work outlined here will take us, and others, time to develop and complete – but we are committed to playing our part in improving the evidence base.

Going forward we will be transparent about how the Commission is making progress on these themes, as we add further layers to our understanding. We will continue to assess the quality of the evidence base that we rely on, and when needed we will work flexibly to shift focus as our knowledge improves. There will be points where we need to stop, explain, and discuss what we have found with our stakeholders and colleagues in the wider ecosystem before moving on, whilst also listening carefully to the insights delivered by others. We want to encourage others to contribute through their own work and experiences, from whichever part of the ecosystem they are in.

The pace of progress will ultimately be dictated by the resource available. We have purposefully developed our evidence themes in a way that allows work to be scaled up or scaled down should our capacity change. It will also be driven by the wider ecosystem’s capacity to make the most of the data and resources available to it, and ability to work collaboratively to ensure that our collective knowledge is the true sum of what we separately know.