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Industry Forum minutes for 6 August 2025

Minutes of the meeting of the Industry Forum, 6 August 2025.

[Remote] Industry Forum Meeting.

Members:

  • Nick Rust (Chair)
  • Kirsty Caldwell (item 4)
  • Ashley Padgett
  • Nigel Roddis
  • Helen Walton
  • David Williams.

In attendance: REDACTED.

Apologies:

  • Tony Boulton
  • Leo Walker
  • Mark Pearson
  • Charles Cohen

1. Welcome, apologies and declarations of interest

Apologies for the meeting were noted, no new declarations of interest.

Minutes were approved subject to changes noted in Action below.

REDACTED

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2. Item 1: Involving Expert Groups (EGs) in Board session.

The REDACTED explained to members that the GC board are looking at how more value can be added from Expert Groups outside of their regular meetings. To start, the Board and Executive team will have quarterly strategic sessions. The GC Chair wants input from Expert Groups in these sessions, with the first one being held on 17 September 2025.

Some questions around trends in consumer complaints were presented to the forum, to get members views, with the intention that they will be presented to the GC Board at the first of the strategic sessions. Whilst members agreed that there were no ‘new’ trends developing, they provided comments on existing trends. The most significant complaints are related to account withdrawals and enhanced due diligence checks.

On the topic of account withdrawals:

  1. The Industry Forum (IF) Chair referred to an event where an IBAS representative presented figures on consumer queries and complaints from the previous 2 years which showed that technical betting queries had decreased significantly, partly because of the improvement in operators’ terms and conditions. However, there is an increase in queries about withdrawal delays and the IF Chair noted this subject was covered in a conversation he had with Andrew Rhodes (GC CEO).
  2. It was noted that operators are typically “friction-light” on sign-up and “friction-heavier” later in the customer journey. This is because a significant number of customers will be light or very light users with an operator, so the burden of document requests very early in that journey is seen as being disproportionate to the perceived risk.
  3. One operator’s data showed that 99 percent of withdrawals are processed within 24 hours. This needs to be considered when looking at a minority of consumers who experience a delay.
  4. A comparison was made to non-gambling retail businesses, where refunds can take 3-5 working days, but operators are held to a different standard. The Chair reminded members that an important part of gambling for consumers is receiving their winning funds (unlike in retail).
  5. Some operators are undertaking EDD checks earlier on and incentivising customers to do. The early undertaking by customers can lead to benefits later on if their level of activity increases meaning, for example, smoother withdrawals. However, this may put operators concerned at a significant competitive disadvantage
  6. An example was provided of a company who offer complete EDD checks at a very early stage in the customer journey. However, the audit trail was confusing and difficult to present during regulatory assessment. It was also found that consumers still had to do additional checks later on, often relating to account activity. From this perspective there didn’t seem to be an obvious advantage to the early stage checks, as in many cases they needed to be repeated.
  7. A member said their business has observed a lower level of attention on social media regarding withdrawals and complaints. They added that social responsibility (SR) complaints have significantly reduced.

On the topic of Enhanced Due Diligence (EDD) checks:

  1. Feedback was provided from 3 operators on this. In summary, they are seeing more complaints driven by AML processes and requests for documentation. Another operator highlighted instances of complaints being escalated to IBAS which are not being dealt with by IBAS directly but do require conversations with them.
  2. Some organisations receive fewer complaints over withdrawals but more related to Anti-Money Laundering (AML) and/or Know Your Customer (KYC) requirements. These complaints may be linked to disparities around processes and parameters between operators.
  3. It is the experience of most members that consumers will often cease trading when asked to provide EDD documentation.
  4. Members commented that AI tools could in future be leveraged and improved to help identify issues earlier, however negative industry impact of AI tools was also referenced through increased cases of fraudulent documents being received, which are being generated through AI.

Members discussed how operators categorise complaints in different ways, so looking at these holistically would be extremely difficult. If the GC wanted a more granular view, it would be helpful to define complaints categories more clearly in their guidance.

It is worth noting that operators can go to other ADRs instead of IBAS, which can potentially provide different outcomes for complaints.

The Chair concluded the discussion by reiterating that whilst the forum do not believe there are any ‘new trends’, it would be useful for the Gambling Commission’s Board to have some insight into the topics that have been discussed today and understand the deeper context to how quickly issues are resolved.

Question 2: Has there been an increase in legal claims from consumers?

Members have observed emerging entities who appear to proactively engage with the social media posts of gambling consumers, with the intention to encourage legal action against operators. Members also noted instances where consumers have even copied journalists into their complaint emails.

Question 3: On the basis of these trends, are there areas where the Commission could consider a change of approach, in support of its’ statutory objectives?

Reporting requirements could be made clearer on regulatory returns, for example as suggested above, by providing clear categories of complaints.

Question 4: Is the delay to the formation of an Ombudsman creating any behaviour or pressures that the GC should be aware of?

No behaviours were noted but frustration was expressed over the lack of progress on the Ombudsman, and a lack of clarity about who owns this. Members raised concerns that the industry will receive some blame for the delay when they are keen for this to be progressed. Members would like to see an update on this from the GC.

3. Item 2: The cost of regulation

The REDACTED introduced the topic; in spring this year, treasury released a paper on economic growth which was aimed at 16 key regulators within the finance, environmental and science and/or technology sectors. The GC has been proactive in identifying relevant areas of the report and has taken away several recommendations that will be pursued internally. The paper encouraged regulators to engage with their industry, and the two key topics for discussion and feedback from industry forum are:

  1. Transparency, not for regulatory outcomes - as this is already in the GC’s annual report and Impact Metrics on GC the website - but for processes such as licence applications.
  2. Regulatory burden. Has the regulatory burden accumulated over time? For example, one area the GC is looking at is data submissions and how they ask for these to be submitted. The GC is also looking at how to make guidance etc more accessible.

Industry Forum members provided feedback and comments:

  1. Third party costs should be considered within this work. For example, game audits, test houses, industry lawyers and consultants. Changes to guidance on remote gaming controls and the subsequent recertification of games needed to meet those controls can cause additional costs for operator.
  2. The burden of cost associated to specific games can result in some of them becoming commercially unviable in certain markets. This can lead to only the highest risk games being commercially viable. For example, scratch cards are the same cost to certify as a slot game but they don’t generate the same revenue. The cost is fixed rather than proportionate, so lower risk products are effectively being pushed out.
  3. Regarding data requests, it would be helpful for the GC to identify what data has been asked for against what has been used. For example, are the monthly Covid data reports still required? Can it be changed to a quarterly request? Currently this data is being requested manually, so if it is going to be a permanent data request, operators would like to be updated on this so that it can be automated instead of the burden involved in the manual pulling of the data. In terms of transparency, covid data categories were not explained to operators at the time. The REDACTED commented that this is something that the GC will be looking at. There are circumstances where regulators will ask for data that industry may not understand the purpose of. But this does not mean the data should be continued to be requested if it is no longer needed.
  4. Change of Corporate Control: this is a long-winded process, with operators typically engaging with external counsel for support. Is there an opportunity to streamline this process to make it less resource intensive, so that those resources could be used elsewhere?
  5. S122 requests for information: It would be helpful if there was a standard set of questions that could be asked, to add consistency to the process. REDACTED.
  6. There are some countries which accept GC certification, and it would help if GC would also accept certification from other jurisdictions, where there are similar regulatory requirements. If Ireland begin to regulate separately it would reduce burdens on operators if the UK can align with them.
  7. When querying data in circumstances such as during regulatory action, it would be more efficient for these conversations to happen promptly, rather than the longwinded email or letter correspondence between the GC and operators.
  8. PML holders in Ireland have a longer process for DBS checks than the UK because they do not have central DBS checking systems.

On the topic of transparency, a member commented that operators are still being asked by the GC to provide COVID data sets every month, and made the following points:

  • this was a temporary data set to monitor customer behaviour during the peak COVID period, which we are now out of. However, operators are still being asked to provide this data
  • the data is provided without proper governance from the Commission, that is, there are no agreed definitions for each data set which can result in inconsistencies across the industry
  • the data is requested outside the standard requirements for normal data requests (that is, regulatory returns are quarterly, but these are monthly)
  • as this is seen as a temporary data set, the data is manually extracted, if this is to be a permanent request, could this be automated?

Members also noted a lack of transparency around the LCCP notification process:

  • members noted reports that general operator feedback has highlighted a lack of consistency in receiving closure notices for their LCCP notifications.
  • similarly, operators report a lack of transparency on which stage in the process an LCCP notification is at with the Commission. This causes governance issues as it prevents accurate and timely reporting to internal stakeholders on what is happening with a notification.
  • on performance data there is no visibility around how the Commission deals with LCCP notifications (that is, it would be useful to see ‘‘x’ LCCP notification made across the industry and this resulted in, ‘y’ NFA, ‘z’ advice to conduct, ‘a’ regulatory settlement, ‘b’ licence review’.
  1. For the GC to be outcome focused they should provide more clarity about what is being asked for, and why.
  2. To increase trust, the GC should try to state when something is no longer their position. Can the GC be more open about how and why their position may have changed? For example, when they have a deeper understanding on something which has led to a change in position.
  3. Can GC give clarity about why they have asked for specific data?
  4. On performance tracking, industry would like to see more data published on what the outcomes of different reports and/or actions were.
  5. When senior GC colleagues give public speeches, it is common for industry to thoroughly evaluate exactly what was said. At times, decisions are made as a consequence of these speeches and therefore speakers need to ensure their speeches align more carefully with guidance, to help build trust.

The REDACTED expressed gratitude to members for their feedback and welcomed further feedback via email.

4. Item 3: SmartBash update

The chair gave an update on the SmartBash networking event where he hosted a session on gambling regulation.

  1. About 250 people attended, some attendees were punters who arrange syndicates. There was strong international attendance, and it is expected they will meet again in the future.
  2. Positive feedback was given for the GC’s attendance to the event and how well the GC REDACTED represented the regulator.
  3. Some feedback from attendees at the event is that EDD checks are too intrusive and are leading players to the unlicensed market. Lots of comments were made by attendees about their preference to presenting documents upfront instead of at the withdrawals stage. Attendees questioned the progress on a gambling ombudsman and commented that adjudication takes too long.

5. Item 4: KnowNow conference

IF member will be attending the KnowNow conference to present about the Industry Forum. The audience will be compliance focused attendees from industry.

Members anticipate that there will be a lot of questions about the progress the forum has made since its inception.

  1. Members agreed that there may be some criticism over the delay in publication of Industry Forum minutes.
  2. The REDACTED explained that the minutes were not previously published for Expert Groups prior to last year but that the GC would like to be more transparent and publish minutes for all the groups. There is a backlog to publishing the minutes due to a lack of resource to support the lengthy process it takes to get these published. However, it was assured that this is a priority for the Expert Group team who are focussing on this.
  3. The REDACTED and the REDACTED are happy to coordinate questions from members to GC teams when there are big questions coming from their seniors within operator organisations.

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6. REDACTED

There was no other business to discuss.

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