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Panel minutes for 22 May 2025

Minutes of the Digital Advisory Panel (DAP) Meeting

22 May 2025, 10:00 to 12:00 Virtual meeting via Microsoft Teams

Panel Members:

  • Alison Pritchard (Chair)
  • Francine Bennett
  • Simo Dragicevic
  • Christian McMahon
  • Paul Smith
  • Darren Williams.

In attendance: REDACTED

Apologies: None

1. Welcome, apologies and declarations of interest

Attendees were welcomed to the meeting and apologies noted.

There were no new declarations of interest.

The huge contribution and value of the Member leaving DAP was noted. Their depth of knowledge and expertise would be missed.

Gambling Commission Officials referred to the useful bridge that the Member had provided into industry thinking and capability, and how they had supported the Commission to think differently. Their balanced and useful input was appreciated.

2. Minutes of previous meetings

The minutes of the last meeting were approved.

The Chair had met with a Commissioner and referred to the current speed of change in the data environment and in industry. It was important for DAP to keep up with this.

3. Review of actions

REDACTED.

4. DAP: maintaining our impact into the future

The DAP Member leaving the Panel referred to the valuable experience he had gained from working with the Commission. The new Chair was welcomed as a natural fit to the role. The Chair’s inspirational speech at the spring conference, regarding the data programme, was referred to.

The DAP Member highlighted the broad scope of DAP as laid out in the terms of reference. There had been a focus on data and analytics, reflecting the Commission’s journey and business plan priorities.

By focusing on internal initiatives, DAP could directly influence the Commission, but there was a question as to whether the panel’s focus should be wider considering its remit.

The DAP Member provided an analysis of the global industry, highlighting the pace of change in the online gambling industry which would give rise to new risks, opportunities and regulatory challenges which could be useful in considering DAP’s future priorities. He referred to the PESTLE (political, economic, social, technological, legal and environmental) analysis highlighting the following:

  1. There is a trend towards regulation and licensing, with complex political dynamics around taxation and regulation.
  2. The UK has a mature industry (both land-based and online).
  3. The illegal market is a growing challenge across most jurisdictions.
  4. There is a focus on harms and problem gambling, with continued political pressure around consumer protection. There is a shift in approach towards responsible gambling.
  5. The Gambling industry worldwide is a half-trillion-dollar business. Land-based gambling is declining overall, however land based remains the major segment and some forms are growing faster than others. The digitisation of slots requires investment.
  6. Lotteries remain the largest gambling vertical globally. Digital lottery and instant win games are a growing vertical.
  7. The gambling industry is competing against other entertainment avenues such as, for example, Netflix and gym subscriptions.
  8. Products are being developed to meet the interests of younger generations. These include digital content engagement and social and community elements.
  9. Advertising remains controversial. Italy, for example, has banned the advertising of gambling, however advertising is still commonplace. As soon as a boundary is set, the industry works around it.
  10. On the technological side there are lots of developments. The traditional casino format and live gameshow format has evolved. Arcade style interaction games are growing. Aviator games are making a lot of money.
  11. There are more sport betting opportunities. There is a growth in automated betting and heatmaps and analysis after a game.
  12. There is a focus on personalisation, with lots of services being offered on top of a game, for example the introduction of the community element and collectibles overlayed.

The Panel Member concluded that:

  1. DAP’s focus on the technological piece of interest and broader technology, for example AI, makes sense. DAP could continue to look at these areas and continue to consider how the Commission can respond.
  2. There may be further opportunities to collaborate with the Advisory Board for Safer Gambling (ABSG), noting the research and data experience in that group. Collaboration opportunities and the interface with the Lived Experience Advisory Panel (LEAP) and Industry Forum (IF), could also be explored.
  3. Noting a potential skills gap, in terms of industry knowledge, opportunities for DAP Members to work with the Commission to engage with industry, for example, by attending conferences, could be useful.
  4. DAP could be more public with its opinions. Regular communication would broaden the influence of DAP on the sector.

A DAP Member referred to the engagement with industry.

A DAP Member confirmed that there had been visits to suppliers and operators to get a better understanding in the past, but there had not been an active need to do this more recently.

A DAP Member referred to the positive involvement of DAP at the spring conference and that a blog written on the data programme had been picked up by the trade press. More recently the focus on the internal had been the priority.

Commission Officials referred to building industry confidence through engagement. It would be helpful for DAP to consciously engage on certain matters, as part of a rolling piece of engagement work against a plan of activity. Attendance at industry conferences would provide the opportunity to get a strong feel of where the industry is at and the Commission would be interested in DAPs reflections. DAPs views on the Regular Feed of Operator Core Data (ROCD) product and DAP’s perspective on aspirations for the future would be helpful. There may be the opportunity to undertake operator visits with a particular focus, for example with the 3 operators involved in ROCD to contribute to the lessons learnt review. The research and statistics team would be keen to share insights from industry.

REDACTED.

Regarding industry trends and future movement, a DAP Member referred to research considering personality types and traits and how they map to more effective marketing.

It was queried if the Gambling Survey had a question on personality traits, as there is a particular impact on children and there may be the opportunity for more research in this area. This suggestion was put forward as example of how DAP Members could draw from their experiences and knowledge, to put forward research and thought pieces for Commission consideration. This would be an alternative way of interacting with the Commission.

The Chair agreed that a live DAP think piece, continuously evolving, was a positive suggestion.

A DAP Member welcomed opportunities for connections with industry, referencing the use of AI as an example area whereby it would be useful to build an understanding.

The Chair referred to the opportunity to create an ongoing thematic piece of DAP thoughts which could be updated regularly.

REDACTED.

A DAP Member highlighted that recruiting a new Panel Member with knowledge of industry, and potentially upskilling other DAP members in this area was important.

The Chair agreed that whilst it would be difficult to have someone on DAP currently working within the industry, previous experience of working in industry would be desirable.

A DAP Member highlighted the importance of engagement with third parties. It is helpful to find out what the industry needs, their priorities for discussion and what we can be done to support them. It would be useful to have cross sector approach to these conversations.

The Chair suggested that Commission Officials could help set up sessions with industry and for DAP members to attend industry conferences.

In response to a DAP Members query regarding the industry’s current mindset, another DAP Member referred to the period of change and that the industry was waiting for a more settled period. All recent changes would need to be evaluated, with the Commission needing to show how the industry is better protecting consumers and how the market is fair and open for consumers. It will be a challenge for the Commission to show how it is building the evidence base to demonstrate this. There is also a lot of competition and innovation within the industry because of AI, which will be a big challenge for the Commission to keep pace with.

REDACTED.

5. Updates

GMTS DAP support

A DAP Panel Member reported on a meeting with a Commission Officials regarding the Gaming Machine Technical Standards (GMTS) review. Key points included that:

  • the Commission is looking for support from DAP when the response is received from industry
  • the ambition is to consolidate technical standards from 5 documents into 1
  • updating machines would be a requirement with standards being enforced on all machines. Legacy machines do not currently follow modern standards
  • DAP Members would meet with Commission Officials again when feedback had been received.

REDACTED.

REDACTED.

REDACTED.

REDACTED.

REDACTED.

Commission AI update

A Commission Official referred to the paper that had been shared which identified 4 areas where the Commission expects to encounter AI and seeks to establish principles and ownership to assist in developing use cases and appropriate controls to manage risks and embrace opportunities. The tension between being risk averse with the need to use AI and the different approaches to AI within the Commission were referred to, with the risk appetite statement including, low appetite, open and high tolerance. There is tension between the risk appetite which is led by IT and those who are considering how utilise it. There was an acceptance that this needs to be addressed internally. DAP views were sought on whether the areas identified cover what is required, who in the Commission should own AI, and the various principles put forward.

The Chair highlighted the importance of establishing ownership. She referenced her recent call with a Commissioner in which they discussed the mismatch between risk appetite and tolerance.

A DAP Member commented that the areas of work appeared comprehensive and mutually exclusive. It was suggested that ownership should stay with the people who own the area of work, as AI is another tool for the experts who manage strategies with the appropriate support.

In terms of the Civil Service’s position, the Chair explained that whilst there was now some limited agreement on how AI can be used within the in public sector, it was hoped all public bodies were now going as far as they could in relation to the guidance, within a relatively safe space.

A DAP Member referred to the internal guidance for regulators issued in 2024 (opens in new tab), which includes 5 individual principles when managing AI. Whether or not the guidance is followed and adopted, these principles should be used when shaping the policy. There is also a code of practice for cyber security (opens in new tab) which should be referred to.

A DAP Member suggested consideration of the consumer use of AI, for example do people use AI to find illegal gambling, subsequently putting themselves at more risk?

A DAP Member referred to the safe and effective deployment of AI within the Commission. A likelihood or impact approach to risk could be used. It is helpful to combine variables and Red, Amber, Green (RAG) rate them. The language in the excerpts provided could risk the Commission being seen as out of date and lead to questions around its reputation and/or relevance in this area.

The Chair referred to discussions with the Commission Chair. It was recognised that the measurement of risk in the past had not considered the risks of not using AI.

A DAP Member referred to the need to consider the data available and how it could be profiled unfairly, and in a way that the Commission does not want to be received. The Commission needs to consider what falls under the scope of AI and where it wants to use it. How the Commission may wish to automate processes and how far information is trusted should be given further consideration. The legal and regulatory context will also need to be considered, and it should be determined how far the Commission wants to go, and how fast. The Commission’s tone in relation to AI should be consistent. Everyone should be using the same corporate messaging.

A DAP member noted that all were on an AI journey and there were many different models. Whilst there should be enough control of infrastructure, there should be recognition that AI models move direct control further away.

A DAP member referred to the risk appetite not being broad enough to truly reflect the appetite of the organisation.

The Commission Official confirmed that the risks identified were not specifically in relation to AI but are the areas within the Commission’s full risk statement that are relevant to AI.

A DAP member referred to the approach to communicating all aspects of policy with staff and the need for training on the types of AI and how to use AI well. It is important to be clear on what is meant by AI and its strengths and weaknesses.

The Chair suggested that the 3 areas could be further defined and owned by the owners of the affected services and/or areas. When considering the internal efficiency of organisation for example, this should be owned by the Chief Operator, the second area regarding effective regulation should be owned by the Head of Compliance. There should be a focus on use cases with ownership embedded with those utilising it.

REDACTED.

6. Skills audit and/or recruitment

The Chair referred to the review of expert groups.

REDACTED.

REDACTED.

REDACTED.

REDACTED.

REDACTED.

REDACTED.

The Commission Official referred to the skills audit and asked that all DAP Members update or complete this form for the first time so that DAP skills can be updated.

It was suggested that the 2 vacancies on DAP could potentially be replaced with one individual, and that the skills audit would help clarify what skills needed to be recruited.

Panel Members referred to the challenge of completing the skills audit when there was no distinction between awareness and expertise and interest. A three-category approach was suggested whereby people could indicate if the person had the core skills, was aware and experienced, or did not have the core skill. This would help differentiate if someone had the deep technical knowledge that might be required by DAP or not.

REDACTED.

REDACTED.

A DAP Member referred to the restrictions placed on potential members, that they have no direct involvement in and/or are not paid by industry, have no shares in gambling companies. International recruitment was suggested.

7. AOB

There were no items.

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