Consultation response
Autumn 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response
This response sets out our position in relation to the consultation on the proposed changes to LCCP and Remote Gambling and Software Technical Standards.
Evaluating the impact of relevant changes
The Gambling Commission works to assess progress towards the key commitments set out in our Corporate Strategy. This includes increasing our capacity to evaluate new requirements and policies, with particular focus on the commitments we are responsible for in the Gambling Act Review White Paper (opens in new tab)(white paper) and supporting efforts by government and others to evaluate the impact of the white paper reforms. This has been borne out in our consultations, where we welcomed views about evaluation of the proposed changes to the regulatory framework.
15 responses concerning evaluation were received across all topics in the November 2023 consultation (opens in new tab). These highlighted 3 key themes:
Evaluation approaches should reflect the inherent complexity - in common with responses to the July 2023 consultations, respondents referred to the complexity involved in evaluating the proposals in the white paper. Comments included the risks of evaluating while the impact of other previously implemented policy changes were unclear. Others stressed the importance of understanding the interplay between the effects of different policies on customer experience and customer behaviour, stressing the importance of understanding cumulative effects on consumers.
Evaluation should capture unintended consequences - some potential examples were noted, for example, prompting riskier behaviour such as higher spend or depositing behaviour, or triggering individuals in financial distress. Potential unintended consequences were also flagged for particular groups, for example, those experiencing gambling related harms.
Evaluation methods and data need to be inclusive and robust - responses emphasised the importance of embedding lived experiences within the evaluation process, and noted the role of collaboration with industry and financial institutions in gathering meaningful data to evaluate impacts.
The Commission recognises these challenges, which are addressed in our evaluation of the Gambling Act Review. The Commission and Department for Culture, Media and Sport (DCMS) have jointly commissioned the National Centre for Social Research (NatCen) to deliver the evaluation. DCMS published an overview of the evaluation plan in December 2024 (opens in new tab) and the Commission published an accompanying blog post .
The evaluation plan was a deliverable of the Commission’s Business plan and budget for 2024 to 2025, and provides the underlying principles and approach to the evaluation of white paper reforms including evaluation aims and objectives, evaluation questions, the analytical framework, and research methods.
The evaluation approach addresses complexity by use of theory-based evaluation. This utilises a Theory of Change to articulate the goal of policies, their intended impacts and how measures might feasibly lead to those impacts. Importantly, this helps us to ask the right questions, and collect the right data; at the level of an individual policy, as well as being reflective of the interplay between policies.
Complexity is also factored into the evaluation through Contribution Analysis; an analytical strategy that provides a structured way to consider all the evidence generated and answer the evaluation questions we have posed, that the world in which policy changes are taking place is complex and ever evolving, and also helps to identify and factor in unintended consequences into the evaluation process.
Evaluation requires involvement and cooperation from a wide range of stakeholders. We will continue to engage through formal consultation and informally. The experience of consumers, operators and other stakeholders will be key, and we welcome participation in surveys, interviews and other planned research in the coming months. We will use our Industry Forum, and other informal routes, to both promote participation in the evaluation and help shape how we collect data efficiently. Notably, this includes working collaboratively to access operator data that might inform the evaluation and ensuring what we ask for is proportionate and robust. We anticipate much of this data collection will be done on a voluntary basis, appreciating that we have a shared interest in understanding the impact of these changes. A Lived Experience Panel has been established by NatCen as part of the evaluation. The Panel will provide guidance and input on the progress of the evaluation, and ensure that the voices of different groups with lived experience of gambling are considered. This includes individuals with experience of gambling with no adverse effects, as well as those experiencing harm, including those of affected others.
An Evaluation Advisory Group has also been set up by NatCen to provide independent expertise and advice on how to take the evaluation forward, as well as assurance for key evaluation products and outputs. This brings together researchers, academics and evaluators with expertise and experience in the field of gambling policy, research and regulation.
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Annex to the Autumn 2023 consultation – Proposed changes to LCCP and RTS
Last updated: 4 February 2025
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