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Recommendations Digital Advisory Panel Advice

At a headline level we recommend that Gambling Commission continues to focus on its area of core competence, namely:

  • research
  • regulation
  • licencing
  • compliance as it continues to adapt to the new and evolving world of online gambling.

Specifically, we recommend that the Gambling Commission avoids the temptation to build online or digital technologies to monitor the activities of the operators or gamblers. Instead, we recommend that the Gambling Commission continue to develop its understanding of the technologies being used by the operators to allow the creation of licence and regulations that can keep in step with technological advance.

Other recommendations that the Gambling Commission should strongly consider:

Habit Forming Apps

Regulate the use of software development techniques for mobile apps and web-based gambling sites that promote addictive and compulsive usage. This might include increasing the ‘friction’ of using this software but will certainly involve consultation with operators and academics.

Single Customer View

Require the large operators to form an arms-length joint venture that will provide a service that will consolidate a single customer view for all online gambling activity, so improved interventions are possible for both problem gamblers and gamblers at-risk. In parallel, the GC should continue to drive the agenda for research into markers of harm and specific gambling triggers so that this knowledge can be built into this service in the future.

Online advertising

Require the operators to report annually on the progress they have made in directing their online advertising, free bets and bonuses away from problem and at-risk gamblers, as well as children.

Gambling Commissioners

Now that online gambling represents more than half of the total, the balance of skills of the commissioners needs to be adjusted. We recommend that the Gambling Commission consider appointing commissioners with digital awareness and background that are comfortable with the topics referred to in this paper.

The DAP welcomes the opportunity to assist the GC in developing all or any of these recommendations further.

Gambling Commission Digital Advisory Panel

September 2019

Footnotes

1Gross Gambling Yield (GGY) is the income of a gambling operator minus its pay-outs.

2Industry statistics updated 30 May 2019, Gambling Commission – NB: some of the uplift since 2012 can be accounted for by the introduction of the ‘point of consumption’ regulations, which brought overseas-based operators into scope of GB regulation for gambling by GB-based customers. Prior to 2015/16, data for the GB online gambling market is less accurate as this predates the Gambling Commission becoming responsible for collecting data on the whole online market. Nonetheless, remote GGY (from betting, bingo, casino and pool betting) has risen from £4.2bn for 2015/16 to £5.3bn for 2018/19.

3Industry statistics updated 30 May 2019, Gambling Commission.

4Gambling Participation in 2018: Behaviour, Awareness and Attitudes (opens in a new tab)Gambling Commission, 2019

5Gambling Participation in 2018: Behaviour, Awareness and Attitudes (opens in a new tab)Gambling Commission, 2019.

6Gambling Behaviour in England & Scotland. Findings from the Health Survey for England & Scottish Health Survey 2012, NatCen – NB although there has been a numerical increase, this change is not statistically significant.

7 GambleAware Press Release: Gambling companies spend £1.2bn marketing online, November 2018.

8Interim Synthesis Report. The effects of gambling marketing & advertising on children, young people & vulnerable adults, 2019.

9Irresistible: The Rise of Addictive Technology and the Business of Keeping Us Hooked, Adam Alter, 2018.

10 Hooked: How to Build Habit-Forming Products, Nir Eyal, 2013.

11Persuasive Technology: Using Computers to Change What We Think and Do, B. J. Fogg, 2003.

12 Gambling Aware: Remote Gambling Research: Interim Report on Phase II, PwC, 2017.

13We note the Gambling Commission is currently consulting on what action it should take in relation to the use of credit cards to gamble.

14GambleAware Press Release: Gambling companies spend £1.2bn marketing online, November 2018.

15 Harnessing new technology to tackle irresponsible gambling ads targeted at children, ASA and CAP news, April 2019.

16 Regulatory Statement: Gambling Advertising Guidance, CAP, February 2019.

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DAP reflections

Last updated: 14 April 2021

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