Prohibition of gambling on credit cards
- Executive summary
- Background and approach
- Methodology and limitations
- Operator Implementation and customer behaviour
- Credit cards and digital wallets
- Deposits prior to the introduction of the ban
- Displacement to other high-cost credit sources
- Displacement to illegal sources of funds
- Bypassing the ban through other behaviours
- Displacement to unlicensed gambling sites
- Inconvenience to leisure gamblers
- Conclusions and next steps
Limitations of the ban and evaluation
Limitations of the ban
There are a number of exceptions to the ban that are worth consideration, including:
The ban does not prevent absolutely all gambling with credit cards – with the main exception being the purchase of lottery tickets at a grocery store, which will not be captured as a gambling transaction due to the non-gambling Merchant Category Code of the retailer. This was recognised at the time that the ban was introduced, with the decision to exclude this activity based on proportionality and risk of harm.
The ban introduces high levels of friction into the use of credit cards to fund gambling, and prohibits their use wherever feasible and proportionate to do so. However, the Commission cannot extend the ban to scenarios such as using a credit card to withdraw cash from an ATM and then using that cash for gambling, as neither an operator nor financial body can have visibility of that trail of funds. Therefore, reports of indirectly accessing credit card funds may be accurate, but that does not mean that the implementation of the ban was unsuccessful.
Limitations of the evaluation
There are a number of limitations of the information sources that are worth consideration.
The online tracker information asks respondents to report behaviours and gambling activities, but the questions which are listed in the appendices, do not have the level of granularity to understand whether the reported use of credit cards are for permitted activities, such as the purchase of lottery tickets in grocery stores, or prohibited activities.
The online tracker information is reported behaviour which is subject to recall inaccuracies. Inaccuracies are increasingly likely when respondents are asked to think about a prolonged period (12 months), but we have also seen that respondents confuse their own debit/credit card behaviour.
The Consumer Voice qualitative research is based on a limited sample size, with 29 full respondents and, as noted, the sample of respondents comprises a larger number at the higher-end of the Problem Gambling Severity Index (PGSI).
People breaching the regulation are likely to be satisfied that they have done so. Even if they are aware of the prohibition on gambling with credit cards, they are unlikely to report the breach to the regulator.
The impact of Covid-19
The introduction of the ban on gambling with credit cards (14 April 2020) occurred at a very similar time to the first national lockdown measures in Great Britain (legally introduced on 26 March 2020).
The Covid-19 lockdown periods have had a significant impact on gambling behaviour and people’s financial circumstances. For the impact on gambling behaviour, see our Covid-19 datasets.
Due to the multiple, changing lockdown measures that have been in place since March 2020, it has been very difficult to attribute changes in financial or gambling behaviours to the credit card ban, rather than the changing environmental factors.
In the Consumer Voice research, there was a blend of respondents who had not changed their gambling behaviour, and those who reported an increase in the time spent gambling, particularly younger respondents who reported greater boredom during lockdown and felt they could spend more money gambling as they were not spending money on other (temporarily unavailable) activities. It remains to be seen whether these new behaviours continue now that Great Britain has removed its lockdown restrictions for now.
The lockdown restrictions not only prevented the availability of land-based gambling opportunities, but also reduced the likelihood of other activities, such as meeting loan sharks.Previous section
Methodology for key sources
Last updated: 1 November 2022
Show updates to this content
Following an audit the 'Covid-19 datasets' link has been updated.