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Consultation response

Summer 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.

Published
1 May 2024

Last updated
11 June 2024 - Changes

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Contents

Evaluating the impact of relevant changes

Our summer and subsequent November and December consultations highlighted that the Gambling Commission works to assess our overall progress towards the strategic objectives set out in our corporate strategy. This includes our work on Impact Metrics.

The proposals in the Summer 2023 consultations related to the first 3 of our strategic objectives. Those are protecting children and vulnerable people from being harmed by gambling, a fairer market and more informed consumers and keeping crime out of gambling. The proposals also included controls designed to support the following outcomes:

  • children are unable to gamble on the age-restricted products we licence
  • vulnerable people do not experience gambling related harm
  • consumers have access to fair products and services which deliver what licensees promise
  • consumers make informed choices and are confident licensees will treat them fairly and address issues promptly
  • the gambling industry is free from criminal influence and activity.

The consultations noted that we would consider views on the evidence that would help inform evaluation, as well as evidence presented throughout the consultation process.

A small number of consultation responses addressed the theme of evaluation. Points raised included the Commission’s approach to these policy proposals. For example, not introducing a change until the related previous policy has been evaluated and to adopt systematic evaluation of Commission led changes. The need for clarity and some recommendations on the design and delivery of these planned evaluations was also raised. This included support for running and evaluating the results of a pilot of our proposals on financial risk. Support was also expressed for the design of our Social Responsibility Code provisions requiring licensees to conduct evaluation in relation to the effectiveness of specific Licence Conditions and Codes of Practice (LCCP) requirements, for example, Code of Practice provision 3.4.3 - Remote customer interaction.

The Commission welcomes and shares the aspiration for greater policy evaluation. Having taken account of the existing regulatory framework, the White Paper – High Stakes: gambling reform for the digital age (opens in a new tab) sets the medium-term policy agenda for the gambling market in Great Britain and sets out a number of projects which the Commission has committed to deliver. Accordingly, our primary focus for policy development and evaluation is consultation proposals which take forward those commitments.

The consultations indicated we will develop a proportionate approach to evaluation. For example, this appreciates the significant complexities and challenges involved in the evaluation of the overall impact of all aspects of the Gambling Act Review (GAR), particularly the difficulty of attributing any observed changes to particular policies.

In respect of GAR deliverables, we highlighted in our consultation in November 2023 that to help us deliver an important overview evaluation, we intended to commission a partner to help us to design the evaluation framework which will best enable us to achieve this aim. Given that the framework is expected to include activities that are being led by both the Commission and the Department for Culture, Media and Sport (DCMS), we have jointly procured that partner. They will introduce independence, which is a recommendation of good practice in evaluation, and additional expertise to enhance the quality of those evaluation activities. Further details were shared in our blog, 'Evaluating the impact of the Gambling Act Review'.

We anticipate developing an initial evaluation plan which covers the following:

  1. Overarching GAR evaluation, including consideration of:
    1. To what extent has the total package of measures been effective in preventing gambling-related harm to vulnerable groups and wider communities whilst enabling a balance of consumer freedoms, fairness and informed choice?
    2. What has the overall impact of the GAR been on gambling behaviours and the gambling market?
    3. Attribution of individual DCMS and/or the Commission led measures towards shared impact.
  2. Evaluation of organisation specific measures, including consideration of:
    1. Have DCMS led measures achieved their intended outcomes and impacts?
    2. Have the Commission led measures achieved their intended outcomes and impacts?

Once developed, we will roll out this plan, appreciating it may take some time for all the impacts to be fully realised. Likely key areas of focus in relation to Commission-led measures are those that can be expected to deliver the greatest impact on gambling consumers and the gambling market. We will also be keen to capture insights and opportunities through formative, process evaluation activities so that relevant learning can be applied to the design and implementation of subsequent policies.

We expect the developed plan to set out steps that will enable us to understand the overall impact of the package of measures through the development of relevant metrics. These metrics will draw on available information, such as population-level participation and prevalence statistics, compliance information and regulatory data, plus additional information that will have to be collected for evaluation purposes. One of the bespoke data collection methods is likely to focus on the views and experiences of gambling consumers, with the ‘consumer voice’ being a key source for assessing the impact of policies on consumer behaviour and developing our understanding of which policies have led to any observed behaviour changes.

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Annex to the Summer 2023 consultation – Proposed changes to LCCP and RTS
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