Bingo Association AGM - Tim Miller speech
02 May 2025Speech by Tim Miller
This speech was delivered by executive director Tim Miller at the Bingo Association AGM on 1 May 2025.
Please note: This is the speech as drafted and may slightly differ from the delivered version.
Thank you everyone and thank you for that introduction.
What do I want to speak to you about today? Well I want to look back on some of the areas we’ve worked on over the last year that impact you. I will reflect on some of the current issues as well. And as part of that I want to cover how much we value the engagement we’ve had from the Bingo Association. Because one thing that runs through all the areas I will talk about today is the constructive and helpful engagement we’ve had from Miles, the team at the Bingo Association and you as its members. So let’s start there and why having a collaborative relationship, based on compliance at the earliest opportunity is so important to the Commission, you and consumers more widely.
You will have heard me, or Andrew our Chief Exec, talk about this before but at the Gambling Commission we want a collaborative relationship with the gambling industry, based on supporting compliance at the earliest opportunity. And we want this because we know that through working together we can achieve far more - and often more quickly - than if we simply rely on our formal powers alone. Now I’m not here pretending that means we’re going to agree on everything and clearly, there are going to be times when things can be more challenging. That is a natural and healthy part of the relationship between a regulator and those it regulates and actually demonstrates the independence from industry that we have as a regulator. But wherever we can, we want to work with you in collaboration to make gambling safer, fairer and crime free.
And the approach taken by the Bingo Association in recent times has been exactly what we need when it comes to the issues that matter. We’ve just entered the third year of implementing the Gambling Act Review. In the same time period we’ve made great strides in strengthening the evidence base around gambling. These are not easy things and there have been plenty of times where the easy path for industry would have been to call for more collaboration but then step back and either wait for others to act or indeed sling some mud or double down on defending the status quo. To be honest it is frustrating when we have created opportunities for collaboration, such as the creation of Gam Protect or the financial risk pilot, and we face a kind of reverse ‘I’m Spartacus’ moment with very few operators prepared to step forward and participate. However, in contrast the engagement we’ve had through the Bingo Association on many issues has been positive, practical and constructive.
And its this commitment to collaborative working that we want to see and are so pleased to have established with the Bingo Association. And given what we have going on at present, that is really important for both our work, your businesses and consumers.
One such issue is our current consultation on Gaming Machines. This is an important consultation for everyone in this room and at the Commission – as with all our consultations – we are determined to get this right.
As you will already know, the consultation is focussed on the gaming machine technical standards and the related testing strategy.
Just this week I’m pleased to say that we had an opportunity to demonstrate how have listened to you and others and confirmed that we are extending the consultation period for responses, extending the deadline past the initial closing date of 20 May by another two weeks to 3 June. This will give more time for those impacted or interested to make submissions, provide data and give us the information we need to get to the right outcomes.
And the decision to extend, is just another example of where we can make decisions off the back of positive and constructive engagement from stakeholders. You are committing resource, time, money and research to make sure we get the information we need from your industry on this. And again, that’s important. The White Paper set out that a top priority is ensuring that gambling happens safely. The Commission of course shares this commitment and this consultation proposes how we could implement gaming machine changes in the land-based sector.
Our intention was to arrive at a package of proposals that protects vulnerable people, ensures consumers can make informed decisions about their gambling and recognises the need to minimise the impact on consumers who are not experiencing difficulty in managing their gambling safely. We do however remain keen to hear workable alternatives to our proposals. But we also need to be clear. The starting point for alternatives should aim to achieve the same policy objectives. There is no going backwards when it comes to consumer safety here.
That said, we also recognise that regulatory changes that impact the design of machines can come with considerable costs. So it is absolutely vital that we get the evidence that will assist us in measuring both the likely regulatory impacts of the proposed changes and the likely costs of implementing them. Whether that be from consumers, gambling businesses or other interested groups. This evidence will be invaluable to helping make a robust assessment on whether the costs involved are justified by and proportionate to the benefits to consumers and the licensing objectives. So the work being done by all of you in this room is really important to that process. Keep going, get those submissions in. The evidence provided can and does make a difference when it comes to us finding the right outcome.
And getting better evidence and better data is vital across gambling as well. This is something the Commission is of course committed to and I’m pleased to say this is another area that we’ve been really pleased to see the level of commitment from the Bingo Association as well.
One key area for us to strengthen the evidence base in recent years has been the development of the Gambling Survey for Great Britain (GSGB). As the new methodology for our participation and prevalence statistics, we are really pleased with the granularity and regularity of the data, the breadth of what it can give us and scale as well – GSGB is the largest survey of its kind in the world and will see around 20,000 responses this year.
But whilst there is no going back we of course want to make sure the GSGB is as strong as possible. We have started on the road to making improvements based on the recommendations of Professor Sturgis but part of improving it is listening to feedback from stakeholders like yourselves.
Now we recognise the concerns that some have about GSGB. But whilst some have chosen the tactic of trying to shout loudest, and demand we go back to a methodological world that can simply no longer work in the way it needs to. Or insisted we rely on other surveys that are less frequent and do not give a GB-wide perspective, the Bingo Association has once again been constructive and focused. As a result of that approach, we have been able to collaborate on new questions for the GSGB that will give us better insight into participation in Bingo. The data collection under those questions has already started and we’ll begin publishing this data later this year. But again, constructive feedback, backed up by evidence, in a spirit of collaboration has led to this and I expect will mean better data and better outcomes for all of us.
Another area we are keen to deliver better outcomes through working with you is in tackling illegal Bingo. We engage with the Bingo Association regularly and recently you have shared through the team at the Association that you are becoming increasingly concerned about bingo offered without a licence. Bingo which does not appear to follow the rules for relevant exemptions either.
Keeping crime out of gambling is of course one of our Licencing Objectives and as with the others, something we take very seriously. And I can tell you today, where we have sufficient evidence of this, we will always look to take action. The problem we have at the Commission though is the level of reports we have received does not always appear to match the level of concern expressed.
So I want to reassure you all here today, intelligence shared with the Commission in confidence is just that. We will make use of it to crack down on illegal operations and will treat it in confidence. The reporting system is easy to find on our website and it’s literally called 'Tell us something in confidence'. We want to make sure that everyone in Great Britain playing Bingo is doing so safely, fairly and – unless its reliant on a legal exemption - with licenced operators who abide by our rules as well. But we can’t take action if we don’t have the evidence. This is particularly true for illegal land-based activity. The evidential burden that the courts expect us to meet is high for criminal prosecutions. So I would encourage any of you that has evidence of this type of illegal practice in your communities to share that with the Commission or your Licensing Authority.
And on that, I’ll leave it there. The Gambling Commission is committed to delivering safer, fairer and crime free gambling. We can best do that when we can work constructively with industry on the basis of compliance at the earliest opportunity. With the Bingo sector, I’m happy to say we’re doing just that at the moment. Let’s carry on in the way we have been. Thank you.
Last updated: 2 May 2025
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