CEO Briefing 2025 - Andrew Rhodes speech
10 November 2025Speech by Andrew Rhodes
This speech was delivered by chief executive Andrew Rhodes at the CEO Briefing on 6 November 2025.
Please note: This is the speech as drafted and may slightly differ from the delivered version
Welcome everyone. Thank you very much, Sarah. I've got a few things that I'm going to talk to you about so first thing, thank you very much for taking the time to be here.
The opportunity of days like today are not just the things that you hear about, it's the time and, as Sarah said, with this concentration of people from across the industry to be in the same room together. Because there are lots of things going on at this time and one of the things that I find most valuable out of this is the time to discuss that together, so I'm very grateful for you taking the time to be here today. I'm also really pleased that Sarah Fox from DCMS is here again this year for the Q&A as well.
One of the things I also want to talk about today is also what our remit is and that might seem a strange place to start, but in the four and a half years I've been in this role, there have been numerous challenges to what the remit of the Commission is, and I think that's been much more intense during the last the last 12 months. There's also been actually a reasonable amount of litigation, or threatened litigation, involving the Commission, where people are seeking to challenge our role or trying to focus our role in ways which are more about how they wish our remit was, rather than how Parliament defined it, and that's making for quite a challenging time for us.
But I think together, in between the industry and regulator, we've made a huge amount of progress. There are things which are very different today to how they were a few years ago. But the debate does matter. At one time, I thought, somewhat wrongly it turns out, around the time of the White Paper, that that would be the most intense part of the debate around gambling. I don't think that was true now. I think we're seeing something much more intense now than perhaps we've ever seen, and if anything, perhaps the White Paper dealt with some of those debate points, but in some ways deferred them and that's what we're experiencing now.
I often start these events with relevant statistics and you will know all of those, because you will see what we publish, they will be about your businesses. You can see that on the screen, just how big the market is in this country. Some 22 and a half million consumers gamble on a regular basis in this country. It is a significant economic and social activity that people take part in and continues to be a mass participation exercise but one we all know brings its challenges. And in the debate at the moment, it's perhaps a sad reality that some of the actual facts are sometimes being lost in the fervour of debate. It's not for the Commission to be engaged in a moral debate about gambling. We're here to licence it and regulate it, and that's what we will do. It will be for others to decide what our remit is, but we can't ignore the fact that there is a very, very heated debate around this sector at the moment.
To be crystal clear, our remit is unchanged. If you think about the role of the Gambling Commission, sometimes people overstate the role that we have. Policy is set by Government. We work within the confines of the Act that we've been given and the policy that we've been given and that's our job. Our obligation is to aim to permit gambling providing it's in line with the licencing objectives and that's what we will continue to. But we recognise that the moment there is a lively debate and where we can we are providing the evidence to try and properly inform that debate.
There are lots of questions at the moment about rules and local authorities and where gambling should and shouldn’t be but it's not our role to step into issues with local authorities, that's not what we're here for. It's not what we're funded for. It is for others to do that, but nonetheless that has led to some very challenging media stories and some very challenging cases.
One of the things that has been talked about a lot in recent years, which there is a particular debate about at the moment of course is illegal gambling. We set up our specific team to address this some three years ago and more recently our Research and Statistics team have done some tremendous work in this space, in fact today, we published the final part of our four part series of our analysis on illegal gambling, again to try and inform that debate. We've been extremely active in this space and in talking to a huge number of regulators around the world we haven't found any that have invested in the way that we have. Nonetheless, for the avoidance of doubt, because every time I give a speech, there are people who will pour over it and feel the need to tweet about it, we have been extremely active in this space, but we know we don't have coverage of all the risks that are out there. But you can all see what it says behind me, you can see the scale of what we've been doing just in this financial year so far:
- issued 480 Cease and Desists to advertisers and operators
- reported 188,297 URLs to various search engines and seen 104,192 URLs removed as a result so far
- referred 659 websites to the search engines for delisting
- disrupted 504 websites so that they have either been taken down or geo-blocked.
If you were to roll this back a bit further, there is an even larger set of interventions that that we've made. But what we've done as well is be transparent about the impact that we're having. So we've talked about where we are making reductions able to reduce illegal traffic and what are the most effective interventions. We also have further powers on the way in upcoming bills in Parliament, which will further strengthen this area. At the end of the day, the Act says that one of our one of our obligations is to protect children and vulnerable people from being exploited by gambling. There is nothing more exploitative than the illegal market. We are here for all consumers. If they're self excluded and they take the choice to not gamble because that's the right thing for them, they shouldn't be exploited by criminals, organised crime and unscrupulous people seeking to take that opportunity in the illegal market. That is just wholly unacceptable. Likewise, you in the legitimate licenced sector should feel that we are addressing that challenge because while you pay licence fees, you pay taxes, you have regimes to protect consumers, you have to make delicate decisions all the time, you should feel that there is at least some fairness in that.
Something that I've talked about at previous events as well has been a huge talking point in the last few years is about the relationship that you have with consumers and how consumers have perceived the industry. And one of those areas has been account withdrawals. Some of you will have been a direct part of these conversations. So what we did was instead of just allowing the debates to roll on and form dominant social media narratives and become established facts, we did the work and did the research. So again, we can see the figures there and the huge numbers of withdrawals and extremely high proportions now flowing automatically. Data covering June to September 2024 shows:
- 44.2 million withdrawals
- 96.3 percent cleared automatically
- 3.5 percent cleared within 24 hours
- 0.1 percent that took up to 48 hours.
But consumer expectations have changed. What people expected 2-3 years ago is different to what they expect now. Now when you order anything, it's tracked, you know the name of the person who's dropping it off at your front door, what time they can be there, all of those sorts of things. So consumer expectations about the liveness of their interactions with you, it's just different. But you can see there, that it's actually a very tiny proportion of withdrawals that took more than 48 hours, despite the strength of the debate.
The other thing that we looked at as well is account restrictions. So this was looking amongst larger operators of active accounts during the last 12 months and the proportion of accounts that was restricted. It was interesting to read the Racing Post coverage of this afterwards, where their own survey was showed much higher numbers, but that does go to show that how you conduct research and what cohorts are used can generate some very big differences. There had become a very dominant narrative about the way the industry is operating and what this data shows is yes, there are people having their accounts restricted for commercial reasons, but not at the sorts of levels reported. That is not a regulatory issue, but what we can see is what the actual scale of that is compared to the narrative that we saw in the public debate. And this really comes back to the point that I briefly touched on at the beginning of this, which is how we consider the debate. How we try and inform the debate with evidence over emotion.
In terms of how the sector is performing in the round, when I first did one of these and I think this is the fourth one, so it's been a while, the pattern of what we see now in terms of compliance in the industry is very, very different to what we've seen before. We see some repeated issues, yes. On the whole we have seen the overall trajectory improved. Again our data helps here. Our Impact Metrics tell the tale:
- assessments of Licensee compliance with consumer protection last year (March 2024 to March 2025) over 73 percent of assessments were Good or Satisfactory
- first two quarters of this year though sees nearly 66 percent were Good or Satisfactory.
Now we don't expect perfection. What you're doing is complicated and there are many moving parts. So what we have here is an overall position, which is showing some positive trends, when compared to previous years. We can't really do year on year comparisons because we assess different people and operators. We're not trying to maintain a constant baseline and that would be a particularly significant cost and burden for you if we were to try to do that. So we look at this in a longitudinal way over time. Overall the position is a generally solid one but there are some challenges within that.
One of the areas that we have invested in, quite significantly, in the last three years or so, is data and what we want to get to is something that is a much smarter form of regulation, which could move away from relying on minimum thresholds and backstops. And whilst we are definitely not there yet, we are starting to see the shoots of this from the data we are now able to analyse. What we're finding in that data is it is reinforcing some of the risk areas that we know about and is providing a good, solid evidence base. But having real time information to be able to inform how regulation can work best, how consumers can be best protected and how those who don't need to experience any friction can avoid that friction is a huge opportunity: the data that we have started to be able to pull together is allowing us to move in that direction.
We don't think there are many, if any, regulators in the world that are getting into this level of insight. It's still very early days for Regular feed of Operator Core Data (ROCD), but what we have seen in it - and we’ve got to be careful not to conflate too many things together - is that we could see staking patterns changing according to major events. Not really a huge surprise but being able to evidence in real time is helpful. We've also seen younger people - those under 25 - were the least likely to set deposit limits for themselves, but they were the most likely to reach levels where you might consider financial risks are starting to present themselves. And what we saw in that cohort was operators proactively setting deposit limits because those customers were higher risk.
What this insight is starting to show us is if we can expand on this sort of insight, we can start to get to a position where there is a truly risk based regime which looks at cohort level instead of only what happens when you have spent X, or done Y, because we all know that the individual experience between consumers will vary enormously depending on their circumstances as well as a load of other patterns of behaviour. We should be careful not to conflate this of course with the pilot around financial risk assessments. They are not doing the same things and I'm sure Helen Rhodes will touch on this later on as well as obviously where we are with the Gambling Act Review. Most of the progress that we have made has been by working together. It's operators that supported ROCD by joining in. We work extensively with other regulators around the world because we think that is the right thing to do, but one of the things that I've tried to do in the last few years is change the nature of the relationship with the industry we regulate. I recognise there is always going to be some tension between the regulator and those who are regulated. There are going to be disagreements, there are going to be different interpretations and that is the nature of things, but it doesn't have to be adversarial. That is a choice and what we've chosen to do is try to work together productively, and we've seen a lot of progress as a result.
There are a number of challenges ahead of us and some areas that we want to do some more work in. So one of the areas that we think is problematic, but we think we're getting some good traction now with Government is in the area that we've talked before about around the white label regime. A loophole was created in 2014, and it had its reasons, but it has caused us a problem today. I read some media coverage lately which claimed the Commission has ‘softened’ its position on this topic, but that’s not true at all. The Commission thinks it is wrong that people are sponsoring football clubs who don't have a licence in this country. We just think that is wrong. But it is not necessarily automatically an infringement of the licencing objectives, because if they are not taking any traffic from Great Britain, it is difficult to see how that would be an infringement, but our analysis is demonstrating that it is not quite as clear cut as that. And if you are under pressure as a sector, to consider how you advertise and when you advertise, who you use to advertise - all of those complex areas - we don't think that you should be pitted against people who don't have licence. And the good news is the Government is very, very supportive of that. We've had genuine, grown up conversations about how the world has moved on and enforcement action has been taken in relation to some White Label providers which has meant they have exited the market. I think that is the right thing to have happened, but it's given us a different challenge. And that is one that we're addressing with government and I'm really optimistic that we will be able to do something in this in this space. The answer cannot always be about expecting more and more from the Commission’s limited resources where a more strategic solution could be put in place.
The other thing that I talked to you about when I stood here last year - and I spoke very slowly on purpose to emphasise my point, I remember – I very deliberately urged everybody who has any B2B partners who might be supplying them with games or software, to make sure you do your due diligence as to where they’re doing business.
There will be no more warnings for those actors. I'm not talking about you, I'm talking about providers who may be also servicing the illegal market. There will be no warnings. We have undertaken nine suspensions in the last few weeks, and these are all on issues that we have repeatedly warned about: provision of software and also self-exclusion. There are no excuses. We will not accept any excuses. And you should as a sector, expect to see more enforcement action in the coming weeks and months. We've been working on this area very actively and we don't intend to stop.
One of the other challenges that I think we have, we were just talking about at the International Association of Gaming Regulators (IAGR) at their latest conference two weeks ago, is cryptocurrencies. Now my remarks have been reported variously as committing to different things, so let me just be really clear. The growth in cryptocurrencies amongst younger demographics means that there is a pressure building within the system. The reality is, in some years to come there will be probably a significant cohort of consumers who use cryptocurrencies because that is what they're accustomed to. It is a demographic shift that will find they have no place in legitimate industry because of the currency they use. That is a challenge that probably didn't really exist in few years ago, or not at this level, and as I said in my speech two weeks ago, what I thought was a five year away problem, perhaps a year or two ago, I think is now 18 months to two years challenge. But that's not me committing to saying we're going to start licencing crypto. This is going to have to be government level discussion and it is a government level decision because once you open that door, you cannot close it. It brings questions around are you considering crypto as a source of wealth? Are you considering that as a source of funds? What conditions would you put in place? What are the risks and how do we manage that? But the reality is, and this growth in those demographics means, I don't think governments can ignore that pattern. And it's good to see Financial Conduct Authority (FCA) are doing a lot of work in looking at how we might create a regime for this.
As the saying goes, we are cursed to live in interesting times. This event we like to try and use to set out the future programme and our areas of focus. The reason that we like to do that is it gives you some time to think about this too, to prepare and consider what that might mean, so you know what's coming down the line and what the Commission's going to be interested in. So as I said last year, I talked to you about software suppliers and then our work followed.
But we are in a position with some really material uncertainties at the moment to the sector and the regulator actually. We have a budget coming at the end of this month and there has been a very active debate and focus on taxation of this sector. What started as a harmonisation consultation has become a much bigger debate. It has brought more heat and attention around illegal gambling and how that is taking place in other countries. I mentioned earlier that we set up our team about three years ago and that was because we thought there was an obligation on us for all consumers, but we also thought it would be a growing issue. We have published the latest tranche of our research and you've seen the figures on our interventions and their effectiveness. I think most people although not all, would agree that at the moment illegal gambling is not at scale in this country, but it is nonetheless a challenge.
When I joined the Commission in 2021, we had material uncertainty then too. We had the impact of COVID pandemic. We had the uncertainty of what it would do to the land-based sector in particular. We also had the pending White Paper, which took longer to see published than was expected, for good reasons, but created some uncertainty. That uncertainty created an opportunity for us, which I've not really talked to you about before. What it did was give us an opportunity to invest funds in areas which were covered by the White Paper, but also areas of emerging risk. So the work that we've been doing around data, to get to smarter regulation and that really sharp level of insights, was invested in through this period. The whole of our illegal gambling apparatus was invested in and built during this period, from the reserves that we had built up. If you read our last two annual reports, you will see year on year, a 300 percent increase in criminal cases taken forward by the Commission. Those criminal cases are about betting integrity, they're about cheating, they're about illegal gambling and also the work we've done to support other bodies. That is protecting you as an industry and protecting consumers from being ripped off by unscrupulous people. That increase in our in our activity in prosecuting people taking forward criminal cases was funded through this period, which takes us to where we are now and that capability.
The White Paper is often being discussed in terms of what it requires you to do as an industry, but it also requires us to do a lot as well. The Commission is funded solely by fees and receives no income from the taxpayer. But nor are fees linked to inflation or any uprating. So roughly every 5 to 7 years or so there is a fees review, and this was allocated for 2024 in the White Paper but is now due to take place at the end of this year. This does mean the extra investments we have made in areas like illegal gambling, criminal investigations and data capabilities amongst other areas are not funded beyond the middle of next year, as they have been funded from our excess reserves built up in 2021/22, which will now be exhausted. Just as there is a very active debate about taxation and the sector at the moment, there is also a very active debate about the role of regulators and Arms Length Bodies and to what extent we stand between you and growth and to what extent we ensure a level playing field, which will no doubt be a consideration for the Government as it considers the Commission’s future programme. Our programme over the next year is to continue this work as much as we possibly can, while we await an outcome from the pending fees review.
The last thing I was going to touch upon is market movements. As I said in a speech earlier this year, we've seen a significant growth over time in society lotteries with sales now over a billion pounds. Society lotteries now occupy a very large part of the wider ecosystem that we regulate. Now we don't regulate prize draws but we have seen significant growth over the last few years and there is likely a lot of demographic overlap between society lotteries, the National Lottery and these prize draws. We've seen an interesting diversification in where consumers are spending their money. In terms of participation, last year prize draws now sit just behind betting as a participation activity. So we've seen these things move quite significantly in recent times. There is a continuing growth in casino games in terms of revenue share.
Now I don't often talk about Lotteries at this event, which is an oversight of mine as they are a very significant part of the industry. What we have seen emerging in the last few years, but more so in recent times, is a change where the verticals of lotteries and what you might call ‘traditional gambling’ being held together in the same commercial groups, through various mergers and acquisitions. We’ve seen Flutter and Sisal - the lottery provider in Italy and elsewhere, we've seen Bally’s and Intralot, FDJ who run the lottery in France and actively involved in other areas acquiring Kindred group and Allwyn have made acquisitions in the wider gambling industry as well and I'm sure there are others that I've not mentioned.
Historically those verticals have tended to sit quite separately. Lotteries and gambling have not necessarily sat within the same groups in that way before. But just as we've seen operators diversify how they find new ways to attract and retain customers, we're now starting to see this greater integration with lotteries and that's going to bring some interesting questions. I am not mentioning this for any reason other than we think it is an interesting development and it's going to pose some interesting questions as to how those very different types of products might intersect more. For the first time, two weeks ago, we convened a meeting of global regulators to specifically talk about lotteries because there really isn't anywhere where that takes place currently.
The whole purpose of what we're trying to do today is really three things: trying to give you a sense of what we will be doing in the next 12 months and beyond so you understand where your regulator is focusing its attention; to give you some updates, which will be coming up shortly, to help you understand where we are with a number of developments and, time for networking to simply talk to each other in what is one of the biggest concentrations of operators by Gross Gambling Yield (GGY) in the world. One of the things I note from events like this is you read a series of articles and blogs and everything else, trying to interpret what was meant by a certain phrase or a certain thing. Just come and ask us. Talk to us. Because we waste so much time trying to reinterpret things when we could just have a conversation and I think we've got better at that over time, but days like this are for that.
The last thing I want to say is again, thank you ever so much for giving us your time today. Everybody is busy but it is important that we get the opportunity to spend this time together and I hope we've made it and will make it worthwhile for you today.
Thank you very much for taking the time to listen and I look forward to the Q&A later.
Thank you.
Last updated: 10 November 2025
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