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CEO Briefing 2026 - Sarah Gardner speech

06 November 2026

This speech was delivered by Acting Chief Executive Sarah Gardner at the CEO Briefing on 5 November 2026.

Please note: This is the speech as drafted and may slightly differ from the delivered version.

Hello everyone, thank you Sarah for that introduction. As many of you know from previous years at this event, it’s normally my role to be the one compering proceedings today. Now of course this is not a normal year and so it’s great to have the chance to speak to you all today as Acting Chief Executive of the Gambling Commission.

And the fact that this has been a year of change at the Commission is probably a good point to start with, especially as the coming year will also be bringing further change, both at the Commission and, more importantly, in the sector more widely. In fact, it can be argued change is the only constant in the gambling sector in recent years.

I think that made it all the more important for me and the team at the Commission that on the list of things not changing was this event or our commitment to constructive engagement with the industry. Having so many senior leaders from across the gambling sector and colleagues from the Department for Culture, Media and Sport (DCMS), all in the same room, for a morning of discussion, is arguably more important this year than it ever has been. It’s a unique gathering in Great Britain (GB) and one I know the team at the Commission always gets great value from. So thank you - in a year of change - for also being part of this constant in the calendar today.

And there is plenty of important topics to get our teeth into today. After I’ve finished speaking we will have updates on our Policy work, our latest Research and Statistics output and on what our Operations team are seeing and doing as well. I’m also really pleased that Emma Floyd, Director for Sport and Gambling at DCMS will be joining myself and the team to answer your questions later.

But first it’s my turn. The last year has had its challenges, and partly related to that, it’s also been another year of big delivery at the Commission, on the Gambling Act Review, on the National Lottery and in our work to tackle illegal gambling. So I’ll talk about all of that and how these areas look going into next year. And returning to how change is a constant, I also want to repeat that a constant for the Commission is our commitment to engagement with those we regulate. We want a collaborative relationship with you, built on compliance at the earliest opportunity. But first I think its worth pausing to comment on where the gambling sector finds itself today.

Before I go any further, I think it’s important to acknowledge last week’s Budget and the changes that has brought to parts of the sector. The Gambling Commission does not advise on taxation, it’s not our role, but we appreciate the importance that anything announced by Government can have for the businesses in the sector and we, like you will see what impacts that may or may not have. I’ve already spoken to some of you myself this week about your thoughts and I know Sarah Fox has as well. These decisions are for Government and that is exactly right, but we recognise how taxation and regulation are key factors influencing how you provide your products and services to consumers. We want to understand that. For our part, we will keep engaging, we will continue to listen to you and where you have questions on issues that are within the Commission’s role or remit please do continue to get in touch and to raise them.

But whilst this understandably is at the forefront of our minds, we must also remember where the industry and consumers are and the shape of the market. And to usefully do that, we need to get into a little bit of the detail. I also want to be clear that we understand the wider cost pressures on industry. Heating bills have gone up for everyone in recent years and that’s as true for every betting shop and bingo hall in the country as well, to name one example. The numbers I’m about to share don’t then tell the whole story in that regard. And as audiences go, you don’t need me to tell you that the gambling sector in Great Britain grew to £17.5 billion by Gross Gambling Yield (GGY) at the end of last Financial Year. You know that and you probably prefer other metrics more useful to your businesses anyway. And you know as well as we do, that our official statistics from the Gambling Survey for Great Britain (GSGB), cite headline participation in the past 4 weeks as stable at 47% for 2025. But what I think you probably do want reassurance on is that we, like you, are interested in the more granular picture available to us and that we pay attention to this detail.

So whilst we have an overall picture of GGY growth in GB – 4.4% last financial year - if we dig into where that growth is coming from, we see some interesting numbers. Parking Lotteries for a moment, when we focus on the rest of gambling, we see remote casino, betting and bingo grew by 6.9% year on year to £8.3 billion by GGY. And if we drill deeper it becomes apparent that online casino is basically driving the entire headline figure for growth across pretty much the whole sector, certainly for remote and online – up £736 million in GGY, compared to the whole gambling sector going up by £728 million in the same period.

And in land-based gambling we see another nuanced picture. The GGY for land-based sectors went up 1.1% in 2025/26 – so when you factor in other costs this is a tough picture for many companies here. But there are market changes here too – Adult Gaming Centres appear to be bucking the wider trend, at least on GGY, with an 11% growth compared to a drop in non-remote betting, negligible growth in casinos and an 8% growth for non-remote Bingo. Again though, the wider picture here is that if you compare the GGY for machine gaming today to before the B2 machine stake cut, back before the pandemic, machine gaming is still around a £100 million down.

The British gambling sector clearly remains as fierce as ever, but from looking at the numbers and speaking to many of you, we can see the impact of that is felt unevenly and you are the ones feeling that pressure.

The lotteries sector as well, sees stable participation but we know how much pressure this sector now feels for those of you in it. GSGB data gives us a picture on how licensed lotteries are now competing with prize draws in a way that was not the case before the pandemic. The GSGB gives a participation rate for Prize Draws in 2025 of just over 8% – similar to online Instant Win Games for the National Lottery and society lotteries combined. As a result of the Gambling Act itself, we don’t regulate prize draws, albeit we police the border to prevent illegal lotteries multiplying. But we appreciate for many of you in the lotteries sector this is competition you are grappling with. And that spills over again into the wider gambling sector as well. We hear you and we see it in the data.

And I talk about this to make a point. Sometimes we get told or we read in the press that the Commission is aloof to the realities of those it regulates. Worse, I do get told from time to time - or again, read in the trade press - that the Commission is an object of fear for some in the industry. Whilst there are of course good reasons for you all to be mindful about the Commission and how we may interpret your decisions, or how we may react if we find things that don’t meet our rules, this is different.

One of the opportunities stepping up to Acting CEO this year has been having more opportunity to meet with you, see your businesses and discuss with you our work and our priorities at the Commission. But also to hear from all of you about what this means for your businesses and how you see the sector reacting, developing and innovating. At the Commission we want your feedback and there is no caveat on that. And no one should fear talking to us about concerns or challenges. We want to hear from you. Especially where we are going to disagree. We act where we have a regulatory basis, nothing beyond that. Constructive challenge then helps us and you – it’s not something we fear and we don’t want you to fear our reaction.

We have our role and remit. As competitive businesses you have your responsibilities also. But within that, where appropriate, we want to be supportive. That means taking action to frustrate attempts to provide illegal gambling at scale in our jurisdiction. It means asking you for ideas on how we can reduce regulatory burdens – as we did this Summer with our call for proposals. It means being transparent in our approach and our expectations and improving understanding of regulatory requirements through our Operator Engagement Forum and other work with you. Everything is driven by delivering for consumers and the wider public, but within that we want to work through collaboration.

But that doesn’t mean we will concede either if we are clear on what the evidence is telling us. In this room, we all know we won’t always agree – it’s the nature of the relationship between regulator and regulated. But not agreeing is not the same as not listening. We want to listen and if we can create more space for you to share your feedback, insights and, yes, concerns then we are happy to look at that. Again, we want to hear from you while we continue to deliver against our priorities, making improvements along the way, armed with perspectives and evidence.

To that point, this morning we published new research, making use of new questions in the Gambling Survey for Great Britain, that gives us the best picture of the illegal market in Great Britain we’ve ever had. Ben Haden, Director of Research and Statistics will be talking to us all about that later and I have no desire to steal all the best bits of his presentation. But there are a couple of points I want to highlight. Last year we explained we couldn’t put a number on the scale of the illegal market but that we would continue to explore that - with methodologies that can be replicated and with fully published data. Today, 12 months on, this work demonstrates a big step towards that goal and gives us the best data we’ve had on use of the illegal market. And as we continue to collect this data, alongside other sources of evidence, we can track this. With other trend data we can then use it to help target our interventions. Secondly, consumers are telling us that in the year up to this April, 1% of respondents in Great Britain had engaged with illegal gambling websites over the previous 12 months. Among those respondents who gamble online, excluding the National Lottery, 4% had engaged. This in itself is a baseline and we can build trend data from this point which, again, we can and will make use of to evaluate and target our interventions. And when combined with other data sources we have published, including last week’s innovative analysis of open banking data, it really starts to develop the picture of the illegal market.

These insights wouldn’t be possible without a consumer survey of the scale and regularity of the GSGB: one of the largest surveys of its type in the world. We know – I know – that some of you have expressed concerns with the GSGB and how it is used by some as part of the wider debate on gambling. You should not fear the Commission and we are not afraid of your feedback, indeed we welcome it where it is constructive and highlights new and emerging issues which can help build an informed public debate on all sides. As with most comparable national surveys, GSGB is not fixed at any moment in time, never to be changed - quite the opposite in fact. We know no statistic is perfect and the estimates from consumer reported surveys require continuous review and refinement as with the wider data all of us hold, use and manage - including in industry but beyond too. As an official statistic and in line with good practice, the GSGB will always need to iterate - not least to stay relevant to those we ask to complete it in a fast-changing gambling environment. It is of course also at a relatively young age and we want it to complement effectively the wider datasets needed to triangulate effective answers to questions posed. As indeed we are doing with the Illegal Market datasets. That's precisely why we consulted on the methodology underpinning GSGB before launch, sought further independent review of the methodology and development and also invited the Office for Statistics Regulation (OSR) to consider what improvements we could make in line with their Code. We have made good progress on this work but this is a work of continuous improvement and the Commission looks forward to their next report which we will welcome in the spirit of what more we can do as the custodians of the most authoritative and comprehensive study of consumers' experience of gambling in this country. I hope what you see today on illegal market research underlines why having a survey of this scale and nature is so important and will continue to be - but also why we need to do more to contextualise it in a wider evidence base, an evidence base we can and should all be part of building.

Sue Young, our Executive Director for Operations is also speaking later on and will be talking about our work to tackle the illegal market as part of her wider presentation so I won’t dwell on this for long. But we are a year on from last year’s Budget, where the Government committed £26 million to the Commission over three years to help tackle the illegal market. In that time a Minister-led Taskforce has also been set up, we have called out the social media giants on advertising and happily started to see some positive responses to that, although we want to see more. We have continued to push forward with our world leading approach to disruption and now, just over six months since the first £7 million of the new funding arrived, we have been able to really start to scale up our capacity.

We want to do more. But I think it’s worth reflecting on a couple of numbers here – and apologies to Sue for stealing a little of her thunder. If we compare last financial year to the first six months of this one:

  • 741 Cease and Desists were issued to advertisers and operators last year
    • compared to 1005 Cease and Desists in April to September
  • nearly four hundred thousand (397,527) URLs reported to various search engines and over two hundred and fifty thousand (266,667) removed in the last Financial Year
    • this year, over 7.8 million (7,824,932) URLS reported and over 3 million (3,038,969) URLs already removed
  • over a thousand (1068) websites were referred to the search engines for delisting 
    • now we’re already over two thousand (2201) websites referred in April to September
  • over a thousand (1134) websites disrupted so that they were either been taken down or geo-blocked last year 
    • already more than that (1668) taken down this year.

There is more to do. These numbers only paint a picture of some of the activity we’re doing and some of what we need to do. And I don’t rule out that the focus of our interventions may evolve away from some of these numbers as we continue to develop our approach. Sue will be talking more about the wider approach and impacts later on. And there will be learnings along the way. But we are making progress here. We want to continue working with you on gathering intelligence, on building the evidence base and on frustrating unlicenced, illegal firms who are trying to operate at scale in Great Britain.

So more delivered and more to follow on the illegal market. The same can be said for our other priorities as well. Shortly we will publish our updated Business Plan for the remainder of the financial year. We committed to publishing this update once we had certainty on our Fees and so this is our first step in providing transparency now we have that certainty. Clearly we didn’t get everything we wanted and whilst ring fenced funding elsewhere will mean an expansion of our capabilities in some areas, we will need to continue to be disciplined on our core spending and core functions in the years ahead.

The next step will come next year with the publication of our new 5 year Corporate Strategy. We’ve been working on this for some time and even later today, we are getting insight from some of your colleagues in industry on how the new Strategy is shaping up.

Whilst our Board are still to agree the final shape and detail of our strategy I can provide some headline themes it is likely to include. We will recommit to the headline regulatory outcomes we are here to deliver for consumers, the wider public and you as licensees. Those outcomes are drawn from our licensing objectives and National Lottery duties, but importantly focus on our role and remit in delivering those. This will ensure an ongoing focus on our core remit as we move into the third decade of the Commission being operational.

In addition to a focus on how we positively impact those outcomes, our Commissioners have also recognised the challenging fiscal environment in which we will operate over the next 5 years and the need for us to review and improve how we deliver our functions. We must demonstrate how we are making the most efficient use of our resources, as a smarter, more tech enabled and informed regulator. We must demonstrate value for money use of our resources and ensure regulation is proportionate to you as licensees and by extension for consumers.

We are working on the changes we believe will improve our impact, efficiency and proportionality over the next 5 years across 5 priority areas:

  • regulating in the public interest – including how to understand our impact and the impact of recent changes, and how we work with you to deliver improved licensing experience and compliance at the earliest opportunity
  • preventing crime – work to tackle illegal gambling will be at the forefront, but as will our Anti-Money Laundering (AML) supervision given the UKs upcoming Financial Action Task Force (FATF) evaluation, a priority for Government
  • a smarter regulator – we think there are real opportunities to improve how our digital and data capabilities can improve outcomes for consumers and you as licensees. We also want to maximise the use of new funding for regulatory research to further improve the evidence base
  • a successful National Lottery – this strategy period will cover a core part of the 4th National Lottery licence.
  • strong organisational foundations – focused on the internal foundations essential to the operation of any high performing organisation.

Before we get to the new Corporate Strategy, we are also working through a number of our remaining commitments from the 2023 Gambling Act Review White Paper. Helen Rhodes, Director of Policy, is up next to update in detail on this work. For my part though I wanted to acknowledge the progress we have collectively made on implementing the Review and acknowledge the work we all need to complete.

We are now, getting closer to the end. Whilst we know there is still work to do, the publication of the Gaming Machines consultation response in September and our announcement of our decision to implement Financial Risk Assessments were two big milestones in what the Commission has left to implement.

On Gaming Machines, we have welcomed the input and engagement we have had from industry throughout and I think this is reflected in the decisions we have made in the response document. Whether or not you agree with all the decisions we ultimately made, those decisions were better informed because of the evidence presented to us during consultation and engagement. That’s not to say we don’t appreciate the changes we’ve committed to don’t come with burdens for affected businesses but we are committed to a phased implementation and have begun engagement with you as our licensees, but also technical service providers, Test houses, UKAS and Trade Bodies to make sure this goes smoothly and that everyone has a chance to give us feedback.

And when Government is also looking at how gambling exists on the High Street and in our communities, industry working with us on these changes – changes with consumer protection at their heart - is I think an important signal to send.

Turning to Financial Risk Assessments (FRAs), I think the main thing I want to say is that following the announcement in the Summer we asked leading operators: both those who were involved in the Pilot and those who weren’t, to lean in and participate in implementation planning. I am really pleased to see that has been happening and I am sure implementation of FRAs will be stronger as a result. FRAs were identified as a frictionless way of identifying high spenders at risk of harm in a way that would then reduce friction for the rest of consumers. That’s what we were committed to following the White Paper. The Pilot itself has increased our understanding of the risks these high spending consumers are facing - between two and four times more likely to have a debt management plan and between two and five times more likely to have a default in the previous 12 months than consumers in the wider population. And the Pilot also showed that the checks can be delivered in a way that far exceeds the benchmark set for them in the White Paper. 97% of those spending above the threshold levels could be easily and frictionlessly assessed for financial difficulties – significantly higher than the 80% estimated in the White Paper. With the ongoing input from industry we are finalising the consultation response for publication in the coming weeks but that is not the end of the story. We still want your engagement and we remain committed to staged implementation, to make sure we get this right – for consumers and for industry.

One of the topics that comes up a lot when FRAs or other measures we’ve implemented from the White Paper are discussed is evaluation. Evaluation is crucial to the Commission’s work and for a programme such as the Gambling Act Review: it was vital to be open on how we would approach it in advance. Working with DCMS we jointly tendered and contracted NatCen to conduct a full evaluation of our work on the Review and its impact. We expect the first report, detailing initial findings of our implementation of the Review so far to be published early in the New Year. Whilst we’re still implementing other Gambling Act Review commitments, that report of course, will not tell the full story. And we will be looking for more industry engagement on evaluation as we continue. But I think you will agree where we have initial findings, publishing them will help what comes next. We are committed to acting transparently on this as well as the rest of our remit and you can expect more on this in the year ahead.

I want to finish on some reflections on changes at the Commission but before that, I want to take a moment to reflect on the changes we see in the lotteries sector. As I mentioned earlier, our data is telling us as it is telling you in the sector, how there are emerging pressures on the sector. And whether it’s through ownership or other ways, there is also, worldwide, a continuing blurring of lines between traditional lotteries and gambling more widely. That is something we are paying attention to. How we regulate the National Lottery compared to society lotteries is different due to legislation. But ultimately like the wider gambling sector, we are committed to engaging with you, receiving your feedback on the market, your own operations and how our work impacts that. Again, we need compliance first, but we want that same collaborative relationship with you for the same reasons as we do with other operators.

I’ve talked a lot about change today. And that of course is true at the Commission as well. I was delighted to welcome Ruth Evans last month as the new Chair of the Commission, Ruth having been appointed by Government for a five year term. She is getting stuck in, already meeting a number of industry Chairs, including today. I’m also pleased to say that we have been working on the recruitment of a permanent Chief Executive and hope to progress that later this year. And when the new Chief Exec starts, I know they will be quickly looking to meet with many of you.

So new Chair, new Chief Executive, new Corporate Strategy. Does that mean new Commission? Well new people and a new Strategy bring new ideas and that’s very welcome. But that doesn’t mean how we work with you, our licensees, will change.

I have talked about change a lot today and about how much has been delivered. This is something that won’t change next year. Change remains constant. So does our commitment to working towards safer, fairer and crime free gambling. But so does our dedication to working with you, collaborating with you to deliver on those goals.

Thank you very much for listening.

Last updated: 6 November 2026

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