Ethical Gambling Forum - Tim Miller speech
28 April 2026
This speech was delivered by Executive Director Tim Miller at the Ethical Gambling Forum on Tuesday 28 April 2026.
Please note: This is the speech as drafted and may slightly differ from the delivered version.
Good morning everyone, thank you for that introduction and thank you everyone for being here today for what looks to be a really productive agenda. I’m Tim Miller and I’m pleased to be speaking to you today for what is the first Ethical Gambling Forum to be held here in Great Britain.
Anyone who knows the gambling sector knows it is not one that seeks to stand still. If gambling as an industry is anything it is one that seeks to innovative, is highly competitive and one that is always looking to push forwards. This of course is often a strength, especially for consumers and as I will expand on today, it is not for the Gambling Commission to get in the way of that without cause. In fact, where it’s in line with our licencing objectives, we want to actively encourage compliant operators to innovate in ways that maintain Britain’s global reputation for a vibrant, engaging and well-regulated gambling market.
But there is a balance to be struck and as the 2023 White Paper set out, changes to help reduce the risk of harms were needed. Much of the White Paper has of course already been implemented and at the Commission we have nearly completed our part of this work. So I’ll spend some time today updating you on where we are here as well. In particular I want to talk to you about where we are with Financial Risk Assessments, the pilot we conducted last year and to reaffirm what this White Paper proposal is actually about.
And at this point I also want to welcome that one of today’s themes is that of collaboration. This is crucial to how the Gambling Commission carries out its role and so I also want to stress today the importance that I and the Commission continue to put on working collaboratively. That will include with many of you here today, if not all of you.
I want to start this morning with recognising that we come together over the next couple of days at a time when the landscape around gambling is changing. For example, no one in the audience here today or those reading this speech online later will need to be told about the changes to taxation made in the Government’s Budget last year. Now the Commission does not have a formal role to advise on tax, we have no crystal ball that can tell us the full impact of these changes. But we know, from the discussions we have with industry what some of those impacts may be. And, of course the Government themselves set out some of the potential impacts of these changes as well. This included the risk of transference of consumers to the illegal market.
This is one reason why as part of the Budget, it was announced the Gambling Commission was to receive £26 million over three years to ramp up our work in tackling illegal gambling and it’s why Government has set up an illegal gambling taskforce. As someone who is involved in the taskforce, and chairs one of the subgroups, I’m pleased with the start it has made and I know Government shares our view that this taskforce cannot become a talking shop but must generate results. One of the areas that my own subgroup is working on at the moment is the publication of a national risk assessment on the illegal market to help ensure that we are all focussed on the main risks that might arise.
I’ll return to what the Commission is doing alongside others to further tackle illegal gambling later on.
And before I move onto other topics that are perhaps, a little more parochial in nature, I want to start by recognising the large number of attendees today who have come from all different parts of the world to be here. So thanks to the organisers of this event for attracting such a global turn out. I have to say that I love speaking to an international audience.
Firstly, I always find it so useful and valuable to learn from what is going on in other jurisdictions. Britain remains one of the largest, licensed gambling markets in the world. But that doesn’t mean we have all the answers or are getting everything right. So I am especially looking forward to those sessions today where we will hear about experiences of gambling and gambling regulation in other parts of the world.
The other reason I value engagement with colleagues from other jurisdictions is it allows you to get perspectives on what is happening here at home from people that can often offer a more dispassionate view of things. From people that don’t spend a lot of their time caught between the cross hairs of stakeholder groups that hold diametrically opposed and, often irreconcilable positions on issues.
Which brings me on to where we are in Britain with implementing the recommendations from the Gambling Act Review.
Financial Risk Assessments are probably the main remaining white paper commitment for the Commission to decide next steps on.
Now there has been a lot of recent commentary about Financial Risk Assessments, often from voices unconnected with the work, and sadly much of it has been ill informed or inaccurate. I and others at the Gambling Commission have talked before about how if anything, the debate around gambling since the white paper has managed to get more high-pitched - more toxic – somehow. The spreading of misinformation – whether its deliberate or not – is not unique to gambling and is part of the information space we all now live in. But that doesn’t mean we should accept it. Far from it. And so we recently published a blog on our website dealing with some of this inaccurate commentary and, whilst I don’t intend to repeat all of what that blog says today, I do think there are a number of things that it’s worth underlining here with you today.
But first let’s step back for a moment before I get into some of that detail. It’s worth remembering that expecting operators to have an understanding of risk for consumers of gambling harm has been a feature of the regulatory system since the passing of the Gambling Act in 2005. However, in 2026 it can’t be right that this still leads to some operators asking consumers to share bank statements and other financial documentation. Such an approach is outdated, inconsistent and disproportionate. That’s exactly why we worked with the Steering Committee on Reciprocity (SCOR Committee) to develop a more streamlined approach using credit reference data targeted at highest spenders.
Financial Risk Assessments were identified in the white paper by the previous government as the best way to bring a frictionless and consistent method for gambling firms to check whether a consumer is in financial difficulties. And this proposal is also supported by the current government. At the time of the Gambling Act review, it was identified that consumers who might be at risk, experience a patchwork of different approaches by gambling operators as to how they identify financial difficulties and the data they use to do so.
And despite some improvement that position hasn’t fundamentally changed today.
Nor has it changed that many operators default to asking their customers for documents when there may be little real need to do so, serving only to inject friction into the customer journey. And again, at the same time, our casework found too many examples over too many years of operators not providing support for high spending customers who may be at financial risk.
And if anything, through the pilot for Financial Risk Assessments, we now have more evidence that makes clear the status quo can’t hold.
We have found that there is a group of vulnerable customers that are not currently being identified by other approaches. Customers in the pilot cohort were between twice and four times more likely to have a debt management plan and between twice and five times more likely to have a default in the last 12 months than comparable consumers in the population. Some of these customers may be identified and supported by operators now, but too many of them are being missed.
But then will Financial Risk Assessments work? And, as promised by the white paper, will they be frictionless for the vast majority of consumers who aren’t one of the vulnerable customers Financial Risk Assessments are there to help? Well the Pilot is clear that the answer to both of those questions is yes:
- based on the White Paper and the consultation proposals, less than 3 percent of active customer accounts would trigger any steps by an operator under these proposals. In formulating recommendations, we will be mindful of this important targeting of the measure at the highest spending accounts
- of these 3 percent that would meet the requirements for an assessment, the pilot showed 97 percent would successfully receive a frictionless assessment process. This is far better than what government estimated when they published the White Paper, which was that 80 percent of assessments would be frictionless
- only a very small proportion of active accounts would require an assessment and be unable do so in a frictionless manner. The white paper expected around 0.6 percent of active accounts would fall into this group. The pilot shows it would actually be 0.1 percent. So only one in a 1000 accounts would be unable to receive an assessment in a frictionless way. And even that number could be reduced further, by operators meeting their existing obligations at the start of the consumer relationship to ensure that customers’ details are correct and their identity had been appropriately verified.
But there are other misconceptions running wild as well. So let me be clear, the proposed thresholds for an assessment are not limits or caps on customer spend. They are not ‘affordability checks’ by a different name - the checks we have been piloting will not even attempt to make an assessment of what each customer can afford to gamble. And lastly but maybe most importantly, there would be no need to require document checks following a financial risk assessment. In fact, if these checks are implemented it will allow us to give clear guidance to operators that they should not require consumers to provide documents to assess financial risk following a financial risk assessment. And to provide assurance to industry, our approach to compliance would also ensure that failing to request documents following a financial risk assessment would not be a reason for regulatory action. Indeed, to request financial documents in such circumstances would serve no legitimate regulatory purpose and consumers could rightly refuse to provide them.
We’ll be taking some recommendations on next steps to our Board in the near future. But nothing I’ve said today should give the impression that we have predetermined next steps. Our Board will make the decisions on this and no one should be tempted to pre-judge that. Our Board will want to be satisfied that there is a strong evidence base for any next steps on financial risk checks and also satisfied that the Government’s public policy approach continues to support such a change.
But if the decision is made to introduce these assessments, we will work closely with DCMS, the industry and credit reference agencies to establish an implementation group that will jointly develop the details of a sensible implementation plan and timetable. It will also help shape the guidance to operators to ensure that they take a proportionate approach to interacting with customers where financial risk is identified.
I’m sure there may be questions on this after I’ve finished speaking and I’m very happy to take them. We are not shying away from this issue, far from it, so if you have questions please do feel free to ask them.
Elsewhere, the other big deliverable we have remaining is the Gaming Machines consultation response. We published some initial information on this at the end of January. That confirmed from 29 July 2026 all operators must immediately remove machines if the Commission informs them that the manufacture, supply, installation, adaption, maintenance or repair of the machine was not carried out in reliance on a gaming machine technical operating licence, or did not comply with other standards. The change is aimed at streamlining processes and ensuring non-compliant machines are swiftly removed from premises - a benefit to consumers and operators.
The wider decisions for this one are still being considered. We are still reviewing consultation responses, supplementary data and research and evidence reports. But we said in January that we expect to publish a full response in the Summer and I don’t think that has changed. Again, not to prejudge the outcomes on this, but I will say that we recognise the potential financial costs of implementing some of the original proposals and that will have a significant impact on the final decisions we reach. We will weigh up whether the costs to business of some of the proposals are proportionate to the consumer benefits, especially in the current operating environment.
More widely we published our Business Plan last week and alongside our continuing work to implement the Gambling Act review, that includes more work on illegal gambling. It is also looking to further improve our data maturity and evidence base and continuing to both take decisive action and proactively engage with operators, to ensure compliance with our rules. We are of course waiting on the outcome of the consultation on our own Fees, that DCMS ran earlier this year. Once we have the results of that we will likely set out in further detail what the year ahead has in store. That includes looking at how we can support and encourage innovation in the market, for the benefit of consumers and operators alike.
I’ve already said that innovation is a real strength of the gambling sector and whilst recent years may have been dominated by what Government and the regulator think is needed in terms of protecting consumers, now is a moment where we need to also look at what we can do to help keep the consumer experience positive and competitive, especially when viewed against the illegal market.
Now this will be very dependent on what resources are available to us following the fees review and so I can’t commit to specifics until we know where our fees will be, but there are tangible ideas we are looking at. A strategic piece of work to review the impact, efficiency and burden of current regulatory requirements - all consistent with the Government’s wider regulatory reform agenda - is certainly one that is being planned. And I am pleased to say that we have started conversations with our Industry Forum, about what a potential path forward would be, to create a way for cryptoassets to be more easily used as a consumer payment option for licensed and regulated gambling in Great Britain.
But more widely where operators have ideas I want to make clear we are open to hearing them. As I have said before, the current statutory and public policy framework will place some limitations on what can be achieved but it doesn’t need to be an automatic no to innovations that deliver a better consumer experience. At the Betting and Gaming Council’s conference earlier this year I extended the offer to industry to come forward with ideas. It’s fair to say that there hasn’t been a stampede so far. So if you have identified opportunities for consumer-friendly innovation, we want to hear from you. Show us you are committed to the licensing objectives and we’ll show how we are committed to collaborating with you on innovation.
For our part we want to continue innovating in our work to tackle illegal gambling too. In recent years we’ve built a world-leading apparatus to do just that. In 2025 to 2026 alone we have:
- issued 741 Cease and Desists to advertisers and operators
- reported 397,527 URLs to various search engines and seen 266,667 URLs removed as a result so far
- referred 1068 websites to the search engines for delisting
- disrupted 1134 websites so that they have either been taken down or geo-blocked.
And with the funding from the Treasury [and the new powers just finishing their path into legislation] we want to go further, as fast as we can. We will continue to ramp up our action against the illegal market and work with other regulators and law enforcement bodies to ensure we have a co-ordinated approach. At the same time we cannot allow inaction by others to undermine our efforts. We have all heard concerns expressed in the media and in Parliament about how tech companies are simply not being proactive enough to keep people safe online. Our ongoing work to tackle the illegal gambling market has shown that the increasing visibility and accessibility of illegal sites is yet another example of big tech being too reactive and only using their considerable resources for harm prevention when really pushed to. So we will become increasingly vocal in drawing attention to those companies that fail to take seriously their obligations to protect British consumers from exploitative illegal gambling operators. And in the spirit of collaboration I would encourage all of you to lend your voices to that cause, including our international colleagues here today, as the illegal market is an international problem, requiring international solutions and international engagement.
And building collaborative relationships remains central to how we want to work with industry, international partners and anyone who shares our objectives of safer, fairer and crime free gambling. I’ve said before that the diversity and strength of the offer to consumers does make our domestic gambling market one of Britain’s big commercial successes of the last decade and one that many jurisdictions have looked at with envy. The future of that market will depend upon us all working together with a shared purpose to continue delivering an innovative and engaging consumer experience within a well-regulated environment that has fairness and safety at its heart.
And with that there should be some time for questions. Thank you.
Last updated: 28 April 2026
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