IAGR 2025 Conference keynote - Andrew Rhodes speech
22 October 2025
This speech was delivered by chief executive Andrew Rhodes at the International Association of Gaming Regulators (IAGR) Conference on 20 October 2025.
Please note: This is the speech as drafted and may slightly differ from the delivered version.
Good afternoon everybody. Thank you. It's a pleasure to be here today and thank you very much for having me. It's also a pleasure to deliver the first keynote of this year's conference. Of course, with it being the first keynote the statisticians amongst you will know it is of course, the best keynote of the conference that you've had so far. That means it's the worst keynote of the conference you've had so far too though, so let's not dwell too much on that.
So what I'm going to talk to you about this afternoon is I'm going talk to you about the shape of the Great Britain (GB) market. Because, as I've said at a couple of conferences I've been to before, a lot of what happens in the world, given the maturity of the GB market, tends to happen with us first, and it follows everywhere else. So I'm going talk to you a bit about what's happening in our market. I'm also going to talk about some current and future changes in consumer pressures that we are seeing. I'm going to talk about the challenges around measuring change impact. I'm going to talk a bit about illegal gambling and some insights, though not too much because John Pierce is doing that later this week. And whatever you do, you should go and see that as it will be really good.
I'm going to talk about account restrictions for consumers and frustrated consumers as well. I'm going to talk a little bit about data insight and some recent insights that we've managed to develop through some of the work that we've been doing. I'm going to talk about financial risk assessment pilots and what that evidence has found. And the last thing I'm going to talk about is the need for us all to work together.
So starting off, I'm going to talk about the shape of the UK market. We very recently published the latest wave of the Gambling Survey for Great Britain. This is probably the largest survey of its kind in the world and what it's showing is participation in GB at the moment is stable at around 48 per cent of the adult population which if you think about it, is a very significant amount of participation. What we see in terms of the whole GB market is valued at about £15.6 billion and £11.5 billion of that is the size of the market once we exclude lotteries. Remote gambling which is almost all online will be £6.9 billion in terms of the market, 60 per cent of the whole shape of our market, once we exclude lotteries.
Now headline figures are clearly really important, but let's dig a little bit below the surface of that into some of those numbers. So if we look at remote gambling, that's up 7 per cent in 23/24 from 22/23 and it's up 63 per cent since 2015/16. Online casino games, particularly slots dominate the remote sector with £4.4 billion in 23/24. In terms of that market value, this is probably not all that surprising. Certainly in the UK, 95 per cent of adults have the Internet at home. To be honest, 95 per cent seems low these days. You think about the activity people undertake. People average over 4 hours online a day, 75 per cent of which is on smartphones and no doubt that's similar to what all of you will be seeing in your countries as well. And that will have also driven some of the increase we've seen in the creation, in fact of gambling regulators since the pandemic.
But what we see as well in the environment, including in GB is constant change and artificial intelligence is starting to make itself felt. Now there are a whole load of things being talked about here and I think it's quite interesting when we look at the use cases that we've seen the industry adopting within GB. I would say around perhaps 5-6 years ago, one of the predominant problems we saw amongst operators was not really having policies in place for meaningful interactions with consumers. Then I would say perhaps four years ago, those operators had policies, but they weren't always following them. Then perhaps a few years ago they were following them, but the quality wasn't very good, so interactions were happening. Safer gambling interactions were happening, but the quality wasn't good, or probably more often than not, was really inconsistent. And what we've seen in the last 12 months or so is operators increasingly now using generative AI, and they're doing so to try and improve the consistency of customer interactions. What they're trying to do as well is measure the consistency of the interactions they're having, because we know people are variable and machines are less so and what they're trying to do is bring some consistency to that. We've seen various other changes around AI and bots and what that's done. Online poker was mentioned earlier on.
One of the other things that I think we need to watch out for is the general trend towards hyper personalisation. So serving up more and more meaningful content to people. Now, if you're in a service industry or leisure industry, what you want to be doing is serving up more and more meaningful content to people. What that means is the engagement will be higher and higher. But we need to make sure we're balancing the risks between serving meaningful content and not getting to the point where people are starting to feel an increased intensity that nobody necessarily intended. One of the other things that we're seeing and it's been mentioned already and I'd be surprised if it's not mentioned a lot more, is growth around cryptocurrency. Now, right now we don't have any licenced operators offering crypto. It's difficult to see how we would licence those who are offering crypto casino, but we do know in the illegal market it is widespread. We also know that the demographics under 40 are starting to use cryptocurrencies a lot more, in fact for many crypto assets are more dominant than Fiat currency or Fiat based assets. Which means over time there will be a generational cohort who currently, if they are using cryptocurrencies, do not have a space in the legitimate market. And what I personally felt maybe a year or two ago was perhaps a problem that was five years away. I think that is now maybe 12 months, 24 months away as we are seeing this grow. It also brings some interesting and difficult questions for us around how would you even try and work with cryptocurrencies given all the problems we know we have around traceability of funds, AML risks, terrorist financing, do you start to look at cryptocurrencies as demonstrating a source of wealth, or can they be a source of funds? Now these are going to be governmental level questions. They're not, I think in reality going to be questions for individual gambling regulators, but that pressure is definitely not going to go away and we can certainly see that building within GB.
We've also seen some other trends in the last few years. What we call Society Lotteries. So these are charitable lotteries where in GB, 20 per cent of the money needs to go to good causes. They are now at sales over £1 billion. They've become a considerable part of our market. At the same time prize draws are growing – which are large scale prize draws which offer a house or other life changing prizes. Now we don't regulate those, but we've seen those growing fairly exponentially in the last few years, not so much necessarily in the last one or two, but they've grown considerably and we've been measuring some of that participation and now those products are sitting just behind betting in terms of participation, so it's interesting to see how that has been evolving.
The other thing that we've certainly done a lot more on and again the panel I thought touched on it quite a bit earlier on, and this is around betting integrity cases and criminal cases. So in the last two years between our annual reports, one of the things that's really, really stood out to me is year on year we saw a 300 per cent increase in the number of criminal cases we were taking as a regulator. And I'd be surprised if that's not a pattern that is starting to emerge around the world. So there has been a tremendous amount going on for us during that period.
The other thing that I want to talk about was resilience to change. Gambling is constantly evolving and so must we. The thing is, change rarely takes place in isolation. Governments and regulators typically make changes as part of a package of measures. Therefore, it's sometimes quite hard to disaggregate the different components of what the individual impacts have actually been. So this means sometimes campaigners will apply a false attribution to the effects of different things. Different groups will claim the impact of something is the sole cause of a particular movement. Now it might be, but it also might not be. One of the issues that, a year ago very few of us were talking about, but I can tell you today and I know several of the regulators in this room are now talking about, is taxation and gambling, which wasn't a huge talking point necessarily in the regulated space a year ago, but it is today. It's a very live debate in GB right now. In fact, when I was at the airport waiting to fly out yesterday, the BBC News was on in the background, with operators talking about their concerns about taxation and similarly, there are stories about whether the sector is appropriately taxed. Now these are going to be really big debates and they're taking place in many countries at the moment, and it is quite hard sometimes when different factors change to work out exactly what impact each individual component had. That's why in GB, we've got an evaluation programme, which is to evaluate the impact, as best we possibly can of the different changes that the Gambling Act Review White Paper has delivered within our country.
A topic that I won't dwell too much on, but let's talk a little bit about illegal gambling. This is a huge topic around the world. We have set up a dedicated team about three and a half years ago to specifically focus on this area. Why did we? There has to be a reason to want to be in the legitimate market. And part of that reason has to be that we make sure there are penalties and disincentives for being in the illegal market, but also one of our obligations under the Gambling Act, which created us as an organisation is we are here to protect children and the vulnerable from being exploited by gambling. There is nothing more exploitative than the illegal market. And we've been publishing research recently. In fact, there'll be another piece that's out this week on the cohorts that make up the illegal market. But here's some of the work that we've been doing and one of the partnerships that we're very proud of is with search engines and disrupting the flow of traffic from the illegal market. This Financial Year we're getting close now to 200,000 URLs being reported to search engines. We've had nearly 100,000 or so removed. What we're finding is as we're doing this, we are disrupting the traffic and the figure that you've got there and John Pierce will go through this in detail as to exactly what we do and hopefully that will be useful to everyone. But we can measure the impact we've had and we're tracking over 1000 illegal operators as we try to shut them down: what effect we're having on their traffic. And what we can see is if we can remove things from search results, we make it harder to find, so we slow them down. Facebook, little less of an impact, but Facebook would be very good at removing illegal lotteries, which has been our biggest problem on there and again hugely effective. But the most important thing is getting the website removed all together and this is where we do things at source. So our focus in GB has been all about disrupting illegal gambling upstream. Yes, we closed down individual websites, but what we're most interested in is making them harder to find and harder to operate. We've also focused a lot on B2B (Business to Business) game suppliers as well and trying to choke off the content that goes into the illegal market. Thus making it a lot less attractive.
The next thing I wanted to move on to is talking about fairness and fairness is, I think a really interesting concept in gambling, because what does fair mean? So one of the things that was the biggest topic of complaints to the Gambling Commission in GB was withdrawals. The ability to withdraw your money. Now I bought a part for my watch a couple of months ago and I had to get the part online. The only place I could get it was on eBay, in Italy. And what was fascinating was I ordered this part on a Tuesday morning and I was told all the way through that my part had been packed, that it had been dispatched. I was told that DHL now had it at an airport and with flight radar, I could see the actual plane it was on and it was tracked in every different point. When it was being delivered to me, I knew how far away it was and it had arrived. I mean I knew it had arrived because I was standing on the doorstep, but do you know what? Everything we order now, we know exactly where it is when it's going to arrive, how long it's going to be. The name of the person bringing it even. And consumers expect that with everything. So once they ask for a withdrawal of money from a gambling operator, they expect it to be instantaneous. They want to know when it's happening, and that wasn't the case for their experience.
So we've been measuring this and we've been tracking it. And what we found for June to September 2024, is there were 44.2 million withdrawals and that's a big number. So if you imagine that it's a small percentage that’s not right then that would still not be a small number of people. But what we're finding is 96.3 per cent is cleared automatically. 3.5 per cent cleared within 24 hours and only 0.1 per cent took more than 48 hours. What we're really interested in is the 0.1 per cent. Why? Why they're delayed now? That could be for very good reasons. That could be because there are AML concerns. It could be because there is suspicious activity on the account, it could be identity issues, could be all sorts of things, but that's where we're trying to refine our effort and focus on where is the disruption for consumers.
The other thing that we did, and whilst we were already thinking about this, it actually stemmed from a conversation we had with our colleagues in Massachusetts. We thought the point that they made was a really good one. That there is this huge frustration here with accounts being restricted. So we analysed a huge amount of data from our largest operators. To understand what the true picture was. 4.31 per cent of accounts are being restricted. These active accounts in the 12 month period were being restricted by operators. Now let's try and quantify this a little bit because that's a reasonably big number, but we know that most consumers have more than one account, so we're probably talking at something like 1-2 per cent of people who are gambling had their account restricted. Now this is account restrictions for a commercial reason. So this is people that the operators either don't want their business at all or they want it to be managed in a different way. But that leads to also some other interesting things that we discovered. So 2.23 per cent of accounts were closed altogether, but the most likely outcome was stake factoring. Now I know we sometimes call things different things between different countries. So I'll just be really clear what I mean. What I mean by stake factoring is the amount that you are allowed to bet compared to the maximum available stake. So for a lot of these customers, they were being limited to 0.1 per cent of the maximum available stake. Which means that in certain events they could probably bet a reasonable amount of money, but in most things they really couldn't. And if we dock that in with our research on illegal gambling, we see two very interesting things. What we found in our research in so far into illegal gambling is that there are a cohort of consumers who are gambling in the legal, legitimate industry, but also in the illegal industry. And what we're seeing is there is a cohort of people who are likely, it's difficult to pin down exactly, unable to gamble in the way that they want to in certain aspects of the legitimate industry for commercial reasons and may be able to do so in the illegal industry. But either way, we're seeing this hybrid arrangement is starting to happen and we ought to be concerned about that, and we ought to be concerned about what is going on. The other thing that we found with account restrictions is they were far, far more likely to be in profit personally. So in deficit to the operator, they were not profitable customers and there were a cohort, a reasonable percentage that were having their accounts either suspended or factored after as few as 5 bets. Which is really quite interesting when you think what does that mean? Well, it's hard to say exactly. What are we going to do about it? Well, the reality is there is no requirement to take business from someone in GB. Unless you're refusing business because of what we call protected characteristics for example of someone's race or gender. If not that, then you can refuse business. But it is interesting that we see these cohorts of people in the illegal market and that's something that we should try and at least understand as well as we possibly can.
The next thing I wanted to move on to was talk to you a bit about data, in particular a project called ROCD (Regular feed of Operator Core Data). Effectively what this is, is live data from operators. So they're feeding their data in and we can see pretty much in real time what's happening with our customers. Why are we doing this? Well, we're not trying to track the individual bets. We're not interested in that, we’re interested in what the consumer behaviour is. We don't have a lot of operators in this yet, but it will get bigger. But here's some of what we found. In the sample size of data we have which is not insignificant, we found that those who were under 25 were the least likely cohort to set deposit limits. They were also the most likely cohorts to reach a financial risk trigger. Now, perhaps we shouldn't be overly surprised by that. But isn't that an interesting thing? We also found that the Under 25s were the most likely to have a deposit limit set by the operator themselves, and the fact that they hadn't set their own is probably part of that.
But what this data is showing us is the higher risk consumer groups are exhibiting some of the higher risk behaviours and that's something again, we need to be mindful of in our regulatory frameworks. We're not trying to infringe anyone’s freedom. We're just trying to curve back the behaviours of those who might be putting themselves at risk into a more manageable space. But this data is incredibly powerful and what we're hoping as we get more and more operators onboard is instead of us talking about big crunching milestone points in how we manage consumers, we're looking to start to get something that much more accurately identifies individual risk factors and the power in this is tremendous.
The other thing that we've been doing is piloting Financial Risk Assessments. Now, probably a year, maybe 2 years that I've been coming to IAGR, this has been a massive talking point in GB as to whether this should happen or not. And what we've found with our work around Financial Risk Assessments is we have been able to in a frictionless way, through the use of credit reference agencies get data on basically all accounts for all but 0.1 per cent. So we've been able to identify the highest spending customers and find out whether they're in a position of financial risk. So what we found here, you've got the ability for us to identify them through data. This was far better than we expected. What did that tell? I think this is really stark. So why are we worried a bit more about people who are spending more money on gambling? Well, it's not because we want to infringe their life choices. However, we found that in this pilot that the consumers who are spending the most on gambling were between two and four times as likely to have a debt management plan as the rest of the credit check population. That really does stand out, but further they were between two and five times more likely to have a debt default in the last 12 months. So this is telling us that there are cohorts of people who are gambling more than others, who are more likely to two or four times more likely to have a debt management plan, two or five times more likely to have a default in the last 12 months. This data is very important because this tells us we're looking in the right places to try and help manage risk. At the end of the day, what we don't want people to do is get in such a position with their gambling that they are being distressed and having problems and that spirals into a more difficult position. That is not a sustainable place to be, but data doesn't answer everything. We've got to continue to work together to understand what exactly it means. But I think this has been really powerful and important to us in GB. We're not there yet in terms of finishing this work and there's still a live debate about exactly what you should do with all of this, but nonetheless I think it's important.
The last thing that I wanted to talk about and we started doing this at the first IAGR I attended in Melbourne and we put pictures up of not everyone we've met, but we put pictures up of some of the people that we meet through the course of our work. And it got touched on in the panel and I wouldn't underestimate this. We all regulate many of the same organisations. We all have many of the same problems. There maybe some nuances of difference between them. We all have very similar objectives as to what we're here for as regulators, but we would all be making a critical mistake if we believe we could solve them all on our own. The reality is it's so, so important for us to work together, even if that is as little as sharing insight and information, because consumer behaviour, yes, varies between countries and cultures, but not so much as to render that information worthless. There is so much more that we can do together. To work together as regulators to share understanding and to cooperate. The work that we've started to do with the IAGR Illegal Gambling Working Group is really important. But there are so many other things that we could do. And one of the pleas that I made at that first conference, one of the things that I said is, we all have a shared aspiration. Our words are to keep gambling safe and fair and crime free, but yours will all be variations on the same theme.
Find something this week, with another regulator that you can work on together that will help us and help you achieve a better outcome. That's what these gatherings are for, much as there will be a huge amount of informative content through the different sessions through the bits of networking you do. But try and come away with one thing that you can do with another regulator who's here. This is the best, most important concentration of gambling regulators meeting anywhere in the world. Find something to work with someone else on that will make a difference because you won't regret it and it will be the thing that takes you on one further step forward. On that note, thank you very much for taking the time to listen and I’m happy to take questions.
Thank you.
Last updated: 22 October 2025
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