IAGR 2026 Conference keynote - Sarah Gardner speech
21 October 2026
This speech was delivered by Acting Chief Executive Sarah Gardner at the International Association of Gaming Regulators (IAGR) Conference on 20 October 2026.
Please note: This is the speech as drafted and may slightly differ from the delivered version.
Hello everyone, thank you for that warm welcome. My name is Sarah Gardner and I am Acting Chief Executive, normally Deputy Chief Exec, of the Gambling Commission back home in Great Britain (GB). And thank you to the outgoing President, Ben Haden for that kind introduction as well. Of course, he has to be kind as he works with me back in Great Britain and it’s a long flight back from Peru!
And being here in the historic city of Lima this week, I should also say ‘buenas tardes’ to our hosts and to all of you from Latin America. One of the great things about IAGR is being able to meet so many colleagues from around the world all in the same place, to share the issues that we are working on and – regardless of the language we speak – to know you are speaking to those who have the same worries and the same aims. More on that later but for now ‘muchas gracias’ to our Peruvian hosts. And with that I promise not to push my Spanish and your patience further!
Today I’m going to speak about some things we are doing in GB and share learning I believe could be useful on an international basis. My comments will include our effort to tackle the illegal market and how we play our part in a transformed research space.
On that note, I’m going to talk about some new research we are publishing today on illegal gambling. Much of what I will say will overlap themes from other speeches and panellists which are insightful. The common issues amongst you and value of IAGR bringing us together like this. But first, to provide a bit of context to all of this, let’s have a little look at where things stand in Great Britain today.
If we look at the data we collect, the year ending in March 2026 appears another year of growth. For the whole regulated sector across Great Britain, Gross Gambling Yield (GGY) was up to £17.5 billion – a 4.4 per cent increase on the year before. If we take all lotteries out of the equation GGY is £13.2 billion – up by 4.7 per cent on the year before. And whilst we’re on lotteries, whilst the core products remain distinct, and for us how we regulate our National Lottery is under different laws, it is increasingly true that the lottery sector is blurring into the commercial gambling sector, whether through ownership or other avenues. This is a trend we are paying attention to.
But back to the stats. If we drill down again, GGY for ‘remote’ betting, casino and bingo, for which the vast majority is online, was £8.3 billion – a 6.9 per cent increase on the year before.
When we factor this in against the picture from the Gambling Survey for Great Britain, we know 47 per cent of those surveyed, aged 18 and over, participated in gambling in the past 4 weeks. Again, when we exclude people who only play lottery draws, participation was 27 per cent. The population of Great Britain population is currently over 67 million people, so that’s tens of millions of people engaged in some form of gambling every month. These participation rates are stable with the year before and have been stable for a long time. And again, if you look back at previous years since the pandemic, the story is familiar – steady growth in GGY from a stable and sizeable player base. It gives the impression that consumers, operators and we as the regulator are stood on solid ground in Great Britain – the solid ground of a mature, developed market.
But impressions can be misleading. This picture follows several years of strengthening gambling regulation and raising standards of compliance with our rules. The UK Government has made important changes and interventions that impact the gambling sector as well in that time. And at the Gambling Commission things have changed. And change is an important point when we look at the debate in Great Britain at present.
Before I move on, as I mention change at the Commission, many of you will know that we have seen some people changes over recent months. I was delighted to welcome Ruth Evans just a couple of weeks ago as the new Chair of the Commission, Ruth having been appointed by the UK Government for a five year term. I am very much looking forward to working with her and I take this opportunity to place on record our thanks to Charles Counsell for stepping in as Interim Chair.
We have also seen some change in our Executive team. After ten years with the Commission, Tim Miller announced earlier this year that he would pursue a change. Tim is well known to many of you here so I would like to take the opportunity to thank him for his service to the Commission and to wish him well. I was delighted to welcome Sarah Fox to the Commission last month to take over much of Tim’s portfolio, alongside regulation of the National Lottery. Sarah is no stranger to gambling, having come from leading the Gambling team in the UK Government, so has been able to hit the ground running.
The fact that I am speaking to you today as Acting CEO is also a reminder that the Commission will soon welcome a new Chief Executive. I just want to mention here, and not only because he is in the room in a hall full of so many of his friends and colleagues over the years, my thanks again for everything Andrew Rhodes did in his time at the Gambling Commission. He was a great colleague and, backed up by the great team at the Commission more widely, he made an important impact to our work and the sector as a whole. As I say, we are now working on recruiting Andrew’s successor and we will of course keep you all updated on that as we progress and I know that meeting colleagues across the IAGR community will be a priority for an incoming CEO.
Back to the wider picture though and last year the UK Government made changes to the way gambling is taxed across Great Britain, many of which were to begin in April this year – so just after the period covered by the stats I just gave you. Now the Gambling Commission does not play any role in setting gambling tax rates, collecting those gambling taxes or even advising on tax. However, we do have a statutory role to advise ministers on gambling and its regulation so it is important that we monitor and understand the impact of things like taxation on the industry we regulate. In the case of these most recent changes which were announced by the Government in their Budget last November, the full impact is not yet clear as it’s really too early for that. So is the ground beginning to shift?
The UK Government in the same Budget committed £26 million over three years to be used to enhance the Commission’s work tackling illegal gambling. I am pleased that the effectiveness of the Commission on illegal gambling was recognised in this way and I’ll talk more about our work on the illegal market later. The industry is working through the implications and at the Commission we continue to engage with those we regulate to understand their position. Part of IAGR needs to be some self-reflection on what role everyone plays in both problem and solution. For example, there was a panel yesterday that touched on B2B operators supporting illegal B2C operators alongside their licensed counterparts – something we are clear is unacceptable and urge operators to make sure their house is in order.
On top of this, in the Summer – for the Northern Hemisphere at least - we had a change of Prime Minister in the UK and so a new Government as well. Here too, some potential for change has been communicated, with Government signalling an intent to look at how gambling operates in local communities. So this is the picture we have in Great Britain. On the one hand a stable, mature gambling sector, one of the largest, licensed, regulated gambling markets in the world. But also a period of sustained change.
The question then is where does the regulator stand in this picture? And I suspect for many of our fellow regulators, whilst the details might be different, the question is the same.
However the market is moving, whatever pressures globally impact the industry, our overall objectives don’t change.
But how we go about achieving them can. Events can and should lead to changes in emphasis. And that takes me on to what the Commission has been doing.
It’s a key focus for this year’s IAGR Conference, it’s a regular talking point for regulators with the industry and it is an ever present topic in the media. But it has always been a part of our objectives too – a key part of keeping crime out of gambling means suppressing the illegal market. Which is why the Gambling Commission was given a range of powers beyond our regulatory powers over the licensed market in the Gambling Act 2005.
Now I don’t wish to give the game away for the next panel on disrupting the illegal market and one I think you should all stick around for. It’s also a panel where my colleague, the Commission’s Exec Director for Operations, Sue Young will be taking part as well. Tackling the illegal market has always been something we’ve taken seriously at the Commission, taking important action to protect consumers from the serious risks unlicensed operators can pose. But now we are scaling up that action in some significant ways.
Many of you will be all too familiar with the detail of what it takes to tackle illegal gambling. It is not an easy job. By definition, we are talking about people and organisations who do not want to engage with authorities and take active steps to avoid doing so. It is, not least in that regard, very different from regulating the licensed market, often consuming more resources and of course, incredibly expensive as soon as you start conducting more prosecutions and similar activity.
Despite having always had powers and a commitment to tackle illegal gambling, in truth, the resources we’ve often been able to make available to tackle illegal gambling have been much smaller in size than our ambition. That has meant we have had to take tough choices to prioritise cases which would tackle the most serious risks and have the greatest impact. Cases like Futgalaxy some years ago now in which the Commission secured convictions for the provision of unlicensed gambling to children. But in truth, taking prosecutions like that has not been something the Commission can do in numbers at any one time and a case like Futgalaxy would have consumed a very significant proportion of our resources over the period of time it took to secure those convictions. That means that we have not been able to take forward all of the illegal gambling cases we would have wished and we have therefore had to develop creative ways to have the greatest impact possible with the resources we have.
The additional funding we have received of £26 million over three years is therefore very important. It will not allow us to do everything but is a way of building on the approach we have developed, making some investments in our wherewithal to tackle illegal gambling and scaling up our operational activity.
The illegal market is incredibly difficult to measure – an area I’ll discuss more later. But during a period when in Great Britain we have, with good reason, been tightening some aspects of regulation for the licensed industry, making sure we complemented this with further efforts to suppress and disrupt the unlicensed illegal market, we felt, warranted priority.
The end of the last Financial Year, March 2026, is an important moment to mark where we got to. It’s a moment at the end of two years of focus on developing and strengthening our approach to tackling the illegal market but before the first £7 million of the committed £26 million from the UK Government came online in April. So what had we achieved by March this year without those additional resources but with the creative approaches we have been developing to ensure that we have an impact? And when I talk about creative approaches, I mean things like leveraging the relationships we’d built up with internet search giants, payment providers, industry, other regulators and UK Government agencies, in 2025/26 we had delivered:
741 Cease and Desists issued to advertisers and operators
397,527 URLs reported to various search engines and seen 266,667 URLs removed within the Financial Year
1068 websites referred to the search engines for delisting
1134 websites disrupted so that they have either been taken down or geo-blocked.
Obviously the focus in these data is online gambling. Indeed, much of the debate about illegal gambling relates to online and it’s easy to see why. Arguably, it is far easier to mount an attempt to offer unlicensed gambling at scale with the right online presence. However, illegal, land-based gambling poses significant risks to consumers, businesses and communities so we are making sure that our illegal gambling programme is ambitious here too. Partnerships are particularly important in land-based gambling. Under our gambling legislation, local authorities also have powers and we also know that illegal gambling is often connected to other forms of crime which are important for police forces and other law enforcement agencies and others to tackle. That’s why we continue to invest in those important partnerships. Just this year, we’ve seen how those partnerships can achieve results. There has been a steady drumbeat of raids with the Police, prosecutions and convictions and I expect that to continue.
Indeed, it all continues but, with the first £7 million of funding from Government, we are now ramping up our resources and our activity. And this is all with the aim of making it as hard as possible to operate gambling illegally at scale in Great Britain. We know we will never shut down every illegal website or close down every unlicensed gambling premises but our ability to attack this problem with vigour is growing. That isn’t just about the additional funding I’ve mentioned or the way we are building important partnerships. We also have some new powers coming soon – these will enable us to apply to a court for IP and domain name suspension orders. Our strategy remains to prevent illegal gambling at scale. And that strategy is in service of our aim to protect consumers and the legitimate, licensed industry as well. Every consumer who gambles on an illegal site is a consumer at greater risk of harm, at risk of their data being stolen and at risk of losing their money even when they win. And it is unfair to licensed gambling businesses that uphold the standards consumers deserve.
So, with the first £7 million of funding from Government, we are now ramping up our resources and our activity. And this is all with the aim of making it as hard as possible to operate gambling illegally at scale in Great Britain. We know we will never shut down every illegal website or close down every unlicensed gambling premises but our ability to attack this problem with vigour is growing. That isn’t just about the additional funding I’ve mentioned or the way we are building important partnerships. We also have some new powers coming soon – these will enable us to apply to a court for IP and domain name suspension orders as some of you already use.
We have also continued to make an impact through our compliance and enforcement work. This year a particular feature has been AML failings. Taking action to protect the British jurisdiction from Money Laundering and Terrorism Financing is a key responsibility for the Gambling Commission as I am sure it is for many of you. And through targeted compliance assessments we have been able to identify areas for improvement in large and small operators this year. Money Laundering is another facet of illegal activity that we must guard against and this year has shown that whilst compliance levels continue to improve in general, we can and must do more in this area.
And whilst I am speaking about compliance, I just want to warn colleagues about a practice I have noticed on several occasions over recent times. The Gambling Commission has never and will never endorse any one product or supplier when it comes to services that support operators with compliance or other functions that they need to hold a licence with us. As an outcomes-based regulator, it is not something we would ever do. I am sure the same can be said for many of your organisations. But I have on several occasions been told by operators that there are suppliers and others out there telling operators that specific systems are needed to trade in Great Britain or are otherwise ‘Gambling Commission approved’. It is of course not true. So if you ever hear it from a supplier or anywhere else for that matter, please take my word for it that it is not the case.
Now, as we scale up our disruption of the illegal market, we are also coming closer to the end of our role in implementing the British Government’s Gambling Act Review. This was the review of basically all legislation and regulation for gambling in Great Britain, excluding The National Lottery, and recommendations for it were published, by way of a Government ‘White Paper’ in 2023. The Commission has been working on this ever since.
But what does that matter to other jurisdictions? Does it matter globally?
One area that has caused plenty of debate in Great Britain and questions from international colleagues is Financial Risk Assessments (FRAs). And the interest and commentary on this is from all sides – I just have to look at my inbox to confirm that. In a story that again, will be familiar to many of you, on one hand we are told that FRAs are needless interference in people’s lives and on the other we are told we are not going far or fast enough. A classic regulatory challenge to make the balance which ensure protections where it’s needed with minimal disruption to consumer enjoyment or business access.
Combined with other changes to our regulation, such as new rules around marketing and offers; as well as innovative measures like GamProtect and Financial Vulnerability Checks both of which securely make use of consumer data to help protect them from risk; Financial Risk Assessments are an important measure. And in July we announced that our Board had taken the decision to implement FRAs.
So what are FRAs and why is this such a controversial measure?
In a nutshell, FRAs provide gambling businesses with access to limited credit reference data for the first time. The assessments will not affect a customer’s credit rating and the data cannot be used for commercial reasons. Consumers who hold the highest spending accounts will have a frictionless assessment, and if that flags financial difficulties taking account of defaults as well as multiple/significant arrears, the business will consider whether it is right to offer some support to the customer, taking into account other things they know.
I think the innovative work with Credit Reference Agencies (CRAs), makes this something that is worthy of note for other jurisdictions too. The Pilot we have run proved that you can successfully and securely share customer data with CRAs, and then provide flags back to the gambling operator, in a frictionless way for the vast majority of consumers – providing new data and new opportunities to protect high spending consumers from risk.
Less than 3 per cent of customer accounts would need an assessment when fully implemented. For these high-spending consumers who receive an assessment but who are not experiencing financial difficulties, the introduction of financial risk assessments should reduce friction – where a business currently, likely asks for documents or acts based on a generic level of spend.
Where there are financial difficulties, the business can then make informed decisions to support that customer in a proportionate way. And to be clear, that is the purpose of FRAs. Using technology and data to reduce friction for those who don’t need it and providing the information so operators can intervene appropriately where there is risk.
Some of those risks have only been discovered through the FRAs pilot. We now know that high-spending gambling customers are 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. This is a significant risk and one we cannot ignore. We have not identified a better way than FRA’s to tackle that risk.
But there has been at times frenzied attempts to get the Commission to change course. The fact that different Credit Reference Agencies have different methodologies. There have been sustained efforts to suggest that a process that doesn’t touch over 97 per cent of accounts and is frictionless for all but 0.1 per cent is somehow not frictionless. And other commentary citing various concerns.
Now to be clear, where genuine concerns are raised, where evidenced feedback is given, we are committed to working through it – giving space for these discussions is why we announced implementation in July but have not yet published the full consultation response for FRAs. On CRAs we are confident that they hold the best quality data available on customers in financial difficulties. No other tool has the same relevant data. In contrast, current operator approaches are highly inconsistent – using different data sources and interpreting those differently. These assessments are considerably better than the status quo and other available tools. That said, we will support the refinement of credit reference agency models to improve understanding of the aspects where operators need that. And we are committed to supporting industry throughout implementation. The same goes for other sectors that fear an adverse impact, like British horseracing. But what we can’t do is be distracted from implementation given how such a clear risk to consumers have been identified. We would not be doing our job properly to talk past revealed risks of that nature.
Operators in Great Britain are now working with us on the implementation of FRAs for which I thank them. It’s crucial that operators help us in this way, combining effectively to discuss what implementation looks like so that we can get it right. The Commission has received some criticism for not publishing the full consultation response in July alongside news of our decision to implement. But doing so would have meant publishing decisions on implementation without the opportunity to engage with industry on the details. We have already published much of the evidence base and much of our working on FRAs, and we plan to publish the consultation response this Autumn.
I suspect what I’m about to say might not translate clearly into other languages for which I apologise. But at times, with new regulatory measures like FRAs or with our continual efforts to improve the evidence base, some commentators like to engage in distracting tactics to try and slow down or stop changes they don’t like. In Britain you can call this type of behaviour ‘whataboutary’ – the idea you can pick away at the whole by asking ‘what about’ questions about minor points around the main target. In this way you try to make something strong look weak, make something secure, appear fragile.
Again, as I am sure is the case for every regulator here this week, the Gambling Commission not only wants feedback and constructive criticism of our work - we seek it out. The work we’ve done to implement the Gambling Act Review white paper is subject to a fully procured independent evaluation process, jointly contracted with Government. Rightly so questions and concerns which are raised merely to frustrate or hinder, sometimes not even about the policy itself, are not helpful to us, and more importantly, are not helpful for consumers and ultimately are not helpful for the industry either.
This type of thing has always happened of course. But the debate around gambling seems to only get more charged and more heated year on year – certainly in Great Britain. And as the debate gets more charged, every area becomes contested. Statistics are very much part of that. These tactics won’t force us to give up on our commitments. But they can absorb precious staff, time and resources – inevitably slowing us down and drawing colleagues away from the work which can add value or indeed, support the very objectives being called for.
That means that, so often such tactics are self-defeating. For example, the Gambling Commission’s participation and prevalence data, collected through the Gambling Survey for Great Britain, continues to be attacked by a small number of critics, some of whom have some vested interests. Their campaign is a prime example of asking those ‘what about’ questions. And ultimately, that campaign is driven by what the methodology for the GSGB - on which the Commission has consulted, subjected it to independent scrutiny and had verified by experts - has meant for the adult population scoring 8+ on the Problem Gambling Severity Index (PGSI), which we publish annually. And as many of you will know, 8+ on the PGSI means those who will have experienced adverse consequences from gambling and a possible lack of control. The 2025 GSGB annual report provides a figure of 2.4 per cent of the adult population score 8+. Down from 2.7 per cent in 2024.
The shame for those who are often focused on reiterating their mistrust of the GSGB is that it isn’t just about that one data point - it provides data that they will find useful – data in fact that some have used despite often describing GSGB as irretrievably flawed. One example being that 42 per cent of adults who gambled in the past 12 months rated the last time they gambled positively and only 22 per cent negatively. And coming soon we will be using questions added to the GSGB to give us some of the best insights into gambling with the illegal market we’ve ever had, producing data that researchers and others can access via our website. Combined with other data sources, this will give us the best picture so far of the scale and trends of the illegal market.
The shame for those who are keen to declare their mistrust of the GSGB is that it provides data that they will find useful – data in fact that some have used. One example being that 42 per cent of adults who gambled in the past 12 months rated the last time they gambled positively and only 22 per cent negatively. And coming soon we will be using questions added to the GSGB to give us some of the best insights into gambling with the illegal market we’ve ever had, producing data that researchers and others can access via our website. Combined with other data sources, this will give us the best picture so far of the scale and trends of the illegal market.
Before that though, just today, we have published yet more important research into the online illegal market, importantly regarding who gambles with it and crucially what their wider motivations and attitudes are, including how they apply these views to gambling.
Today's publication builds on the work we published this time last year detailing the four consumer groups who gamble with the illegal market. These are:
Self-Excluders: Defined as users of illegal gambling websites by their circumnavigation of the self-exclusion tool, GamStop. Fiona is here, the CEO of Gamstop group, do talk to her.
Social Explorers: Those that do not self-report intentionally gambling on illegal websites, but have given an indication of illegal gambling website use through some self-reported experiences. These individuals enjoy seeking the best deals and new gambling experiences, and are peer-driven in their approach to gambling.
Skilled Advocates: Those that self-report intentionally gambling on illegal websites. When assessing their attitudes, they are driven by a strong sense of distrust of the licensed market, the pursuit of better value and personal freedom. The individuals in this group perceive an overarching sense of ‘friction’ on licensed websites, which they feel reinforces their decision to use illegal gambling websites.
And Accidental Tourists: Another group that show some indication of illegal gambling website use but do not self-report intentionally gambling on illegal websites otherwise. Qualitatively, their use of illegal gambling websites appears as typically unintentional and casual.
The quantitative phase of this research, undertaken with over 4,000 individuals who had gambled in the last four weeks, excluding lottery-only players, uses a Key Drivers Analysis to demonstrate how strongly each surveyed factor is linked to illegal gambling website usage, relative to the other factors measured. Across the whole sample, some factors found are not common experience-focused factors such as searching for better odds, but instead are deliberate, access-related issues, namely:
Looking for sites not blocked by Gamstop,
using gambling websites that the consumer knew would not ask for much personal data.
At a whole sample level these are not common factors, but the frequency with which they are reported does increase among Self-Excluders and Skilled Advocates in particular.
As I said a moment ago, this research strand has led to the development of metrics that the Commission has added to the GSGB survey, enabling a robust, large-scale monitoring of illegal gambling website use in Great Britain. This will provide a clear evidence base to inform future strategy and also help us track how regulatory interventions and gambling company practices may impact on consumer engagement in the illegal market over time. And we think there is information that can be used by others as well.
This research also makes clear that those who gamble with the illegal market are not all the same. Some, like those who self-exclude, we want to help stay safe. Whilst they are self-excluded, we don’t want them gambling at all. For others, there is the potential that commercial practices in industry could be part of the solution. And for others, such as the ‘accidental tourists’ for example, education and awareness may help protect them. Which feels timely given the work that IAGR is driving forwards in this space. At the Gambling Commission, we support the work of IAGR to tackle the illegal market, such as the working group that we play an active part.
The fight against illegal gambling I think is possibly the strongest example of the progress we can make by working together. As we continue to develop our approach and our toolkit for tackling the illegal market, it is increasingly clear, if it wasn’t already, that working with others is absolutely vital.
Now I mentioned the internet search giants and the payment providers earlier. Financial institutions and social media firms are key as well. We called out the later earlier this year and I’m pleased to say that since then we have seen some positive change in the progress being made by some of the online and social media companies in the UK. In some cases – a step change in the way of working with us. More needs to be done by some of these companies but the engagement we are getting is welcome and you can rest assured we will keep pushing for a proactive approach which does the right thing. For example, not running paid for or otherwise ads for illegal actors committing offences and using social media to promote those, to the determinant of consumers.
This connects to another area where we expect more action and better global citizens, and that is across the wide web of advertising, marketing and affiliates who too often we think are happy to promote licensed and illegal operators at the same time. Again, the good actors who want to uphold industry standards and suppress the illegal market need to work with us to root out the bad.
But more positively, I want to finish by highlighting the value we get, year in, year out from our membership and engagement with IAGR and all of its member bodies. At the Gambling Commission we are proud of the progress we are making tackling illegal gambling through working with all of you but it goes much further than that. From workshops and increasing engagement on Lotteries, to how we can appropriately share data and intel, through to sharing best practice and training on topics as varied as enforcement activity through to jointly exploring AI.
In Great Britain, the last 12 months have been a year of change. The ground beneath our feet has begun to move. I know that is the same for many of you – in what is a global industry no single jurisdiction stands alone. But by keeping our focus on our objectives, by prioritising our action to meet the needs of today and by working with partners and fellow regulators, we continue to make gambling in Great Britain safer, fairer and crime free. The year ahead will bring more challenges. It will for us all. But working together- as seen in the pictures on screen - by maintaining our patience and keeping focussed on those objectives, we can continue to make important progress.
Thank you for listening.
Thank you.
Last updated: 21 October 2026
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