Lotteries Council Annual Conference 2025 - Sarah Gardner speech
22 May 2025
This speech was delivered by Deputy Chief Executive Sarah Gardner at the Lotteries Council Annual Conference on 21 May 2025.
Please note: This is the speech as drafted and may slightly differ from the delivered version.
Hello everyone and thank you for that introduction and that welcome. Before I go any further, I just want to take this opportunity to thank Tony for all his hard work on behalf of your sector over his time as Chair of the Lotteries Council. Tony has always been a strong advocate for society lotteries big and small, and I know I and the team at the Commission have always welcomed his candour and his sometimes unique perspective on the matters of the day. So thank you Tony from the Commission and we look forward to working with George going forwards.
It’s great to be back with you all again this year at the Lotteries Council Annual Conference for what I am sure will be a great couple of days of discussion. That said, I appreciate that I am the first speaker after what I hope was a very nice lunch. I can only assume that I’ve been given this slot because an update from the Gambling Commission is exactly what’s needed to invigorate everyone for the afternoon ahead! So how am I going to achieve that? Well I want to spend a little time paying tribute to how the work all of you do in your communities and across society delivers for the public good. Part of being able to play that role of course means working well with the Commission on how you offer the lotteries that you do so I will touch on the importance we put in a collaborative relationship based on compliance, with those we regulate. That will take me on to what we’re working on right now, from implementing the Gambling Act Review through to changes that we’ve made to the data you provide to us – picking out the most important elements for your sector as well. So plenty of ground to cover. But first a bit of context may help. So what does the sector and gambling more widely look like in Great Britain today?
In February we published participation data for July to October 2024 from our Gambling Survey for Great Britain. This data was drawn from a nationally representative sample of 4,675 adults aged 18 and over. And if we look at that these official statistics, we find that participation in all gambling within the last 4 weeks was stable at 49 percent. But below this headline figure we find that one fifth of respondents - 20 percent - only took part in lottery draws in the last 4 weeks. That being either National Lottery or other charity lottery draws offered by organisations like yours.
And whether we look at online gambling or in person gambling, the participation rate splits in a similar way. With online participation dropping from 38 percent to 16 percent when those who only play lottery draws are removed and in-person dropping from 29 percent to 19 percent when you do the same. And this isn’t surprising when you consider that the top two most popular gambling activities in the past 4 weeks were lotteries, with the National Lottery draws at 32 percent and charity or society lottery draws that all of you represent second on 16 percent.
And that 16 percent has been consistent throughout the data for 2024 that we’ve published so far. In third is scratchcards on 13 percent, something again that some of you in this room will be involved in. For those of you who take an interest in these types of statistics, our next ‘wave’ of quarterly data is actually scheduled to be published tomorrow. So you can find that, as well as research on the reasons people gamble and the impact it can have, all on our website.
This we think tells a clear story about the health of your sector and of course what an important job you do for raising funds for good causes. This is further underlined when we consider that for the first time in our 2023-24 industry statistics, society lottery proceeds exceeded £1 billion for the first time. This represented an increase of 11.9 percent on previous year and a 27 percent increase on the last pre-lockdown period of April 2019 to March 2020. And whilst we don’t monitor the totals for smaller society lotteries, it also means that £461.5 million in contributions to good causes were raised.
That’s a huge amount of public good that can be delivered as a result of your work.
And of course, that is what you are all set up to do – deliver for your good causes. Alongside the National Lottery, society lotteries raise great sums for good causes year in, year out. Up and down the country that benefit is felt and everyone in this room should be recognised for the part you play in that. But as I’m sure you all know, there is a huge responsibility to the good cause you are working for and the wider community that is invested in your work, that you are entrusted with.
That means none of us can take the current health of the sector and the public good that comes from it for granted. And that’s where we come in.
In order to continue to play the positive role in our communities that you do, the public needs rock solid confidence in you and the rules that govern your products. And those rules need to keep up with the changing world we live in. I’ll come back to our work to keep the regulation of the sector aligned with the needs of today later on. But first, I want to touch on how much importance we at the Commission put in having a collaborative relationship with those we regulate, based on compliance at the earliest opportunity.
Those of you who like to keep up with what the Commission is saying will have heard me, or others, talk about this before but at the Gambling Commission we want a collaborative relationship with those we regulate, based on supporting compliance at the earliest opportunity. But what does that mean?
Happily, in recent years we’ve not had to use them in relation to lotteries, but the Commission does have far reaching powers, both to update our rules and to take action when those we regulate fall short of our standards. But we know that we can and do get far more done, far more quickly for consumers, when we work with others instead of relying on our powers alone. Collaboration with those we regulate is part of that.
And I’m pleased to say that we are able to work in this way with the Lotteries Council and all of you as its members. The excellent Society Lotteries team at the Commission work with you day in, day out, sharing best practice and helping you be compliant whilst raising money for good causes. And it’s a testament to the strong, collaborative relationship we have, that the workshops that Louise, Jo and Claire host each year at this event are so well attended and so productive. They are running the workshops throughout the Conference and if you didn’t catch it this morning, they are hosting it again as soon as I finish on stage and again tomorrow. These sessions really are a one stop shop for everything you might need to know to stay compliant, so please do if you can, make the time to join them.
A good example of how we work well together, for the benefit of those who play your lotteries and the good causes you raise funds for, is how you have engaged with our consultations, including for the Gambling Act Review. One great example is of course the changes we made to direct marketing, or cross-selling. Originally we included land-based and lotteries sectors in these changes. But thanks to the significant and well evidenced responses we had from people in this room amongst others, we took the decision not to include land-based gambling and the lottery sectors in scope of this requirement. Positive engagement leading to positive decisions.
Another area where we continue to have healthy engagement is our changes to regulatory returns that we made last year. In general, the move over to quarterly from annual reporting has happened smoothly and so I want to say thank you to everyone here who has played a part in that. More frequent data will help us improve outcomes for those we regulate and consumers who gamble. But there are a few points to mention. First we have seen some anomalies in reported lottery submissions and regulatory returns. We’ve already addressed these with those who are affected and I’m pleased to say we’re already seeing improvements in the quality of the data we hold. Secondly, it’s become apparent that some operators are not reporting changes to key personnel. This is important because we can’t make you aware of changes if we don’t have up to date details. It’s a requirement of a licence to keep this information up to date with the Commission, so if you think your organisation may have an issue, tell one of the team here this week and we can make sure its sorted out.
We also need to keep working together on how we tackle illegal lotteries. We know this is an important and troubling issue for you. And alongside other forms of illegal gambling, it’s one we take very seriously as well, as reflected in our Corporate Strategy. We receive hundreds of referrals for potential illegal draws or prize competitions, all of which we review. And if we focus on just one area, during the period 1st August 2024 to 24 April 2025, we have received and referred to our Enforcement team 93 reports of potentially non-compliant free draws and prize competitions. And rest assured where those investigations uncover illegal or non-compliant activity, we take action.
Back to the Gambling Act Review and of course, the work to implement it continues, and that brings me on to more recent announcements that are relevant to the society lotteries sector.
In February we published the responses to our second round of Gambling Act Review consultations. These concerned new customer led tools, transparency of protection of customer funds and changes connected with the new statutory levy. I’ll come back to the other topics shortly but first, I just want to reflect what some of the changes around customer led tools means for you in this room today and society lotteries as a whole.
These rules, from October this year will give consumers more effective ways to manage their gambling by making it easier to set and maintain deposit limits on their online accounts, in ways that work best for them. But I know these changes have raised some questions for some society lottery providers. To get into the technicalities for a moment, in a response to the consultation, the Lotteries Council had asked that the ‘applicable to’ definitions for lotteries within the Commission’s Remote Technical Standards - or RTS - be amended to make clearer what types of lotteries were captured under the various RTS requirements. That said the consultation’s proposed changes were made on the basis of no change to the current position regarding applicable licence categories.
Because we had not proposed to change the applicable licences descriptions, we consider the current description for the standard should remain unchanged. As a result, society lotteries provision which is currently considered to be exempt from ‘RTS 12’ will continue to be so, captured in this context under the description ‘subscription lotteries’. The focus of these changes in relation to how they relate to the society lotteries sector is when we think about high frequency or instant win lotteries. These are intended to be required to offer financial limits in line with RTS12. These are the only society lottery products we regard as being covered by RTS12 so if your lottery provides these type of products, you need to make sure you are compliant by October. Again, if you have any questions, ask us. Either me or you can see the team during the Conference.
On a similar basis, we listened to the feedback we received from you on our proposed changes to transparency of protection of customer funds. As a result, we have taken the decision to only require society lotteries that offer high frequency or instant win lotteries to abide by the new rules in this area. So again, if you offer those products and you have questions about the requirements to advise consumers on the level of protection you have on their funds, ask us sooner rather than later.
Finally, the Statutory Levy, which has now come into force. This represents a step change for how research, prevention and treatment of gambling harms will be raised, administered and distributed, with around £100 million a year likely to be raised. This is undoubtedly an important step in the fight to minimise gambling harms across our society. But we appreciate there are challenges with the introduction of the Levy. The Levy will be collected by the Gambling Commission and whilst it is Government that has driven the Levy forward, I know that at the Commission we are committed to making the transition as smooth as possible for those paying the Levy as well as those who will depend on it to keep on delivering vital services and research.
There is of course plenty going on to implement the Gambling Act Review, so if there is anything I haven’t mentioned that you would like to know more about, please do ask in the Q&A to follow.
Society Lotteries, alongside the National Lottery, play a vital role in our society, in raising important funds for good causes up and down the country. At the Gambling Commission, we want to make sure you can fulfil that role, compliant with our rules and therefore retaining the confidence of the communities you serve.
Compliance at the earliest opportunity also means we can keep on building that collaborative way of working, with good communication leading to better outcomes for all of you as lottery operators and for the people up and down the country who play them. So we need to keep doing just that. For our part, the Commission will continue to engage and provide you with advice and support where you need it. And in turn we need you to continue to meet our standards.
Thank you and I look forward to your questions.
Last updated: 22 May 2025
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