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Policy

Misuse of inside information: Policy position paper

This document sets out the Gambling Commission’s approach to dealing with potential incidents of misuse of inside information in betting (June 2025).

Appendix 1: Misuse of information spectrum

A detailed overview of the spectrum and an indication the Gambling Commission’s view on the different elements can be found in the following table.

Misuse of inside information spectrum
Type of betting Description Commission definition Commission input Severity
1. Art of betting This end of the spectrum is not inside information. It relates to information which may not be readily known by the general public, but which is available to those who make the effort to find it. It includes for example:

a. Trying to watch players or horses training in a public area.
b. Information provided during media interviews or during public talks.
c. Information that is available to the public, even if payment is required to access the information.
d. Applying knowledge about how a player or horse will perform in certain conditions or over certain ground.
Not inside information. The Commission has no concerns about this type of information. None
2. By chance (uninformed) This is a form of information which will generally not be considered misuse of information would be necessary to establish that the individual could not reasonably have known that the information is restricted. For example:

a. The stereotypical comment ‘overheard in the pub'.
b. Receiving a tip but having no reason to believe the tip is restricted information.
c. Being in the right place at the right time.
d. Working in a hospital where a player is being treated for an injury which has not yet been made public.
Not misuse of inside information. The Commission has no role to play in incidents involving this type of information. None
3. By chance (informed) In these cases, information is received by chance by an individual, but that individual should reasonably be aware that the information is restricted and should not be used for gain or passed onto third parties. For example:

a. A sports club employee overhearing a conversation between 2 senior employees, on club premises and where the individual is aware that the information is not in the public domain.
b. A stable lad observing concerns for the welfare of a horse or noticing that a vet has been called to assess a potential gallops injury.
Inside information. Although the Commission would have some concerns in this area, it is likely that we would consider sports rules, education programme, referral to employer and/or the SGB and other disruptive action to be appropriate.

In particular, we wish to encourage sports and other bodies to quickly release information which is sensitive in betting terms to the public, as this is an appropriate means to limit the impact in this area.
Moderate
4. Restricted information This is information which the individual has gained because of their role in connection with the sport or event; or because of a close association with an individual with such a connection. This information is then used for financial gain or passed onto a third party. For example:

a. A club official with advance information about a team line-up that has not been made public.
b. A club official with inside knowledge of the club manager leaving his position who uses or passes on this information to a third party for betting purposes.
c. An employee working on a television competition (for example TV talent or reality competitions) with advance knowledge of the health of a competitor, participation in a TV show or of early phone results.
d. An employee of a licensed betting operator who becomes aware of information relating to an event and uses the information for commercial advantage.
e. An employee of a licensed betting operator uses information about unusual betting patterns to place a bet and does not take the appropriate action to notify their employers.
Potential misuse of inside information. The Commission would have concerns in this area.

In most cases, the appropriate form of sanction would be through the Sports Body or through the employer, combined with the betting operator refusing the bet under contractual terms.

The Commission would have serious concerns in this area, although the circumstances of each individual case would have to be considered.

The Commission may consider taking action to void a bet.
Severe
5. Awareness of possible criminality (or malfunction) This could be described as ‘getting in on the act’ such as where an individual spots some potential criminality and attempts to use that information to place bets. It could also cover an individual who becomes aware of a malfunction in processes which enables them to have prior knowledge of the outcome of an event. For example:

a. A trader spotting a strong trend of bets contrary to the odds in a location close to the home of a primary participant.
b. A trader or retail worker identifying individuals connected to a group of players placing bets on their team to lose.
c. Being aware of an attempt to dishonestly manipulate betting odds or an event. They are not part of this attempt or have not initiated or paid for this manipulation to occur but have become aware of the attempt through their role.
d. Becoming aware of a breach in sports rules which provides an advantage to those with advance knowledge – for example knowing that a participant intends to pull out of a tournament or event despite a public commitment to participate.
e. Commonly, the Commission would identify this behaviour when an employee of a betting operator fails to protect the operator from exposure to risk and fails to make a 15.1 report and instead gains from making bets using the information.
Potential aiding and abetting a criminal offence. The Commission would have serious concerns in this area, although the circumstances of each individual case would be considered. These circumstances would determine which cases we would consider appropriate for criminal investigation. For those who were aware of an attempt to manipulate the event or the odds, we would most likely consider referral to the sports body or employer to apply an appropriate sanction. We would encourage betting operators to consider and address the risks of betting by their staff through education and employment terms. Those individuals (such as traders) who have access to information should be educated about the proper use of that information and the sanctions which may occur.

The Commission may consider taking action to void a bet.
Severe
6. Manipulation of the event In this case, an individual(s) has manipulated the event or part of the event and individuals who are aware of this use that information to place bets. For example:

a. Spot fixing (or in play betting) – this relates to bets on events within a match or event such as awarding of the first penalty.
b. Match-fixing - deliberately losing or being part of a collusion to fix the result of a match or event.
Potential Offence relating to:

- Cheating
- Bribery
- Proceeds of Crime
- Fraud
- Conspiracy.
The Commission would have serious concerns in this area, although the circumstances of each individual case would be considered. These circumstances would determine which cases we would consider appropriate for criminal investigation. For those who were aware of an attempt to manipulate the event or the odds, we would most likely consider referral to the sports body or employer to apply an appropriate sanction. We would encourage betting operators to consider and address the risks of betting by their staff through education and employment terms. Those individuals (such as traders) who have access to information should be educated about the proper use of that information and the sanctions which may occur.

The Commission may consider taking action to void a bet.
Severe
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Management of potential incidents - Misuse of inside information
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