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Consolidation of operator complaints and disputes data October 2019 – September 2020

The purpose of this report is to look at all operator complaints and disputes received by the Gambling Commission and analyse key issues, themes and trends

Published: 21 October 2021

Last updated: 21 October 2021

This version was printed or saved on: 3 December 2022

Online version: https://www.gamblingcommission.gov.uk/report/consolidation-of-operator-complaints-and-disputes-data-october-2019

Executive Summary

The purpose of this report is to look at all operator complaints and disputes received by the Gambling Commission and analyse key issues, themes and trends from the Contact Centre, Alternative Dispute Resolution (ADR) providers, the resolution service Resolver and from Regulatory Returns. A description of each source can be found in Appendix 2. The report is designed to be a reference that combines multiple complaint/dispute datasets into a single coherent source.

The reporting periods for each dataset are October to September to align with ADR reporting and to ensure each dataset is being compared with the same time frame. Data described in this report relates to complaints closed within the above period.

There were a total of 151,956 complaints during October 2019 - September 2020 across regulatory returns, the Gambling Commission’s Contact Centre, ADRs and Resolver, with regulatory returns accounting for the majority of these. This is a decrease of 21,410 (12.3%), compared to the same period in 2018/19. Note that there will be duplication of complaint numbers across these data sets, for example a consumer could use Resolver for help in constructing their complaint, before complaining to the Contact Centre and then potentially escalating to an ADR.

A graph showing the total number of closed complaints

Data from graph

Type 2017-18 2018-19 2019-20
Regulatory Returns - Complaints 164,091 155,199 132,862
Contact Centre Complaints 7218 9612 9342
Regulatory Returns - Disputes Esc to ADR 7842 9248 9887
Resolver Complaints 6360 8555 9752
ADR Disputes - IBAS 5186 5235 4475
ADR Disputes - eCOGRA 895 951 1142

The way complaint types are structured is different for each data set, which can make direct comparisons between each difficult. Instead, key themes have been extracted from each data source. The main issues raised by consumers are regarding their accounts, which generally involves non-payment of winnings, account closures, and Social Responsibility, which includes consumers being allowed to gamble after self-excluding.

Overview of closed complaints by data source

The main complaints raised by consumers across all organisations are regarding accessing their accounts and withdrawing/receiving the money they believe they are owed, with particular issues around non-payment of winnings and the social responsibility of operators.

Regulatory Returns Complaints

132,862 - 2019/20 (- 14.4% change)

Regulatory Returns Disputes - Available for ADR Escalation

9,887 - 2019/20 ( + 6.9%)

Contact Centre Complaints

9,342 complaints received during 2019-20, a decrease of 270 (-2.8%) compared to the previous year.

Nearly 80% of all Consumer Complaints involve:

Resolver

9,752 complaints received during 2019-20, an increase of 1,197 (14.0%) compared to the previous year.

The most prevalent complaint type during 2019-20 is Accounts (42.2%), this includes consumers being unable to withdraw funds or having their accounts closed.

ADR

5,617 disputes received during 2019-20, a decrease of 569 (- 9.2%) compared to the previous year.

The most common dispute type received by IBAS was Disputed Settlement Criteria/Bet Instructions (23.4%).

The most common dispute type received by eCOGRA was Deposits and Withdrawals (32.6%).

Reporting covers 1st October to 30th September to align with ADR reporting periods.

The previous information gives an overview of the complaints landscape. Further detailed information regarding each data source can be found in Appendix 1.

Of all enquiries received by the Gambling Commission Contact Centre during the 2019-20 reporting period, 42.2% were regarding consumer complaints. In total, 9,342 consumer complaints were received by the Contact Centre in 2019-20, a decrease of 270 (2.8%) compared to the previous year.

The number of complaints received by operators (as reported to the Gambling Commission via Regulatory Returns) has decreased by 22,337 to 132,862 during October 2019 to September 2020 (14.4% decrease).

Regulatory Returns show there has been an increase in consumers escalating their dispute to an ADR, from 16.3% of reported disputes during 2018-19, up to 18.7% in 2019-20 (9,886 escalations in total). This includes all ADR referrals including those which are refused.

The resolution service Resolver has seen an increase in the proportion of disputes escalated to ADRs, from 14.8% in 2018-19 up to 18.7% during 2019-20.

The two largest ADR providers, IBAS and eCOGRA, reported a total of 5,617 disputes escalated to them during 2019-20. Of these disputes, 3,118 resulted in a resolution, whereas 2,499 disputes were refused. Reasons for refusal include customer communication ceased, operator complaint process not exhausted (complaint reported to ADR before operator 8-week resolution period) and regulatory matters (e.g. self-exclusion).

IBAS, eCOGRA and Resolver have all shown a decrease in the average dispute resolution time, although there are varying time periods across the three, 45 days, 19 days, and 16 days respectively. This can potentially be explained by the complexity of the cases they receive.

Recommendation

To enable more robust reporting of the complaints landscape in the future, we recommend work to standardise the complaints categories across all organisations.
This would allow a more comprehensive analysis of the complaints being raised by consumers and would also show if certain complaint types were more likely to be escalated to an ADR.

Appendix 1

Gambling Commission, Contact Centre Complaints

Of all enquiries received by our Contact Centre during the 2019-20 reporting period, 42.2% were regarding Consumer Complaints. In total, 9,342 consumer complaints were received by the contact centre in 2019-20, a decrease of 270 (2.8% decrease) compared to the previous year.

The main complaint type received was Customer Service Issues (2,018), followed by Non-payment - all other (1,577), although when all Non-Payment complaint sub-types are combined, this becomes the greatest complaint area (3,259).

Combining all Social Responsibility sub-types, also shows a much larger proportion of complaints, with 2,160 during 2019-20.

Combining the Non-Payment, Social Responsibility and Customer Service Issues complaint types accounts for 79.6% of all consumer complaints received in 2019-20, a slight increase from 79.3% during the previous year.

Graph 2 - Percentage of complaint sub-type received by Contact Centre

Data from graph

Type 2019-20 2018-19 2017-18
Non-payment - insolvency 0.6% 0.1% 0.1%
ID Request - Prevented from Gambling 1.1% 0.6% 0.0%
National Lottery 2.2% 1.6% 0.5%
M&A 2.0% 2.1% 2.9%
Unfair RNG 2.8% 4.0% 3.9%
Terms & Conditions 3.3% 4.6% 6.2%
SR – GAMSTOP 3.5% 4.1% 0.7%
SR – Self Exclusion 7.3% 9.4% 13.5%
Non-payment – ID request issue 7.9% 10.8% 13.4%
Illegal activity 9.0% 7.9% 7.3%
Non-Payment - Additional Verification 9.5% 3.2% 0.0%
SR – all other 12.4% 12.3% 10.0%
Non-payment – all other 16.9% 14.5% 12.3%
Customer Service issue 21.6% 24.7% 29.1%

Gambling Commission, Regulatory Return Complaints

The number of complaints received by operators (as reported to the Gambling Commission via Regulatory Returns) has decreased by 22,337 to 132,862 during October 2019 to September 2020 compared to the previous 12 months (14.4% decrease).

Graph 3 - Number of Regulatory Return Complaints

Data from graph

Type 2017-18 2018-19 2019-20
Regulatory Returns - Complaints 164,091 155,199 132,862
Regulatory Returns - Disputes Esc to ADR 7842 9248 9887

The number of disputes being escalated to an ADR has slightly increased (9248 to 9887), with 23.4% of disputes being escalated during 2019-20, compared with 16.3% during the previous period. The larger percentage increase is due to less disputes being recorded. The Regulatory Return data does not currently specify what these complaints or disputes refer to.

There is a disparity between Regulatory Return disputes escalated to an ADR (9887) and the total disputes reported by the two main ADR providers, IBAS and eCOGRA (5617). Current operator guidance states ‘Record the number of disputes that you are aware have been referred to an ADR within the reporting period’. This may explain the higher number as not all consumers will necessarily continue with their dispute and contact an ADR.

When looking at the Regulatory Return sector split there is a large disparity between remote and non-remote operators. There is a larger number of complaints, disputes and disputes escalated to ADR from remote operators compared to non-remote. There are more non-remote (1174) operators, compared with remote (874), with 493 classified as both remote and non-remote.

A graph showing Regulatory Returns Complaints by Sector

Data from graph

Year All Remote Non-remote Remote/Non-remote
2017-18 164,091 136,583 26,916 592
2018-19 155,199 121,862 32,888 449
2019-20 132,862 109,099 22,953 810

The number of complaints received by remote operators has decreased in 2019-20. The number of disputes escalated to an ADR shows an opposite trend, increasing compared to the previous year.

A graph showing Regulatory Returns Disputes Escalated to ADR by Sector

Data from graph

Year All Remote Non-remote Remote/Non-remote
2017-18 7842 6752 1086 4
2018-19 9248 8494 754 -
2019-20 9887 9535 340 12

Resolver

The total number of complaints received by Resolver for reporting period 2019-20 (October to September) was 9752, an increase of 1197 (14.0% increase) compared to the previous 12 months.

The main complaint type during 2019-20 was Accounts, this includes consumers being unable to withdraw funds or having their accounts closed. This complaint type has also seen the largest increase compared to the previous year (1105, a 36.7% increase).

Graph 6: Top 5 Complaint Types received by Resolver
Gambling complaint type includes issues with odds, interruption in play, cash-out, no description of rules.

Data from graph

Type 2017-18 2018-19 2019-20
Accounts 35.1% 35.2% 42.2%
Other (none of the previous) 22.4% 19.0% 17.3%
SR issues (new category) 13.4% 15.4% 12.4%
Customer Service 9.4% 10.3% 10.1%
Complaints procedure 6.7% 8.9% 9.5%

Of the 9,752 cases received by Resolver during 2019-20, 18.7% were escalated to an ADR, this was an increase from 14.8% during the same period the previous year. While both Resolver data and regulatory returns shows an increase in the number of cases escalated to an ADR, the percentage increase for Resolver was less than that reported in regulatory returns (3.9% compared with 7.1%).

During 2019-20, 1,821 cases were escalated and Accounts (37.9%) had the largest escalation rate, compared with Licensing (0.2%) which had the lowest. There is a similar trend for the previous year.

The average resolution time for a case logged with Resolver was 15.87 days during 2019-20, a decrease from 20.88 days in 2018-19.

Alternative Dispute Resolution (ADR)

IBAS

IBAS received 4,475 disputes during 2019-20, a decrease from 5235 during 2018-19 (14.5% decrease). The most common issue received by IBAS was Disputed Settlement Criteria/Bet Instructions1 (1048). The number of these types of dispute has decreased by 348, but still remains the main dispute type over the last 3 years.

The second most common complaint type is Customer Identity, this is a growing area of complaint, with very few exceptions it exclusively concerns remote gamblers. Typically, the complaint is that a consumer has seen their account closed or has been denied immediate payment of winnings or where the operator has concerns about whether the customer is who they say they are.

A graph showing the top 6 dispute types by IBAS

Data from graph

Type 2017-18 2018-19 2019-20
Disputed Settlement Criteria / Bet Instructions 30.0% 26.7% 23.4%
Customer Identity 13.5% 14.8% 21.1%
Social Responsibility / Self-Exclusion 7.6% 13.6% 16.8%
Bonus or Promotional Offer Terms 12.1% 9.8% 8.2%
Price Dispute 12.7% 10.7% 7.6%
Banking/Financial Transactions 3.4% 3.4% 6.7%

The proportion of disputes refused by IBAS during the 2019-20 reporting period was 43.9% (1,964), which is a decrease from 38.9% (2,039) during the previous year. The main reasons for disputes to be refused are regulatory issues, which includes self-exclusion, and that the operator’s complaints process has not been exhausted.

A graph showing the Top 6 Refused Dispute Types received by IBAS

Data from graph

Type 2017-18 2018-19 2019-20
Regulatory Matter (e.g. self-exclusion) 27.1% 33.5% 33.2%
Operator's Complaints Process Not Exhausted 10.8% 21.4% 30.8%
Customer Communication Ceased 43.1% 22.8% 16.0%
Vexatious/Frivolous Dispute 9.1% 8.6% 10.6%
Too Complex/Requires Legal/Police Investigation 4.8% 5.6% 4.0%
Operator Not Registered with IBAS 4.2% 5.0% 2.7%

The average dispute completion time during 2019-20 was 45 days, which is a decrease from 51 days during the previous year.

eCOGRA

eCOGRA received 1,142 disputes during 2019-20, an increase from 951 during 2018-19 (20.1% increase).

The main complaint type received by eCOGRA in 2019/20 was Deposits and Withdrawals (32.6%), this dispute type has seen a slight decrease compared to the previous year (34.9%).

Please note that due to a change in reporting methodology, 2019-20 data only shows Total Completed Disputes by Type, whereas previous year’s show Total Disputes by Type.

A graph showing Top 6 Dispute Types received by eCOGRA

Data from graph

Type 2017-18 2018-19 2019-20
Deposits & Withdrawals 7.6% 34.9% 32.6%
Responsible Gambling 20.2% 33.2% 19.3%
Bonuses & Promotions 39.0% 9.7% 16.6%
Locked Accounts 10.2% 6.7% 14.0%
ID Verification 8.9% 6.6% 8.5%
Disputed Bets 5.6% 3.5% 4.8%

The main issues encompassed within Deposits and Withdrawals are withdrawals being delayed due to requests for source of funds / wealth evidence. This is followed by Responsible Gambling, where the main issue is self-exclusion, i.e. that the consumer has been able to gamble after requesting self-exclusion.

There has been a large decrease in complaints regarding Bonuses and Promotions, which was the main complaint type in 2017/18. These disputes generally relate to bonus specific rules and in particular the maximum bet.

A graph showing Top 6 Refused Dispute Types received by eCOGRA

Data from graph

Type 2017-18 2018-19 2019-20
Operator Dispute Process Not Exhausted First 31.0% 40.4% 46.9%
GB Gambling Commission Regulatory Issues 39.0% 37.9% 38.1%
Duplication Dispute/Dispute Already Submitted 6.0% 10.7% 4.3%
Disputes Closed at the Player's Request 6.0% 3.4% 5.2%
Disputes Outside 12 Month Time Limit 4.0% 3.1% 1.7%
Frivolous or Vexatious Disputes 6.0% 1.6% 0.6%

The proportion of disputes refused by eCOGRA during the 2019-20 reporting period was 46.8% (535), which is an increase from 33.5% (319) during the previous year. The main reasons for disputes to be refused are consumers not exhausting the operator complaints process first and regulatory issues.

The average time taken to resolve domestic disputes during 2019-20 is 19 days, which is a decrease from 38 days during the previous year.

Appendix 2 - Data source description

Regulatory Returns

As part of the Licence conditions and codes of practice (LCCP) operators are required to provide information on the range of gambling activities provided by the licensee. The codes of practice require operators to log complaints made about any aspect of the conduct of the licensed activities, other than those that are resolved at the first stage of the operator’s complaints resolution procedure. The number of complaints logged within the reporting period needs to be recorded irrespective of the outcome.

Disputes are that subset of complaints which concern the outcome of the customer’s gambling transaction. They do not include wider concerns that may relate to the conduct of the gambling operation. As disputes are a subset of complaints, the number of disputes reported on the regulatory return will also be included in the count of complaints on the regulatory return. There is a separate requirement in the code of practice in the LCCP concerning those disputes that were referred to an independent party for resolution.

Operators must also report to us the total number of disputes that are escalated to an ADR entity.

Please note that the Gambling Commission recently consulted on changes to the regulatory returns that would require licensees to report complaints in a different way. Instead of providing a total, there will be a requirement to report against different complaint categories.

Alternative Dispute Resolution (ADR)

Licensees are required to use an ADR provider that appears on our approved list. ADR providers must comply with the ADR regulations and meet our additional standards. Licensees must meet the standards in the LCCP and our associated guidance when handling complaints.

There are 8 Gambling Commission approved ADR providers, this report focuses on the largest two (in terms of gambling related disputes ), which are IBAS and eCOGRA and are used by over 90% of gambling operators . A consumer must contact the betting operator first with any complaint, the operator then has 8 weeks to resolve the issue before it can be escalated to an ADR.

Resolver

Resolver is a free, independent tool for consumers. It provides information about the issue the consumer wants to complain about, and support to help the consumer write emails and letters of complaint. Resolver is not an intermediary and doesn’t act on the consumer’s behalf – but it does help the consumer to make their complaint in a structured way, and to make informed choices about what actions to take.

Appendix 3

Type Sector
Remote Gambling Software
Remote Gaming Machine and Software Manufacturers
Remote Gaming Machine and Technical
Remote Gaming Machine Supplier
Remote Remote Casino, Betting and Bingo
Remote Trading Room Only
Non-remote Adult Gaming Centre
Non-remote Betting
Non-remote Bingo
Non-remote Casino
Non-remote Casino 2005
Non-remote Family Entertainment Centre
Remote/Non-remote External Lottery Manager
Remote/Non-remote Society Lottery