Consumers' views on informed choice in gambling

Executive summary

This research sets out to establish what "informed choice" means to gambling consumers in practice, moving beyond the regulatory principle to the lived experience of making decisions while gambling. It combined a rapid desk review of 53 sources, 3 deliberative focus groups, and 4 in-depth interviews with players at higher risk of harm, mapping findings against the Gambling Commission's Path to Play framework.

Participants viewed the Commission's current definition as a strong starting point, valuing its emphasis on fairness and accessible information¹. But they consistently identified a gap between information being available and consumers feeling informed. Across each stage of gambling, people described information that existed on a platform but did not translate into understanding, because it was hard to find, hard to interpret, or surfaced at the wrong moment. This distinction between provision and comprehension is one that comparator sectors, notably through the Financial Conduct Authority (FCA) Consumer Duty, have increasingly built into regulation, and the findings suggest it is not consistently met in gambling². The consequences extend beyond the risk of gambling harm: consumers who cannot interpret odds, verify payouts, or understand the terms attached to a promotion may be worse off through decisions they would not have made with adequate information. This engages the Commission's 'fair and open' licensing objective as much as its duty to protect consumers from harm.

In this project, participants identified 4 limitations in the current definition:

• information that is technically available but practically obscured during fast-paced or in-venue play
• a static view of the consumer that does not distinguish beginners from experienced players or onboarding from ongoing support
• a focus on administrative transparency over gambling companies' active commitment towards consumer protection, especially towards higher-risk players
• an assumption of odds literacy that leaves consumers unsupported with complex modern products.

On responsibility, participants favoured a shared model but did not hold this evenly across the journey. Before gambling, they were comfortable with personal responsibility, provided information was visible. During play, particularly in immersive or fast-paced contexts, they were more willing for gambling companies to intervene on their behalf. After play, some looked beyond the operator entirely, to banks or a central body with oversight of total spend across platforms. Where responsibility sits depends on the stage, the product, and the consumer's capacity at that moment.

There were 2 further themes that cut across the findings. Personalised information and interventions were consistently valued over generic messaging, which participants found easy to ignore; yet the same behavioural data that enables a helpful intervention also enables targeted marketing, and some participants were openly distrustful of gambling companies' motives for collecting it, and needs varied substantially by product type: sports bettors arrived with a goal and experienced interruptions as a hindrance, casino players needed accessible explanations and active interventions during immersive play, and land-based players operated in an environment where formal information provision was largely absent.

Drawing these findings together, the report proposes a consumer-centred baseline definition to guide future work:

• informed choice in gambling is the consumer's ongoing ability to understand and act on the information relevant to their decisions at each stage of play
• it requires that the rules, odds, mechanics, costs, and risks of a product are presented so that consumers can genuinely understand and use them, with the same prominence as promotions and rewards
• it requires that information and support adapt to a consumer's experience, capability, and changing state, including an active commitment towards consumer protection and those at greater risk of harm
• it recognises that informed choice is shaped before play by the wider information environment, and can be eroded during play by design, pace, and emotional state.

This deliberately extends the current definition in 4 respects: it treats informed choice as a continuous state rather than a pre-play moment; it requires comprehension rather than availability alone; it places an emphasis on gambling companies to take a commitment towards consumer protection, especially those who are at greater risk of harms; and it accommodates varying levels of literacy and capability.

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¹ The current statement of principles, as established by the Commission, defines Informed Choice as: 5.13. The Commission expects that not only is gambling fair in the way it is conducted and/or provided, but that the rules are transparent to players and they know what to expect. 5.14. The Commission will ensure that the rules are fair and that easily understandable information is made readily available by operators to consumers about, for example: the rules of the game, the probability of losing or winning, and the terms and conditions on which business is conducted.

² The Consumer Duty (opens in new tab) sets the standard of care that firms should give to retail consumers. It moves beyond compliance checklists and focuses on embedding fairness, transparency, and customer-centricity into every interaction.

Introduction

Background

One of the Gambling Commission's core licensing objectives is to ensure that gambling is conducted in a fair and open way. Central to this is the expectation that consumers are able to make informed choices about their gambling: that products deliver what they promise, that rules and odds are transparent, and that consumer issues are addressed properly and promptly.

The current statement of principles defines informed choice in relatively broad terms. The Commission expects that gambling is fair in the way it is provided, that rules are transparent, and that players know what to expect. It commits to ensuring that easily understandable information is made readily available by gambling companies, covering the rules of the game, the probability of losing or winning, and the terms and conditions on which business is conducted. However, there is a lack of evidence-based understanding of what "informed choice" actually means to consumers in practice. This includes what information consumers need and when, the barriers and motivations that shape whether they engage with it, and the role that gambling companies and the wider environment play in supporting or undermining informed decisions.

What existing evidence tells us about informed choice

A rapid desk review, conducted as the first phase of this project, examined how informed choice is conceptualised in gambling and in 3 comparator regulated sectors: financial services, energy, and online safety. It assessed 53 sources and identified 5 themes that shaped the design of the qualitative research that followed.

1. Informed choice is not a single moment but a continuous state. Understanding is shaped long before play by social norms, marketing exposure, and prior experience, and can be eroded during play by dissociation, narrowed attention, emotional arousal, and immersive product design. A framework focused only on pre-play transparency risks missing much of what determines whether a consumer is genuinely informed.
2. Providing information is not the same as ensuring comprehension. Across comparator sectors, the regulatory direction of travel is away from disclosure-based standards ("was the information made available?") and towards outcome-based standards ("can the consumer actually understand and use it?"). The Financial Conduct Authority's (FCA) Consumer Duty is the clearest example, requiring firms to demonstrate that their customers genuinely comprehend what they are being told.
3. Consumer motivation to engage with information is variable, not absent. Generic messaging tends to fail not because consumers cannot read it, but because they do not find it relevant enough to process. When information is personalised, timely, and actionable, engagement increases.
4. The choice environment can actively work against informed decisions, not merely fail to support them. Burying information behind additional clicks, pre-setting unfavourable options (such as higher stake sizes or opt-ins to marketing or bonuses) that consumers must actively opt out rather than opt in, introducing friction into withdrawals while streamlining deposits, and placing safer gambling messages where they compete with high-stimulus content all materially reduce the likelihood that consumers will make informed choices.
5. The division of responsibility between consumers, gambling companies, and regulators remains contested. Existing evidence suggests consumers favour shared responsibility but are divided on how proactive gambling companies should be.

Together, these themes provided a foundation for the qualitative research, identifying where the evidence base was thin on consumer perspectives and where there were open questions that only consumers themselves could answer.

Key objectives and approach

This work will build upon existing research conducted by both the Gambling Commission and external organisations, specifically addressing theme 4 of the Commission’s Evidence Gaps and Priorities programme: ‘The impact of operator practices’ and the Consumer Comprehension Evidence Roadmap.

This project was designed to address 4 objectives:

1. To define informed choice from the consumer's perspective: assessing how different consumer groups interpret the term and the extent to which they feel empowered to make informed decisions in current gambling environments.
2. To explore practical implementation: investigating what informed choice looks like when translated from a theoretical definition into real-world consumer journeys, using the Gambling Commission's Path to Play framework as a guide.
3. To examine the responsibility split: building on previous deliberative work (opens in new tab) (BIT, 2025), which indicated that consumers place a high degree of responsibility on gambling companies while acknowledging their own role, and seeking to define where the balance of responsibility lies in practice at different stages of the journey.
4. To consider the balance between information and experience: exploring how best to provide information to support informed choice without creating additional frictions that undermine the enjoyment of a product.

Structure of this report

The remainder of this report is organised as follows. The next section outlines the study's methodology. The findings then begin with how consumers understand informed choice, whether they feel informed and where they place responsibility for it. Then it examines participants’ views on informed choice through the Path to Play framework, across the stages of the gambling journey: deciding whether and what to play, the play experience itself, and how consumers stay informed of outcomes. The report concludes with a set of cross-cutting themes drawing together the key findings and next steps.

In addition to this report, we provided the Commission with a conceptual framework¹ that draws on the report’s insights to outline recommended steps to conceptualise and measure informed choice. The framework offers practical recommendations for identifying key outcomes that can be used to assess whether informed choice is achieved in practice, the target behaviours necessary to deliver those outcomes, and approaches for evaluating the barriers and facilitators that influence those behaviours. Ultimately, the framework, together with this report, can support the Commission in prioritising future research and generating further experimental evidence on consumer comprehension and decision-making.

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³The conceptual framework was provided to the Gambling Commission as an internal working tool and is not published alongside this report.

Method

Rapid desk review

A rapid desk review was conducted ahead of the qualitative fieldwork to establish an evidence base and inform the design of topic guides and stimulus materials. The review covered 2 areas: existing evidence on informed choice within the gambling sector, and how informed choice is defined and operationalised in 3 comparator regulated sectors (financial services, energy, and online safety). In total, 53 sources were assessed, including experimental studies, meta-analyses, regulatory frameworks, and policy papers. Findings were mapped against the Gambling Commission's Path to Play framework to connect the evidence to specific stages of the consumer journey.

Qualitative sample design and recruitment

The research sample consisted of 22 individuals selected via purposive sampling to ensure a diverse and comprehensive range of perspectives. The primary eligibility criterion required all participants to have experience with various types of gambling, either currently or in the recent past. Participants were also screened using the Problem Gambling Severity Index (PGSI), which was used both to segment the sample by risk and to determine the appropriate research method, as described below. Beyond these criteria, the sample contained a sufficient range and diversity: we sought a mix of people based on gender, location, ethnicity, and socioeconomic status. Sample breakdowns are provided in Appendix A. Participants were recruited through a specialist recruitment agency. Incentives were provided to all participants.

To capture the nuances of different gambling behaviours and varying levels of risk, the sample was segmented into two distinct methodologies: deliberative focus groups and in-depth interviews.

3 deliberative focus groups consisted of 6 participants each, all having a Problem Gambling Severity Index (PGSI) score below 8 and a diverse range of demographics. These groups were segmented by product type to allow for targeted discussions.

Group 1, sports bettors: a mix of casual and regular sports bettors, who had various levels of experience with other types of gambling.

Group 2, online casino and slots players: a mix of occasional and frequent players who predominantly engaged in online gambling such as slot games or casino-like games.

Group 3, land-based: a mix of individuals who gamble in land-based betting shops (that is, use machines in betting shops and/or place sports bets), who had various levels of experience with other types of gambling.

4 individual in-depth interviews were conducted with participants scoring 8 or above on the PGSI, indicating a higher risk of gambling-related harm. Interviews were used rather than group settings for this cohort to provide a safe, focused environment for discussing how informed choice and platform design intersect with higher-risk gambling behaviours.

Data collection

The deliberative format was chosen because it allows participants not only to share their individual views but also to engage with new information, consider different perspectives, and develop more considered positions over the course of the session. This was particularly important given the complexity of informed choice as a concept. Each session moved through a structured discussion covering participants' initial understanding of informed choice, their views on the Gambling Commission's current definition, their experiences of making informed decisions at different stages of the gambling journey, and their views on who should bear responsibility. Stimulus materials, including a working definition of informed choice based on existing evidence, screenshots of gambling platforms, and examples of game descriptions and odds displays, were used to ground discussions in real-world experiences.

The 4 in-depth interviews followed a similar structure but allowed for deeper exploration of individual experiences, particularly around how platform design and operator practices intersected with periods of higher-risk gambling.

Topic guides for the focus groups and interview schedules were reviewed by the Gambling Commission's Lived Experience Advisory Panel (LEAP) to ensure that research materials met appropriate standards of care and reflected the perspectives of people with lived experience of gambling.

Analysis

A framework approach was used for data management to support thematic analysis. Data from focus groups and interviews were organised into a structured matrix, with columns for sub-themes and rows for individual participants. This approach facilitated comparison across participants, gambling types, and stages of the gambling journey, while preserving the nuance of individual perspectives.

The data analysis aimed to draw out the range of behaviours, experiences, and views from the data, while identifying similarities, differences and links between them. Findings were mapped against the Path to Play framework to connect consumer perspectives to specific stages of the gambling journey.

Ethics

Gambling is a sensitive topic, and this study addressed behaviours that may be considered risky or legally complex. A full ethics review was completed ahead of the study’s launch to ensure principles for ethical research were met, and appropriate participant safeguards were in place. This included an internal ethics review conducted by BIT’s ethics specialists, and an external review conducted by the Commission, following their Research Governance Framework.

Informed consent was obtained from all participants ahead of the study. Participants were made aware of available support services, and researchers were briefed on protocols for managing distress during sessions.

Qualitative research findings

General views on informed choice in gambling

Views on the definition of informed choice

When first asked what the term “informed choice” means in the context of gambling, participants emphasised the importance of consumers having sufficient information to make informed decisions. This included understanding whether a platform is safe and legal, whether their money and personal data are secure, how gambling products and games operate in practice, how much they can win or lose and the chances for this, how to stay safe, what games are more at risk, and how to ask for support if needed.

Overall, participants viewed this definition as a strong starting point. In particular, they valued the principles that gambling companies should provide consumers with clear and accessible information and that gambling should be fair. However, some also highlighted several areas where the definition and its implementation in practice could be strengthened.

A recurring theme across the deliberative focus groups was that informed choice depends not only on information being available, but also on it being easy to access, understand, and apply at relevant points in the user journey. Some participants described situations where information about games, odds, or rules was difficult to find, for example, in gambling venues where they needed to ask dealers or staff members for clarification, or when playing online live casino games. As a result, some framed the challenge less as a lack of a clear definition, and more as a 15 gap between the principle of informed choice and how it is operationalised by gambling companies.

Participants who were more critical of the current definition identified several perceived limitations. First, some felt the definition does not sufficiently distinguish between the information needs of new consumers and the ongoing support required for existing players to remain informed over time. Second, participants felt the definition could place greater emphasis on gambling companies' responsibility for consumer protection, particularly in supporting consumers who may be at greater risk of gambling-related harm. Third, some believed the definition should more explicitly include information about the risks associated with gambling and help consumers identify what products can lead to the highest risk of harm or how to find support. Finally, it was noted that the definition provides limited guidance on more complex gambling products and experiences, where understanding probabilities, mechanics, or financial implications may require additional support.

Overall, while the current definition was positively received, participants wanted it to go further in requiring gambling companies to actively protect consumers and support genuine comprehension across the different stages of gambling. Their concerns were not limited to the risk of gambling harm; many related more broadly to whether consumers could make decisions on fair terms, for example whether they could understand the true cost of a promotion or verify that a game was operating as described. These findings are aligned with previous research in gambling and other domains. Parke et al. (2014) argued that informed choice is not just a pre-play decision but "a continuous state that must be maintained during the act of gambling," because the psychological dissociation and narrowed attention that occur during play can erode whatever understanding a consumer had before they started⁴ .

Do participants feel informed?

Participants' sense of how informed they felt varied considerably, shaped by the type of gambling they engaged in, their level of experience, and the complexity of the products they used.

Those who played familiar games or had extensive experience tended to feel confident in their understanding. One sports bettor noted: "I think I'm quite confident in understanding the odds," while another described having learned intuitively through years of using apps, promotions, and platforms. Some felt they simply knew enough: "I know what I need to," as one participant put it. Others felt informed through their own research, studying player patterns, comparing odds across gambling companies, or using external data sources before placing bets.

However, this confidence was not universal. Several participants acknowledged uncertainty around complex terms and mechanics, particularly Return to Player (RTP) metrics and multi-leg accumulators. Others lacked confidence in interpreting odds altogether, relying on friends or family to translate them, or simply ignoring odds when playing for fun.

Who should be responsible for informed choice?

Across the discussions, there was a consensus that gambling companies should be responsible for providing information in visible places and in ways that are easy to understand at a glance. There was agreement that their observed current status quo, where information is technically present but requires consumers to actively look for it, is insufficient. This need to shift from information provision to comprehension was also observed when looking at what informed choice looks like in other sectors: the Financial Conduct Authority's (FCA) Consumer Duty (2022) requires firms not just to provide information, but to prove that their customers actually understand it, and to remove sludge that creates unreasonable barriers⁵.

While participants acknowledged that consumers retain personal autonomy, and that different products require varying levels of active information seeking (such as, sport betting requires knowledge of specific sports), they argued that informed choice should not depend on consumers actively searching for game specific information. Instead, they viewed informed choice as a baseline standard of upfront transparency that must be built directly into the platform experience.

While visibility was widely accepted, debate emerged over how far gambling companies should go to ensure consumers actually understand the information. While some were happy with having information without active checks on their understanding, others advocated for a baseline of due diligence, where gambling companies verify that users comprehend their chances of winning, net profits, and risks. They felt this information should cover both immediate financial losses and long-term implications, such as impact on credit scores and mortgage applications. Rather than calling for exhaustive, bureaucratic barriers that disrupt the user experience, the consumers viewed these comprehension checks as a light-touch exercise.

This tension between personal autonomy and structural protection became particularly evident during discussions on platform architecture. When considering whether gambling companies should be restricted from utilising interface designs that distract from key risk disclosures, participants' views were dependent on who they were imagining as the end user. Reflecting on their own habits, several felt such restrictions were unnecessary, confident that they were already well informed and fully aware of the stakes. However, this perspective shifted when participants considered the experiences of more vulnerable players or those at higher risk of harm. For these groups, participants felt that particular vulnerabilities, combined with immersive designs, could overwrite an individual's autonomy in the moment. They expressed a distinct need for proactive interventions that interrupt design distractions and refocus the user's attention on key safety information. It would then be up to consumers whether they wanted to act on those prompts or not. It was further suggested that this protection should be personalised, requiring gambling companies to monitor and intervene when an individual's behavioural patterns show sudden changes indicative of escalating harm.

A need for accounting for the online platform architecture when assessing customers’ ability to make informed choices was also visible in other sectors. Whittle (2023) agreed that true informed choice requires "informative design": actively designing choice architecture to promote understanding, rather than treating a neutral environment as sufficient⁶. The Competition and Markets Authority (CMA) (2022) taxonomy of online choice architecture provides a comprehensive catalogue of the practices that undermine autonomous decision-making⁷. The Online Safety Act (2023) introduces statutory duties requiring platforms to conduct risk assessments, provide user empowerment features, and maintain transparent terms of service.

While the discussion focused primarily on the split between consumer and operator responsibility, some participants emphasised the wider role of the regulator and other stakeholders. The boundaries of this regulatory oversight remained a point of debate. One participant argued that so long as an operator is fully regulated and compliant with the law, it should retain the operational freedom to design its platform as it sees fit, provided essential information remains visibly accessible. Another argued that focusing on specific design bans misses the broader issue of corporate accountability: gambling companies should not need explicit prohibitions but should naturally embed a robust responsibility to reduce consumer harm into their business models, proactively looking after their customers from the start.

Other participants were sceptical of gambling companies’ motivations, acknowledging that they may prioritise commercial gains over consumer welfare. One participant doubted that companies could be trusted to self-regulate and suggested that the government or external authorities must impose mandatory safeguards, similar to those in the tobacco industry. Furthermore, given that consumers can use multiple gambling platforms, some highlighted that stakeholders who have the overarching view of a person's total expenditure, whether banks or a new body, could also intervene and provide information that individual operators lack.

Overall, the responsibility was split between consumers, gambling companies, regulators, and the wider industry. At a minimum, consumers thought gambling companies should do more to actively make people aware of key information about both potential wins, risks and consequences. It was also widely agreed that gambling companies should take more responsibility to offer consumer protection and offer personalised interventions when consumers show a risk of harm. This balance was not held evenly across the gambling journey: participants were more comfortable taking personal responsibility before they began playing, but looked increasingly to gambling companies, and in some cases to banks or a central body, as play became more immersive and as they considered their longer-term spend. This shift is explored in the sections that follow.

These findings are aligned with findings from other sectors (that is, across financial services, energy, and online safety), where the common direction of travel is away from a model where responsibility sits primarily with the consumer and towards one where providers must demonstrate that their environments actively support, rather than undermine, informed decisions.

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⁴ Parke, A., Harris, A., Parke, J., Rigbye, J. and Blaszczynski, A. (2014). Facilitating awareness and informed choice in gambling. Journal of Gambling Business and Economics.

⁵ Financial Conduct Authority (2022). A new consumer duty: feedback to CP21/36 and final rules. Policy Statement PS22/9.

⁶ Whittle, R. (2023). The consumer duty: behavioural context and practical strategies to support informed decision making.

⁷ Competition and Markets Authority (2022). Online choice architecture: how digital design can harm competition and consumers. Discussion paper.

⁸ Online Safety Act 2023. UK Parliament.

Informed choice across the different stages of the Path to Play

Views on informed choice when deciding to gamble

'The Gambling Commission’s Path to Play framework describes 6 stages of the consumer gambling journey: passive influences, external triggers, internal impulses, active search, play experience, and play outcome. This provides a shared structure for connecting the findings to specific points in the consumer journey where informed choice is most relevant, and where interventions might be most effective.

This section examines how participants made decisions about staying informed when choosing whether to gamble, and how they subsequently navigated platforms to select specific games or bets. It examines how passive influences, such as early attitudes about gambling, are formed, and how external triggers (that is, contextual nudges to gamble) and internal influences (that is, motivation to gamble) interact to influence informed decision-making. It also examines what participants need and currently see during active search to help or hinder them from making informed choices.

What it means to be informed before gambling

Informed choice in gambling starts before individuals decide to gamble for the first time. Aligned with the Path to Play framework, participants mentioned that their knowledge of gambling was shaped by external influences, such as early exposure to family gambling, discussions with peers at the pub, media or advertisements they encountered. The degree to which these prior experiences equipped them with sufficient knowledge to make informed decisions varied. Some had learned how a number of gambling products (for example, sports betting or a particular casino game) worked, and considered themselves informed. Others noticed that the external environment offered a skewed perspective on gambling and desired more education about gambling risks and a wider recognition that any money placed as a bet could be lost. For example, some noticed that promotions and adverts, whether online, in media or on gambling platforms, placed more emphasis on what people could win through gambling and success stories rather than the risks of the activity and how to stay safe. Through conversations with other participants, others noticed that there may be key information about gambling, such as its potential impact on credit scores or the existence of safer gambling tools, which they were not aware of, but considered important for making informed choices.

Once consumers chose to gamble, certain key pieces of information were identified as needed for informed choice, regardless of what gambling activity they engaged in. Participants first wanted to understand the trustworthiness and reputation of the gambling operator to ensure that they are gambling on a legal and safe platform. Once on a platform, they were primarily interested in understanding their potential wins and losses, game chances, game terms and conditions, and the risk associated with games. However, given the inherent complexity of gambling products, different types of players required specific additional information to remain informed based on their chosen activity: some sports bettors valued their own research and the consistent display of odds, while those playing casino-like games relied more on the information provided on the platform and needed more accessible support to help them understand the games.

A strongly valued piece of information was clear visibility over how much consumers could win, what the odds or payouts were, and how much they could lose. This suggests that gambling companies making the financial implications of gambling known and clearly visible is key to informed choice. Additional important information included immediate data tracking how much consumers had lost that day, the rules required to win, and clear parameters surrounding minimum deposits and withdrawal restrictions. This was particularly relevant as promotional offers sometimes featured hidden complexities or terms: one participant highlighted that it was sometimes unclear how much an individual was required to gamble before withdrawing funds⁹.

A consumer who accepts a bonus without understanding the wagering requirements may end up spending significantly more than they intended, simply because the terms were not presented clearly enough to support a genuinely informed decision.

Beyond immediate transactional details and game terms, ensuring an informed choice also required accessible information regarding the actual risks or consequences of gambling. This included which specific products could lead to more harm. While some participants believed that these risks may be common knowledge, operating on the assumption that individuals understand gambling involves potential financial loss, others expressed a desire for this information to be explicitly integrated into gambling platforms. This was particularly relevant when important safety alerts, such as pop-ups declaring the risks of gambling or explicitly stating that an individual could lose their entire stake, were absent or difficult to encounter at this preliminary stage.

The additional information needed to make informed decisions differed based on what games consumers were engaging with. Sport bettors represented a distinct cohort who used their own research, performing external internet searches to compare odds across different gambling companies to ensure they got the best price for their bet. This group valued the consistency with which odds were presented on platforms and considered it part of their accountability to look for the best odds and make informed choices. Still, we noticed two types of sports bettors: some felt well-informed and found it fun to hunt down the best odds at events, others struggled to interpret odds, found them too complex, and relied on friends for translation or ignored odds altogether when playing purely for fun.

Two further distinct cohorts were those playing slot and other casino-like games on a regular basis and those trying these games for the first time. The players who were trying new types of games relied more on operator information and desired more support to ensure they understood their decisions. These participants sometimes felt they were "going in blind" without knowing the true chance of winning or how to play the games. One participant described entering a game mid-session and losing money for 10 minutes because they did not understand the mechanics. Some had never heard of the Return to Player (RTP) metric, understood the term, or knew how to assess the odds in different games. This is aligned with previous experimental studies about the comprehension of gambling odds (opens in new tab) (PDF)¹¹ which demonstrated that how statistical information is presented matters, and that common formats, such as RTP, are not well understood and could actually backfire by increasing consumers' perceived chances of winning. Consequently, these users preferred simplified explanations of terms and game mechanics before playing, so that they did not lose money before feeling informed. In contrast, experienced players had learned how to play games over the years, and they relied on their prior knowledge and own research to play common types of games, such as roulette. During the active search, they would simply choose the games they were already informed about.

Barriers and facilitators to making informed decisions when deciding what games to play

Several structural barriers and operational facilitators influenced how consumers processed information when deciding what games to play, including: busy platforms, information overemphasising big wins and animated language over key information about wins, rules, losses and chances, lack of clear instructions on physical gaming machines, and hard-to-find or absent safety information.

A primary barrier was the volume and salience of platform content, which actively distracted users when they were looking for key information. Participants reported that website user interfaces were cluttered and overwhelming, featuring bright lights, cartoons, and pop-up advertisements with enticing offers that contributed to a perceived information overload. This environment led users to ignore safety information entirely. As one participant explained:

To facilitate better decision-making, participants suggested that online gambling companies could simplify website interfaces by reducing visual noise and improving the clarity of information on the site. This would lessen a consumer's susceptibility to flashy promotions and help them make more carefully considered choices. Other research goes a step further, and recommends that risk information and complex terms should be delivered separately from promotional content rather than competing for attention within the same visual frame (Parke et al., 2014)¹².

Another barrier involved the tendency of game descriptions to focus disproportionately on potential wins rather than key information. When reading game descriptions, participants noted that the text focused heavily on wins or animated language rather than conveying the objective details they were actually interested in. Participants were interested in a number of issues such as the risk of addiction, the minimum stake, how much could be won over what time, and the likelihood of being a winner. For example, when playing online slots or casino products, users sought precise clarity regarding: “how each combination works, the probability of them coming up, the minimum bets, how much you can win over how much time.”

Some participants indicated that gambling companies could counteract a lack of useful game information and facilitate informed choice by utilising the registration page to provide useful information. Doing so would allow consumers to go "pre-armed" onto a platform with sufficient knowledge. This could include integrating due diligence questions upon sign-up and before entering games, harsher warnings informing people that all of their capital is at risk before placing a bet, and a frequently asked questions (FAQs) table before placing a bet to explain the terms in simple language. Additionally, ensuring that relevant betting and safety information, such as help links, remained accessible at all times, with the option to hide them, was raised as a valuable mechanism.

Accessibility and game complexity stood out as further interconnected barriers to informed choice. While some core parameters, such as deposit or time limits, have been made more accessible in recent updates (for example, being placed one click from home and deposit pages), participants still reported difficulty locating them in practice¹³. When safer gambling information lacks the visual prominence of surrounding content, or sits alongside high-stimulus promotions, it risks being overlooked. This was compounded by a broader deficit in comprehension regarding structural metrics like RTP; many participants were either entirely unaware of the concept or did not understand what it meant for their financial returns.

In physical venues, accessibility challenges manifested differently but remained distinct. Participants noted that there was a false assumption that when someone walked into a casino, they knew what they were doing. Physical gaming machines lacked explicit instructions, and venue staff did not proactively explain game operations. The sheer complexity of certain game designs and fruit machine mechanics frequently resulted in unexpected financial losses, with one participant stating:

Beyond accessibility, the lack of transparency in online environments also eroded trust in gambling companies more broadly. Some expressed scepticism that they were competing against an algorithm designed to hook a player early in a gambling session and then exploit them, a sentiment captured by one user:

This distrust was exacerbated by experiences where accounts were blocked following complaints about large losses. One participant said they lost money on a slot game without hitting a single game feature.

To resolve these barriers, participants identified several facilitators. For complex digital games, there was strong support for free-play or demo modes, enabling users to understand game mechanics safely before wagering real money. While these already exist in places, participants who proposed this did so as a new idea, suggesting low awareness of tools already available. Participants also suggested that gambling companies could integrate interactive AI chatbots capable of explaining technical jargon and extracting obscure information buried within dense terms and conditions, acting as an on-demand guide so that players are not gambling "blindly." More broadly, consumers wanted clearer and more simplified information for bets they were going to place and promotions they intended to use, clearer guidance on where to find safer gambling information, and a clear indication of the risk of addiction associated with each type of game.

On odds and RTP specifically, participants desired simplified displays, preferring a clear percentage chance of winning or intuitive visual representations presented prior to gambling. This was a particularly significant concern for online slots players, who described feeling as though they were going in blind. There was an accompanying call to humanise the display of chances by sharing stories of both winners and losers on the site to reframe the real-life implications of the activity.

Within physical gambling environments, one participant suggested that informed choice could be facilitated by making a brief check-in part of the standard experience for first-time visitors. For example, when a customer first enters a casino and shows their ID, staff could ask a few straightforward questions, such as 'have you bet before?', to gauge their experience level and offer explanations where helpful, rather than as a condition of play. More broadly, participants agreed that staff should be available to explain game mechanics when customers appear confused, struggling or looking for help.

The report continues in the next section.

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⁹ The participant refers to wagering requirements, which require customers to wager a specified amount on the game(s) set out in a promotion’s terms and conditions before winnings can be withdrawn. In January 2026, the Gambling Commission introduced a 10x cap on wagering requirements. As the participant did not specify the level of wagering requirement they were referring to, it is not possible to determine whether their concerns relate to the current capped requirement or to previous practices.

¹⁰ Identifiers for participants are given as gender, age, most frequent form of gambling.

¹¹ Weiss-Cohen, L., Palmer, M., Torrance, J. and Newall, P. (2025). Never tell me the odds: typical return-to-player information increases gamblers' perceived chances of winning. Addictive Behaviors, 168:108363.

¹² Parke, A., Harris, A., Parke, J., Rigbye, J. and Blaszczynski, A. (2014). Facilitating awareness and informed choice in gambling. Journal of Gambling Business and Economics.

¹³ Following the Gambling Commission's Autumn 2023 consultation on the LCCP and Remote Technical Standards (response published February 2025), from 31 October 2025 all gambling businesses must prompt customers to set a financial limit before their first deposit, make limits easy to review and alter at any time (including via visible links on home and deposit pages), and remind customers at least every six months to review their account and transaction information. A further change clarifying that a 'deposit limit' must be a gross limit takes effect from 30 September 2026.

Views on informed choice while gambling

This stage refers to how consumers stay informed while they are gambling. It relates to the play experience and play outcome parts of the Path to Play framework. The play experience covers both the experience of creating a bet as well as the session of play when multiple bets or games are played, or the time spent in physical gambling venues. The play outcomes relate to both how participants engage with their results once a game ends or a bet is settled, but also how consumers stay informed of their play in the long term.

Type of information needed to stay informed

To stay informed during active gameplay, participants highlighted the need for real-time financial tracking and proactive safety interventions, such as pre-wager comprehension checks or in-game active guidance on game instructions and time spent.

A key theme across the research was the desire for consumers to be clearly and consistently informed of their true financial spend. While some participants noted that basic spend data is visible upon logging into certain platforms, or that they actively use existing features like monthly Profit and Loss (P&L) statements, others found this information difficult to locate. To facilitate genuine informed choice, participants emphasised the value of P&L tools that actively calculate total losses against winnings directly on-screen, providing a transparent, real-time reflection of net spend alongside a centrally displayed live balance.

Beyond live, in-game tracking, participants expressed a demand for structured, periodic financial summaries. The preferred frequency of these summaries varied: some favoured receiving an end-of-session breakdown detailing exact wins and losses, while others preferred monthly overviews that aggregate total spend and cumulative losses since the account's creation. For instance, one participant reflected on reviewing a seven-year transaction history, which revealed that despite staking approximately £75,000, his net losses were minimal. For this participant, access to long-term data provided valuable contextual clarity, allowing him to see the "bigger picture," mitigate the frustration of recent losses, and feel reassured regarding the fairness of the platform. Conversely, other participants argued that these summaries should function as immediate, active interventions. They suggested that fast-paced games should feature direct "reality checks" that explicitly state, for example, the exact duration of the session alongside the precise amount spent and won within that timeframe.

While participants desired clear information regarding their previous transactions, existing research indicates that the way these are designed can further improve or not improve informed choice. Gainsbury et al. (2025) evaluated Australia's mandatory monthly activity statements and found that while 57 percent of consumers opened them at least sometimes and generally viewed them as useful, behavioural account analysis showed no significant changes in betting frequency or deposit amounts, and reading statements did not improve consumers' objective recall accuracy of their net spend¹³. In contrast, BIT’s "How do activity statements impact gambling behaviour?" (opens in new tab) found that seeing any activity statement resulted in lower amounts bet, lower average stakes and improved recall of the amount bet, with 90 percent supporting implementation. This suggests that well-designed activity statements may be necessary, but, given the complex gambling environment in which they are presented, they may not be sufficient. Given the complex and fast-paced nature of gambling games, some participants wanted comprehension checks to inform them of their true spending and behaviour before wagering. Participants who predominantly engaged in sport betting suggested that informed choice could be strengthened by introducing mandatory confirmation warnings before consumers are permitted to place high-risk or mathematically improbable wagers, such as ten-leg accumulator bets. Those playing casino games highlighted the need for explicit safeguards against changes in stake sizes. One participant recounted an instance where a game’s default stake unexpectedly shifted from 20p to £2, noting that a simple, automated friction point, such as a prompt asking, "Are you sure?", would effectively prevent accidental overspending and ensure that every wager represents a deliberate, conscious choice.

Informed choice was seen as a continuous state that requires not only upfront information, but also continuous support while playing games. When engaging with unfamiliar or complex products, such as novel slot games or live casino offerings, participants expressed a need for structural support to help them understand game mechanics during play. Suggested interventions included free practice rounds and permanent, side-screen displays that continuously explain how the game operates and how payouts are calculated.

In contrast, when playing familiar games where the core mechanics were already understood, consumers' preferences shifted away from heavy instructional text toward subtle, live environmental cues. Examples included clear, on-screen text at blackjack tables stating the dealer’s specific standing rules, which helps players easily gauge their immediate odds without disrupting the flow of play.

When playing novel games or familiar ones, participants felt that they could easily lose track of reality, sometimes for hours. To account for this, some desired prominent session timers and periodic pop-ups (for example, at the 45-minute mark) asking if they are happy to continue, functioning much like a Netflix "Are you still watching?" prompt. Rather than generic safety warnings, users prefer targeted pop-ups triggered by their actual gameplay patterns, such as interventions when a system detects rapid, heavy spending or someone aggressively chasing losses.

Barriers and facilitators to staying informed while gambling

The main barriers that interfered with participants' ability to make informed decisions while gambling stemmed from three interacting areas: gambling companies' practices (both complex website design and wider structural restrictions), consumers' own psychological states, context of play and behaviours during play, and the intersection between the operator and individual factors. To help address these barriers, participants suggested having a different approach for different types of gambling (sport betting, casino online games, in-venue games), and personalising the solutions to individual players’ behaviour.

Gambling designs and features

The design of the gambling platforms impacted participants’ ability to make informed choices in different ways, depending on the type of game they were playing. These findings are aligned with the previous literature, which document the systematic use of design features that can work against informed choice. Newall (2025) provides a taxonomy of deceptive features in online gambling, categorising them as sludge (detrimental frictions such as complex withdrawal processes, relevant at play outcome), dark patterns (deceptive UX such as high suggested default bet sizes, relevant at active search and play experience), and dark nudges (exploiting cognitive biases such as framing odds as RTP, relevant throughout)¹⁴. McGarrigle et al. (2025) found pervasive use of "sneaking" (hiding information), "obstruction" (creating friction around withdrawals and account closure), and "interface interference" (bad defaults and inaccessible language).¹⁵

Sports betting

Because sports bettors sometimes log on with a specific goal, some found the betting platforms cluttered or overwhelming. This was due to lists of smaller games and adverts, which actively distracted them from placing their intended bets. This group particularly disliked any pop-ups being displayed while actively building bets, or any prompts guiding them towards specific bets. This was because betting required attention under time pressure, as some may rush to put in bets just before games start. Any distractions at that stage were either ignored or impacted their ability to stay informed. On one hand, promotional pop-ups nudging users toward specific, high-risk outcomes, such as 40-to-1 odds on multi-goal accumulators, were thought to make them more likely to make poorly considered and impulsive decisions. On the other hand, well-intentioned safety interventions, such as notifications regarding time spent on the platform, could backfire in these high-pressure moments: rather than encouraging reflection, they could cause bettors to rush their calculations and make mistakes on their bet slips.

Instead of being interrupted while building bets, some sports bettors preferred unskippable safety checks mirroring online banking security, pointing out exactly the bets they are agreeing to do, and flagging when their bets are highly unrealistic.

Online casino games

The key barriers to staying informed while playing online casino games, such as slot games and live-streamed casino games, stemmed from their immediate play, visual design, immersive nature and fast pace.

When playing novel games, the experience could be difficult to understand when clear pre-game instructions were not provided; one participant gave the example of the live dealer "Cash or Crash" game. As mentioned in the previous section, one participant described entering this game mid-session and losing money for 10 minutes because they did not understand the mechanics. While the dealer did eventually explain the rules when asked via the chat function, participants considered this a structural flaw. The group agreed that such games should offer practice tokens or free demos so that consumers can learn how to use novel games without losing money. This was something they had observed on some poker websites, where it allowed players to learn the rules without financial risk.

Alternative ways to support consumers staying informed about game rules while playing included having game mechanisms displayed permanently on the side of the screen or having help icons that explain terms in simplified language. Some proposed that gambling companies could integrate AI chatbots capable of proactively answering questions and surfacing buried information during sessions, acting as a smart, on-demand guide that teaches players how games work so they are not gambling "blindly."

When presented with images of slot games or other similar instant-win games, participants appreciated that they offered information about time and net pay. However, some remarked that bright lights and cartoon imagery focused their attention on those visual features rather than on the play information displayed elsewhere on the screen.

Having information about the net balance in inconsistent locations made it harder for some to engage with it. One participant highlighted that she was used to looking for information about her deposit amount at the bottom of the screen. However, the net pay was sometimes displayed at the top, and it was updated after the deposit figure. She preferred to look at the bottom centre of the screen, because this was the location she normally checked. This inconsistent and asynchronous design risked consumers either ignoring one piece of information or momentarily processing two conflicting financial figures on the same screen, increasing cognitive load and creating unnecessary friction when trying to quickly assess their true spend.

Play information was also sometimes hard to take in due to the speed of the games. Immersive games absorbed participants' attention, leading to a loss of awareness of not just money but also time. Some thought sites did very little to interrupt them, with one person noting they lost three and a half hours on the sofa without a single warning. There was little awareness of safety tools that could interrupt play, such as reality checks or deposit limits.

The fast pace also created confusion about accuracy. One participant noted that multi-line micro-stakes, such as 20p bets, produced payout sums that felt wrong, but the game's speed prevented him from checking whether the amounts were correct.

To account for the immersive and fast-paced nature of such games, it was widely agreed that pop-ups or other mandatory and attention-grabbing features could be useful. Some suggested that on-screen elements could grow in size or change colour at intervals to better capture attention.

Other suggested mechanisms included Netflix-like notifications to gently check if players are still engaged without triggering stigma, and periodic reminders of time and money spent. When asked whether such pop-ups might backfire or distract from the play experience, participants largely disagreed. Some considered them an act of care from gambling companies. Others highlighted that users are already accustomed to receiving countless digital notifications, and that dismissing them would not require much effort. The prevailing view was that even if some people instantly close pop-ups, the potential benefits outweigh the minor annoyance, because they might catch the attention of someone who genuinely needs a financial reality check at that moment.

There was some dispute about how useful pop-ups would be if people grew accustomed to them. Some liked the repetitive nature of this information, thinking that repetition may help them actually remember it. Others thought they would simply learn to ignore it. Instead, they proposed targeted, unexpected interventions based on actual gameplay patterns rather than fixed intervals:

The importance of personalised information was also highlighted in the wider gambling literature. Auer and Griffiths (2016) found that personalised behavioural feedback significantly reduced expenditure among online gamblers¹⁶ , and the meta-analysis by Bjørseth et al. (2021) showed that personalised pop-ups (detailing specific behavioural data, such as reaching a preset limit had substantially larger effects than generic warnings¹⁷). Gainsbury et al. (2018) found that different consumer sub-groups responded to very different kinds of messages: young adults preferred "tips to be a better gambler," older adults preferred limit-setting prompts, and skill-game players wanted direct, personalised expenditure data¹⁸. This suggests that motivation to engage with information provided is not fixed but is shaped by whether the information feels relevant, personally useful, and respectful of the consumer's autonomy.

Land-based gambling

While engaging in land-based gambling, participants relied more on physical cues, human interaction, and the tangible nature of the environment itself, all of which could act as both barriers and facilitators to informed choice.

Some found that the simpler environment and the physical act of handing over money made the whole activity feel more grounded. One participant argued that online gambling is dangerous precisely because it strips away the natural human reactions to real-world financial loss that a physical setting preserves.

However, participants acknowledged that this sense of tangibility did not necessarily protect against harm and negative impacts to consumers. The social dynamics of a physical venue could draw people into unplanned spending. One participant described how the flow of a casino visit could escalate gradually: playing on the blackjack table and then thinking "just do another quid," until slowly they had spent £100. For some, land-based gambling at events like horse racing was experienced more as a "fun day out," where the costs of gambling were factored into the overall price of the experience, which could reduce the sense that real financial risk was involved.

A distinct challenge in physical venues was the lack of proactive information provision. Participants noted that machines often lacked explicit instructions and that venue staff did not routinely explain how games operated, reflecting a false assumption that anyone who walked into a casino already knew what they were doing. The complexity of certain fruit machine mechanics compounded this, with participants describing unexpected financial losses from games they had not fully understood.

To stay informed during play, some preferred physical staff who could read signs of distress, such as visible frustration, and intervene when appropriate. One participant compared the ideal staff role to a bartender who stops serving a drunk patron, suggesting that venue staff should be trained to spot the signs of gambling distress and actively step in. However, participants were clear that they did not want staff to be overbearing. One described not wanting staff checking in 'every two minutes.' The desired balance was attentive but unobtrusive: staff who noticed when something was wrong without making the experience feel surveilled. Previous research suggests that delivering on this balance in practice is not straightforward, given competing commercial and welfare priorities and the difficulty of accurately identifying signs of harm (Riley et al., 2018; Riley et al., 2024)¹⁹²⁰

Gambling company practices

Beyond specific game or venue design features that could impair information processing and informed choice, some participants noticed broader operator practices they believed could harm consumers, or expressed distrust regarding gambling companies' commitment to safeguarding users. Some highlighted online disputes where gambling companies refused payouts for subjective niche bets (such as "shots on target"), or arbitrarily voided large consumer winnings by claiming the game had crashed.

Casino players highlighted that games would sometimes switch from free promotional spins to using real money without clear notification, or that default stake amounts would suddenly increase without their active approval or without them noticing. This underlines the need for more visible notifications and appropriate friction points to help users understand what the real cost of their play is, and when it changes.

Sports bettors observed that platforms allowed them to place bets with "inactive" conditions, such as wagering on a player to receive a yellow card even when that player was not actually in the starting lineup. Allowing consumers to wager on unfeasible outcomes under standard odds was seen as misleading and was considered unfair. Participants framed this as a question of basic fairness: the product did not deliver what it appeared to promise. One participant suggested that if a player is not in the starting lineup, the platform either should not let the user place the bet at all or the odds should be reduced to signal the player's inactive status.

A further facilitator to aid informed choice would be to give consumers more informational context around the bets they are making. For example, a participant suggested that gambling companies could display recent football statistics directly on the site, allowing bettors to assess how fair the operator's odds for a given bet are.

Consumer variables

Participants' ability to stay informed while gambling also depended on their emotional state, personal habits, and social environment. External factors like drinking alcohol in a pub or feeling pressured by friends and time constraints before a match could easily override a careful betting strategy. Once active play began, consumers sometimes observed a loss of self-control. One participant compared building complex bets to a "runner's high," where they got caught in the excitement and impulsively kept adding more risk without feeling able to stop.

Mood was a further psychological barrier. Strong emotions like excitement or stress could limit how much safety information consumers were willing to read, sometimes driving them to gamble repeatedly just to relieve tension. The immediate results of games could also affect behaviour: losing streaks could lead to "chasing losses," while winning streaks could make players feel overly confident and cause them to ignore warnings.

These insights illustrate that vulnerability is not a fixed characteristic, and is aligned with research from other sectors. The FCA's guidance on vulnerable consumers (opens in new tab) (PDF) identifies 4 drivers of vulnerability (health, life events, resilience, and capability) and emphasises that vulnerability is fluid and situational, not a permanent label. Ofgem's work in the Consumer Vulnerability Strategy (opens in new tab) (PDF) similarly recognises that the market itself can create or exacerbate vulnerability through complex information and aggressive sales tactics. This has a direct parallel in gambling, where the immersive and emotionally charged nature of play can temporarily reduce anyone's capacity for informed decision-making, not just those with clinical gambling problems.

To account for these different states, participants proposed that informed choice interventions could happen outside of the gambling session. This could include sending messages informing players of their deposits, similar to what banks do when customers make payments. External interventions could also take the form of regular, blunt summaries detailing total P&L over a rolling period, such as a week, month, or year.

Consumers may also choose to gamble across multiple accounts, making tracking behaviour difficult and often inaccurate. To address this, some thought the government should establish a unified tracking mechanism to monitor and potentially limit the total amount an individual is gambling across all digital platforms and physical venues simultaneously. Others thought that banks, which have an overarching view of spending, could track total monthly expenditure across gambling sites and intervene if spending reaches concerning levels.

People's own cognitive biases could also prevent them from making informed decisions during games. One participant shared an example of friends playing roulette in a casino who, when a specific number came up, falsely assumed it would not appear again on the next spin. This is a well-documented cognitive distortion, the gambler's fallacy, which the desk review identified as a persistent barrier to rational decision-making (Blaszczynski et al., 2008; Monaghan and Blaszczynski, 2009)²¹²². It illustrates how, at times, people may not be equipped to make informed choices in the context of gambling, regardless of what information is provided, and how environmental cues and active interventions could act as important safeguards. For example, Cemiloglu (2023) tested "explainable persuasion," where consumers were shown short inoculation videos explaining how gambling platforms use persuasive design techniques. ²³This generated significantly more counterarguments against promotional messaging and reduced intention to claim bonuses.

The report continues in the next section.

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¹³ Gainsbury, S.M., Chandrakumar, D. and Heirene, R.M. (2025). Use and impact of government-mandated activity statements for online gambling in Australia.

¹⁴ Newall, P.W.S. (2025). Sludge, dark patterns and dark nudges: a taxonomy of online gambling platforms' deceptive design features. Addiction, 120(10), 1916–1923.

¹⁵ McGarrigle, J., Smith, J., Griffiths, J., Torrance, J., Quigley, M. and Dymond, S. (2025). Dark patterns in online gambling: A scoping review and classification of deceptive design practices. Journal of Behavioral Addictions, 2006-2025.

¹⁶ Auer, M.M. and Griffiths, M.D. (2016). Personalized behavioral feedback for online gamblers: a real world empirical study. Frontiers in Psychology, 7:1875.

¹⁷ Bjørseth, B., Simensen, J.O., Bjørnethun, A., Griffiths, M.D., Erevik, E.K., Leino, T. and Pallesen, S. (2021). The effects of responsible gambling pop-up messages on gambling behaviors and cognitions: a systematic review and meta-analysis. Frontiers in Psychiatry, 11:601800.

¹⁸ Gainsbury, S.M., Abarbanel, B.L.L., Philander, K.S. and Butler, J.V. (2018). Strategies to customize responsible gambling messages: a review and focus group study. BMC Public Health, 18(1):1381.

¹⁹ Riley, B. J., Orlowski, S., Smith, D., Baigent, M., Battersby, M., & Lawn, S. (2018). Understanding the business versus care paradox in gambling venues: A qualitative study of the perspectives from gamblers, venue staff and counsellors. Harm Reduction Journal, 15(1), 49.

²⁰ Riley, B. J., Lawn, S., Crisp, B. R., & Battersby, M. (2024). Much ado about nothing? The role of land-based gambling venue employees in facilitating problem gambling harm reduction and help-seeking. Journal of Gambling Studies, 40(1), 387-408.

²¹ Blaszczynski, A., Ladouceur, R., Nower, L. and Shaffer, H.J. (2008). Informed choice and gambling: Principles for consumer protection. The Journal of Gambling Business and Economics, 2(1), 103-118.

²² Monaghan, S.M. and Blaszczynski, A. (2009). Electronic gaming machine warning messages: Information versus self-evaluation. The Journal of Psychology, 144(1), 83-96.

²³ Cemiloglu, D. A. (2023). Explainable persuasion for persuasive interfaces: the case of online gambling (Doctoral dissertation, Bournemouth University).

Conclusions

Cross-cutting themes and next steps

A related theme concerns protections that already exist. Several of the concerns participants raised, and solutions they proposed, are already provided for in the statement of principles or have been addressed by recent rule changes: free-play modes to learn game mechanics, prompts to set deposit limits, session and spend displays, caps on wagering requirements, and signposted routes to support. That participants experienced these as absent or proposed them as new ideas is itself a finding. The gap lies less in the existence of protections than in consumers knowing where to look, choosing to engage, and understanding what these protections mean, reinforcing the disconnect described above and suggesting that awareness, positioning and comprehension of existing tools should be a priority for future work.

There is a disconnect between information being available and consumers feeling informed. At every stage of the journey, participants described situations where information existed on the platform but did not translate into a sense of being genuinely informed. The reasons varied from terms and conditions being too long and difficult to understand, to likelihood of profit or loss being displayed in formats that were hard to interpret, to net spend appearing in inconsistent locations, or safer gambling tools taking too much effort to find. Participants' experience of informed choice depended less on whether information had been provided and more on whether they could find it, understand it, and use it at the point where it mattered. This distinction between provision and comprehension is one that broader financial sectors have increasingly built into their statement of principles. For example, the Financial Conduct Authority's (FCA) Consumer Duty (opens in new tab) requires firms to demonstrate that customers understand what they are being told, rather than simply that the information was made available. This research suggests that for many gambling consumers, this requirement is not always met.

Participants' accounts suggest practices that undermine good and fair outcomes. Consumers who cannot interpret wagering requirements, who wager on outcomes that turn out to be unfeasible, who cannot verify a payout, or whose stakes change without clear notification may end up worse off simply because the information available to them did not support a good decision. Ensuring that consumers can make genuinely informed choices therefore supports the Gambling Commission's broader 'fair and open' licensing objective alongside its work on harm prevention.

In relation to responsibility, participants favoured a shared model in which consumers, gambling companies, and regulators each play a role. But this general position was not evenly held across the Path to Play. Before gambling, participants were more comfortable with personal responsibility, provided information was visible and accessible. During play, particularly in fast-paced or immersive contexts, they were more open to the idea that gambling companies should intervene on their behalf, whether through pop-ups, comprehension checks, or personalised alerts. Post-play outcome, some looked beyond the operator entirely, suggesting that banks or a central tracking body might be better placed to provide oversight of total gambling spend. This variation suggests that the question of where responsibility should sit does not have a single answer. It depends on the stage of the journey, the type of product, and the consumer's capacity in the moment.

Participants consistently distinguished between information or interventions that felt relevant to them and those that felt generic. Generic messaging was frequently described as easy to ignore, and in some cases actively counterproductive. By contrast, participants engaged more readily with information tied to their own behaviour: their spending data, prompts triggered by changes in their play patterns, or confirmations specific to the bet they were about to place. This is consistent with the experimental literature reviewed in the desk review, which found larger effects from personalised interventions than from generic ones. At the same time, the qualitative work surfaced a tension that the experimental literature does not fully address. Participants wanted gambling companies to use behavioural data to support them, but some simultaneously expressed distrust of gambling companies' motives for collecting that data. The same tracking capability that enables a helpful intervention also enables targeted marketing. How this tension is navigated has implications for any framework that relies on personalised information provision.

There is variation across product types. Sport bettors, casino game players, and land-based gamblers described quite different relationships with information throughout the journey. Sport bettors arrived with a specific goal and experienced interruptions as a hindrance; their needs centred on accuracy, feasibility, and post-bet confirmation. Casino game players faced a wider and less familiar range of products and needed accessible explanations, consistent displays, and active interventions during immersive play. Land-based players operated in an environment where formal information provision was largely absent and the social and physical dynamics of the venue shaped the experience in ways without a direct online equivalent. These differences were apparent not just in what information participants wanted but in when and how they wanted to receive it, and in how they responded to the same types of intervention.

Moving forward, we recommend that the Commission uses these findings in order to conduct a behavioural mapping exercise and translate the concept of informed choice into observable and measurable indicators. To facilitate this exercise, BIT had designed a conceptual framework, outlining practical steps the Commission can take to conduct the exercise, including: mapping the outcomes that would indicate informed choice is being achieved; for each outcome, identifying the specific behaviours that must occur for the outcome to be achieved; noting who contributes to enabling each behaviour; mapping all the potential identified facilitators (and barriers) that could impact the desired behaviour; and evaluating these facilitators according to their impact, feasibility and measurability. All these can be done while identifying metrics or indicators to evaluate the targeted behaviour and test the effectiveness of the facilitators in influencing that behaviour.

Appendices

Appendix A: Sample Characteristics

Sample characteristics of participants in the deliberative focus groups

Main gambling location

Main gambling location

Main gambling location	Number of participants
Online	8
Land-based	6
A mix of online and land-based	4

Gambling frequency

Gambling frequency

Gambling frequency	Number of participants
At least once a week	7
At least once a month	9
Less than once a month	2

Age

Age

Age	Number of participants
18 to 25 years old	3
26 to 35 years old	4
36 to 45 years old	4
46 to 55 years old	3
56 to 65 years old	3
66 years old and older	1

PGSI Score

PGSI Score

PGSI Score	Number of participants
0	3
1	3
2	4
3	1
4	1
5	2
6	3
7	1

Gender

Gender

Gender	Number of participants
Male	10
Female	8

Income

Income

Income	Number of participants
Less than £25,000	4
£25,001 to £35,000	7
£35,001 to £50,000	1
£50,001 to £75,000	4
£75,001 to £90,000	0
Over £90,000	2

Ethnicity

Ethnicity

Ethnicity	Number of participants
Asian	2
Black British	1
Black Caribbean	1
British Indian	1
Mixed race	1
White	2
White British	8
White Other	1
White Welsh	1

Location

Location

Location	Number of participants
London	4
Wales	2
Leeds	2
Manchester	2
Bristol	1
Crawley	1
Kent	1
Lancaster	1
Lincoln	1
Swindon	1
St Ives	1
West Sussex	1

Sample characteristics of participants in the one-on-one interviews

Main gambling location

Main gambling location

Main gambling location	Number of participants
Online	1
Land-based	0
A mix of online and land-based	3

Gambling frequency

Gambling frequency

Gambling frequency	Number of participants
At least once a week	1
At least once a month	1
Less than once a month	2

Age

Age

Age	Number of participants
18 to 25 years old	1
26 to 35 years old	1
36 to 45 years old	2

PGSI Score

PGSI Score

PGSI Score	Number of participants
8	3
14	1

Gender

Gender

Gender	Number of participants
Male	3
Female	1

Income

Income

Income	Number of participants
£25,001 to £35,000	1
£35,001 to £50,000	2
£50,001 to £75,000	1

Ethnicity

Ethnicity

Ethnicity	Number of participants
Asian	1
White British	1
White Other	1
White Scottish	1

Location

Location

Location	Number of participants
Burnley	1
Glasgow	1
Leicester	2
London	1

Appendix B - Glossary of terms

Bonus - A promotion by gambling companies where players receive a reward upon sign-up or as part of a promotion. This may include monetary rewards, enhanced odds, or increased payouts if a bet is successful.

Gambling - The act of betting money or wagering something valuable on an unknown outcome with the knowledge of risk and hope of gain. Some examples:

Sports betting - Betting on the outcomes of sporting events, such as the winner of a horse race or the first goal scorer in a football match.

Slots games - Inserting money into a digital or physical machine to bet that it will show special symbols that trigger a jackpot.

Casino games Playing games of chance typically found in casinos, such as betting that the ball on a roulette table will land on a certain number.

Gambling operator - A company or entity that provides and manages gambling services and activities, such as casinos, online gaming sites, and betting shops.

Multi-leg accumulators - A feature on sports betting platforms that allows users to combine multiple selections into the same bet.

Odds - A number expressing how much people who bet on a certain event can win if that event happens. For example, if 5/1 odds are offered for a team winning a football match, those correctly betting on the winning team get back five times the amount they bet.

Return to player - a metric used to display the expected percentage of wagers that a specific game will return to the player in the long run.

Wagering requirements - a multiplier that represents the number of times a player has to play through a bonus before they can withdraw any winnings.