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Prohibition of gambling on credit cards

This report focuses on research conducted around the prohibition of gambling on credit cards

Published: 2 November 2021

Last updated: 2 November 2021

This version was printed or saved on: 16 May 2022

Online version: https://www.gamblingcommission.gov.uk/report/prohibition-of-gambling-on-credit-cards

Executive summary

On reflection of the evidence presented in this report, we are:

PhaseAssumption/ OutcomeEvidence
ImplementationOperators implement the ban effectively and on-timeWe have found no evidence of systemic breaches of the ban by operators

Bank data shows credit card payments to gambling merchant code reduced as expected
ImplementationFinancial institutions block credit card payments made via their digital walletsThe major e-wallet and electronic money providers (accounting for the vast majority of third-party transactions) have given assurances that wallet transactions are blocked for gambling if originating from credit cards, though some minor breaches occurred and have been rectified.
ImplementationGamblers don't make a large credit card deposit prior to ban introductionBank data shows no observed spike for credit card gamblers in ATM withdrawals from credit cards around the time of the ban
Financial behaviour (Initial) Gamblers aren't displaced to other high-cost credit sources, such as payday loansTracker data shows that the proportion reporting gambling with other forms of borrowed money has remained stable, with consumer voice qualitative research suggesting that Covid-19 has had the bigger impact on financial behaviours.
Financial behaviour (Initial)Gamblers aren't displaced to illegal sources of funds, such as loan sharks, theft or fraudThe Illegal Money Lending Team have not seen an increase in reports related specifically to gambling and the credit card ban
Financial behaviour (Initial)Gamblers don't bypass the ban through credit card cash withdrawals, layering funds through wallets or using pay-later phone billing methodsTracker data shows a greater proportion have stopped using credit to gamble than have been displaced to other sources.

The consumer voice work has identified high awareness of workarounds to the ban, and some respondents who have utilised these workarounds.

Bank data shows no observed spike for credit card gamblers in money transfers in the three months after the ban.
Gambling behaviour (Initial)Gamblers aren't displaced to unlicensed gambling sites or black-market sourcesWe have not had reports of displacement to unlicensed gambling as a result of the credit card ban.

The consumer voice research did not identify anybody seeking or gambling on unlicensed websites.
Gambling behaviour (Initial)The inconvenience to leisure gamblers is minimisedConsumer voice research showed awareness of the ban is relatively low and those that have amended behaviours do not feel inconvenienced. In general, there was support for the ban.

Tracker survey quotes are positive: the ban helps to retain control and stay within means.

Background and approach

Background

  1. 2018 to 2019

    ABSG advice on gambling with borrowed funds.

    Call for evidence (February 2019 to May 2019) receives 110 responses.

  2. 2020

    January: Ban on gambling with credit cards announced.

    April: Ban on gambling with credit cards starts.

  3. 2021

    We monitor the ban impacts since introduction.

    GREO appoint NatCen to conduct a full evaluation.

Aims

The main aim of the prohibition on gambling with credit cards was to prevent those experiencing gambling-related harms from using credit cards as a convenient means of using money they do not possess to facilitate high-levels of gambling debt. It was intended to introduce friction to the process of gambling with borrowed money.

However, it was recognised from the outset that not all gambling with credit cards is prohibited and that some methods of credit card use are permitted. This emphasised the importance of an evaluation to understand how gamblers are funding their activity and identify changing player behaviours, including potentially harmful changes.

The Commission was also mindful of potential unintended consequences of any action taken on the use of credit cards, including displacement to other forms of borrowing.

The consultation document, summary of responses to the call for evidence and final consultation response are available at the following links:

Evaluation Activity

The evalution consists of four distinct phases:

  1. Stage 1

    Greo produced a Rapid Evidence Review into the Role of Credit Cards and Gambling (PDF opens in a new tab) in March 2020 that examined empirical evidence into the use of credit cards for gambling.

  2. Stage 2

    A Theory of Change (ToC) is a description of how and why a particular action is expected to result in a desired change. One of the strengths of the process is that it allows the identification of metrics (represented as outcomes and assumptions) which should be monitored to provide an indication of whether or not the intended aims are being met.

    Details of the ToC contributing organisations can be found within the appendices.

  3. Stage 3

    This report provides an overview of the ‘monitoring phase’ of the evaluation. It became clear that a full evaluation in April 2020 could not capture the full impact of the ban and an evaluation at a later time would be more suitable and more comprehensive. As explored later, the Covid-19 lockdown resulted in many changes to financial situations and gambling behaviour – this would have made it very difficult to determine whether any observed changes were due to Covid-19 or the credit card ban.

  4. Stage 4

    At the end of May 2021, following a competitive tender process, Greo appointed NatCen Social Research to conduct a full evaluation of the credit card ban in Great Britain.

    Greo received a regulatory settlement in June 2019 to create a programme of work to support the National Strategy to Reduce Gambling Harms. As part of that work, they have worked to strengthen evaluation of safer gambling initiatives (opens in a new tab)

    NatCen will assess the progress that has been made towards achieving the intended outcomes of the ban, whether the ban was implemented as intended, any unexpected positive or negative impacts, and opportunities to modify it in the future. We will use these findings, along with our continued monitoring, to inform future policy development.

    The evaluation will seek to address a number of process and impact outcomes that have resulted from the credit card ban on gambling through a mixed methods approach including primary and secondary data analysis and interviews with gamblers, affected others and stakeholders.

    The evaluation is scheduled for completion in early 2023.

Theory of Change: Monitoring Phase

The ban on gambling with credit cards was announced on 14 January 2020 and introduced on 14 April 2020.

The initial steps to lead to a successful implementation of the credit card gambling ban are that ‘operators implement the ban effectively and on time’ and ‘financial institutions block credit card payments via digital wallets’.

Following a successful implementation, it was recognized that at the early stage, it was necessary to identify ‘whether gamblers had made a large credit card deposit prior to the introduction of the ban’.

Financial outcomes and assumptions were identified as ‘gamblers aren’t displaced to other high-cost credit sources, such as payday loans’, ‘gamblers aren’t displaced to illegal sources of funds, such as loan sharks, theft or fraud’, and ‘gamblers don’t bypass the ban through credit card cash withdrawals, layering funds through wallets or using pay-later phone billing methods’.

Gambling outcomes and assumptions are ‘The inconvenience to leisure gamblers is minimised’ and ‘gamblers aren’t displaced to unlicensed gambling sites or black market sources’.

Theory of Change: Future Evaluation Activity

Future evaluation activities will continue to monitor financial and gambling outcomes.

For financial outcomes, ‘There is a reduction in credit and other forms of borrowed monies used by ‘debt-risk’ gamblers’, ‘There is a reduction in gambling-related debt resulting in bankruptcy’ and ‘There is a reduction in gambling-related credit card/financial fraud’. These lead to a goal of ‘A reduction in financial-harm consequences for the gambler and affected others as a result of debt incurrences.’

The gambling outcomes of ‘increased friction results in a ‘pause’ in gambling, greater self-reflection and changed gambling patterns’ and ‘increased friction reduces relapses amongst those recovering from GRH’ lead to a goal of ‘There is a reduction in gambling-related harms resulting from gambling with borrowed money’.

The gambling outcomes of ‘The ban adds impetus to the practice and perceptions of Safer Gambling (SG) support by operators’ and ‘Increased awareness of credit-related gambling harms results in more responsible play and an increased uptake of SG tools/self-exclusion’ to lead to a goal of ‘new gamblers benefit from normalized non-credit, ‘safer’ payment behaviours and industry commitments to safer gambling’.

Methodology and limitations

Methodology for key sources

Many of the findings detailed in this report are based on two sources, our Online Tracker survey and the Commission’s Consumer Voice research. The core details of each approach are detailed as follows.

Online Tracker methodology

A list of questions for each wave can be found in the appendices.

Consumer Voice methodology

Limitations of the ban and evaluation

Limitations of the ban

There are a number of exceptions to the ban that are worth consideration, including:

The ban does not prevent absolutely all gambling with credit cards – with the main exception being the purchase of lottery tickets at a grocery store, which will not be captured as a gambling transaction due to the non-gambling Merchant Category Code of the retailer. This was recognised at the time that the ban was introduced, with the decision to exclude this activity based on proportionality and risk of harm.

The ban introduces high levels of friction into the use of credit cards to fund gambling, and prohibits their use wherever feasible and proportionate to do so. However, the Commission cannot extend the ban to scenarios such as using a credit card to withdraw cash from an ATM and then using that cash for gambling, as neither an operator nor financial body can have visibility of that trail of funds. Therefore, reports of indirectly accessing credit card funds may be accurate, but that does not mean that the implementation of the ban was unsuccessful.

Limitations of the evaluation

There are a number of limitations of the information sources that are worth consideration.

The online tracker information asks respondents to report behaviours and gambling activities, but the questions which are listed in the appendices, do not have the level of granularity to understand whether the reported use of credit cards are for permitted activities, such as the purchase of lottery tickets in grocery stores, or prohibited activities.

The online tracker information is reported behaviour which is subject to recall inaccuracies. Inaccuracies are increasingly likely when respondents are asked to think about a prolonged period (12 months), but we have also seen that respondents confuse their own debit/credit card behaviour.

The Consumer Voice qualitative research is based on a limited sample size, with 29 full respondents and, as noted, the sample of respondents comprises a larger number at the higher-end of the Problem Gambling Severity Index (PGSI).

People breaching the regulation are likely to be satisfied that they have done so. Even if they are aware of the prohibition on gambling with credit cards, they are unlikely to report the breach to the regulator.

The impact of Covid-19

The introduction of the ban on gambling with credit cards (14 April 2020) occurred at a very similar time to the first national lockdown measures in Great Britain (legally introduced on 26 March 2020).

The Covid-19 lockdown periods have had a significant impact on gambling behaviour and people’s financial circumstances. For the impact on gambling behaviour, see our Covid-19 datasets.

Due to the multiple, changing lockdown measures that have been in place since March 2020, it has been very difficult to attribute changes in financial or gambling behaviours to the credit card ban, rather than the changing environmental factors.

In the Consumer Voice research, there was a blend of respondents who had not changed their gambling behaviour, and those who reported an increase in the time spent gambling, particularly younger respondents who reported greater boredom during lockdown and felt they could spend more money gambling as they were not spending money on other (temporarily unavailable) activities. It remains to be seen whether these new behaviours continue now that Great Britain has removed its lockdown restrictions for now.

The lockdown restrictions not only prevented the availability of land-based gambling opportunities, but also reduced the likelihood of other activities, such as meeting loan sharks.

Operator Implementation and customer behaviour

Metric
Operators implement the ban effectively and on-time
Concern
If operators did not implement the ban, it would be an outright failure
Assessment
We are confident that gambling operators introduced the ban in a timely and effective way

Two principle data sources that have been considered for whether the ban has been effectively implemented are as follows:

  1. Bank data: A major high street bank has informed us that they observed the volume and value of gambling transactions with credit cards to the gambling merchant code, MCC7995, reduce to a very low level after the ban.

The continuing low-level expenditure can be explained by activities outside the scope of the ban (predominantly lotteries and competitions spending).

  1. Our information: We have not detected any operator breaches during compliance assessments and have not received any alerts to systemic breaches of the gambling with credit card prohibition.

Credit cards and digital wallets

Metric
Financial institutions block credit card payments via their digital wallets
Concern
Allowing e-wallets to be loaded with credit cards and then used for gambling would reduce the intended level of friction that the credit card gambling ban was intended to introduce
Assessment
We are satisfied that digital wallets loaded with credit cards cannot be used for gambling

The vast majority of remote gambling deposits are made by debit cards, but it was recognised that it would represent a barrier to the ban on gambling with a credit card if credit card payments could be made to e-wallets that could then be used for gambling.

Major e-wallet and e-money providers - including PayPal, Skrill, Netteller and Revolut – have offered assurances to gambling companies that customers cannot transfer funds from their e-wallets and accounts to gambling operators if those funds have been loaded from a credit card; some smaller challenger wallets have offered the same assurances.

These operators account for the vast majority of wallet transactions, although some other smaller wallets may not be set-up in the same manner.

There were a small number of occasions shortly after the ban was introduced where transactions from an e-wallet to a gambling account were permitted and where a credit card had been used with that wallet provider. These occurred due to errors in the merchant coding of some gambling companies and were quickly resolved.

Deposits prior to the introduction of the ban

Metric
Gamblers don’t make a large credit card deposit prior to the ban’s introduction
Concern
In the build-up to the ban’s introduction, gamblers could have made large deposits to their accounts using credit cards which would have reduced the early efficacy of the ban
Assessment
We have found no evidence to suggest that large credit card deposits were made prior to the ban’s introduction

A major high street bank has informed us that, amongst those that used a credit card to gamble, there was no identifiable shift in spend behaviour towards ATM withdrawals or money transfers in the build-up to, or subsequent to, the implementation of the credit card gambling ban.

A significant decrease in ATM use was observed during March 2020, which is very likely to have been a consequence of the spread of Covid-19 during that time.

Displacement to other high-cost credit sources​

Metric
Gamblers aren’t displaced to other high-cost credit sources, such as payday loans
Concern
Gambling with borrowed money through the use of credit cards was associated with harms, but displacement to higher-cost sources of credit is likely to be even more harmful
Assessment
The use of non-credit card sources of credit for gambling has remained stable.

The reported rate of gambling with other forms of borrowed money in our Online Tracker survey has remained broadly stable over the period observed since the prohibition on gambling with credit cards was introduced.

The graph shows the quarterly reported rate for the use of overdrafts, payday loans, other loans, utilising mobile phone accounts for making payments or borrowing from family and friends to fund gambling activity.

Figure 1. Proportion of past 12 month gamblers that had gambled with other forms of borrowed money in the last 12 months Proportion of past 12 month gamblers that had gambled with other forms of borrowed money in the last 12 months - a line chart that shows the categories of borrowing to gamble. The vertical axis is the percentage of people who gambled, the horizontal are the months starting with December 2018. There are two boxes above the lines on the graphs. The first box states "April 2020 Ban on gambling with credit cards enforced" and has a solid line pointing to the approximate place April would fall. The second box states "Note: Added granularity to time periods in question phrasing may have increased recall of participation and therefore increased % figures in the September 2020 wave". It has two broken lines pointing to the either side of where September 2020 is on the axis.

Proportion of past 12 month gamblers that had gambled with other forms of borrowed money in the last 12 months
Overdraft facilityPayday loansOther loansFamily and friendsMobile phone accountBase size
December 20184%2%1%2%1645
March 20194%2%1%2%1587
September 20195%2%1%3%1551
December 20194%2%1%3%1534
March 20203%2%1%3%1565
June 20203%1%1%3%1%1473
September 20205%3%2%3%2%1528
December 20203%2%1%2%2%1575
March 20213%2%1%3%2%1492
June 20214%2%2%4%2%1480
Source: Online Tracker, past 12 month gamblers

The lack of increase in payday loans amongst those that had gambled within the previous twelve months is consistent with YouGov Profiles (opens in new tab) data. Based on information from their panel, the use of payday loans has been stable during the 2019-2021 period.

Figure 2. Have you ever taken out a short-term or payday loan? A payday loan is a small, short-term unsecured loan with high interest rates also known as “cash advances”. Figure 2. Have you ever taken out a short-term or payday loan? The graph is made up of three vertical bars. Each bar represents a year. Each bar is broken down into the following categories: "Yes, and I have completed payment" and "Yes, and I am in the process of completing payment".

Have you ever taken out a short-term / payday loan?
201920202021
Yes, and I have completed payment7%8%8%
Yes, and I am in the process of completing payment2%2%2%
Source: YouGov Profiles, GB 18+

Those that reported using borrowed money (family, overdrafts or loans) to gamble in the Consumer Voice research stated that it was the financial instability of Covid-19 that led to their use of borrowed money rather than the ban on gambling with credit cards.

Displacement to illegal sources of funds​

Metric
Gamblers aren’t displaced to illegal sources of funds, such as loan sharks, theft or fraud
Concern
There is a risk that those gambling with credit cards were doing so because it was their sole access to borrowed funds and, in the absence of that, may turn to illegal sources of revenue
Assessment
We have found no evidence of illegal activities to fund gambling as a result of the ban

From the intelligence that the Illegal Money Lending Team has received from victims with gambling addictions, they have not received any specific reports of illegal money lending from gamblers who have stated they have borrowed because of the credit card ban.

However, this will need to remain under observation as the team has seen a significant reduction in the number of reports received during the pandemic. Pandemic-related factors such as the closure of normal meeting places between loan sharks and victims, restrictions on movement and self-isolation are likely to have contributed to the decrease in reports, but this may change now that restrictions have been eased.

We have found no evidence of illegal activities to fund gambling activities but a regular, reliable source of data on this topic is not available. The Health Survey (opens in new tab) for England includes a question about whether respondents have ‘committed a crime to finance gambling’, but the 2020 fieldwork did not take place due to Covid-19 and the 2021 data is unlikely to be available until Dec 2022. However, the credit card gambling ban is just one of many variables contributing to this figure.

Bypassing the ban through other behaviours​

Metric
Gamblers don’t bypass the ban through credit card cash withdrawals, layering funds through wallets or using pay-later phone billing methods
Concern
Although there are legal methods of bypassing the ban on gambling with credit card funds, a widespread adoption of them would undermine the ban’s efficacy
Assessment
Awareness of workarounds is reasonably high, but far more people who previously gambled with a credit card now gamble with available (not borrowed) funds than other types of borrowed money

Figure 3. How past 12 month credit card gamblers have changed how they fund their gambling since the ban How past 12 month credit card gamblers have changed how they fund their gambling since the ban - The graph is made up of two vertical bars. Each bar represents a category: "I gamble with money that is available to me (i.e. not with borrowed money)" and "I gamble with other types of borrowed money instead of a credit card (e.g. loans, overdraft etc)". Each bar is broken down into the following categories: "Yes - as a result of the credit card ban", "Yes (both)", "Yes - as a result of something else (e.g. saving money, unemployment, furlough etc)" and "No".

How past 12 month credit card gamblers have changed how they fund their gambling since the ban
I gamble with money that is available to me (i.e. not with borrowed money)I gamble with other types of borrowed money instead of a credit card (e.g. loans, overdraft etc)
Yes - as a result of the credit card ban49%15%
Yes (both)2%0%
Yes - as a result of something else (e.g. saving money, unemployment, furlough etc)20%9%
No29%76%
1 respondent reported stopping gambling as a result of something else (e.g. saving money, unemployment, furlough etc). Zero respondents reported stopping gambling as a result of the ban. Source: Online Tracker, those who had gambled with a credit card before April 2020 (March & December wave, n=131)

Nearly half (49%) of the tracker survey respondents who had previously gambled on credit cards and reported that they have changed how they fund their gambling now gamble with available (not borrowed) funds. A minority (15%) have reported that the ban has resulted in them gambling with other types of borrowed money.

Three quarters (76%) of previous credit card gamblers do not gamble with other types of borrowed money.

Caution should be used when considering findings with very low base sizes, but of the 15% (n=17) that had gambled with other forms of borrowed money as a result of the ban:

Of the 76% (n=103) that had not gambled with other forms of borrowed money since the ban, there was a spread of scores across the PGSI: 15% were non-problem gamblers, 24% were low-risk gamblers, 34% were moderate-risk gamblers and 27% were problem gamblers.

Figure 4. When those that had gambled with borrowed money in the last 12 months had done so (either before the ban, after the ban or both). When those that had gambled with borrowed money in the last 12 months had done so (either before the ban, after the ban or both) - The graph is made up of seven vertical bars. Each bar represents a category. Each bar is broken down into the following categories: "Before April 2020 (i.e before the credit card ban came into force)", "Both before April 2020 and since April 2020" and "Since April 2020 (i.e. when the credit card ban came into force)".

When those that had gambled with borrowed money in the last 12 months had done so (either before the ban, after the ban or both)
Before April 2020 (i.e before the credit card ban came into force)Both before April 2020 and since April 2020Since April 2020 (i.e. when the credit card ban came into force)Base Size
Direct Credit49%19%31%180
Indirect Credit28%22%49%81
Overdraft37%37%26%85
Payday Loans28%22%50%39
Other Loans*29%25%46%24
Family and Friends35%38%27%73
Mobile Phone Account37%33%30%47
Source: Online Tracker, those who had gambled with each form of borrowed money in the past 12 months (Dec 20 + Mar 21 wave).

For use of borrowed funds for gambling, the use of loans will continue to be monitored, as will the methods that currently have small sample sizes.

All those that reported direct credit card use also reported in-person purchases of NL draw and scratchcard tickets, which is permitted with credit cards and therefore would not constitute a bypassing of the ban.

Bank Data:

We have seen earlier that there was no identifiable shift towards ATM withdrawals from credit cards at the time that the prohibition on gambling with credit cards was introduced. We have also been informed by the same major high street bank that there was no identifiable shift towards money transfers amongst those that had previously gambled on credit cards, which suggests that funds are not being commonly layered through wallets.

Consumer Voice Research:

The research explored attitudes and the likelihood of displacement to indirect sources of credit. Respondents showed a reasonably high awareness of the legal workarounds, such as withdrawing funds using a credit card by ATM to deposit into current accounts, or making a transfer from a credit account to a current account.

Some respondents reported that they were still funding gambling directly with a credit card, but further enquiries identified that the funding behaviour was actually indirect use of cards. Some examples are in the following paragraphs.

Consumer Voice Research

The Consumer Voice Research explored methods being used by those who reported that they were still using credit cards to gamble. The most common methods were:

Quote

"When the ban came into effect, I simply changed my method of payment to a debit card. Nowadays, I transfer money from my credit card to my current account. So my method of payment is exactly the same as it was before the ban. I just present it differently to the provider." (Male, 52, PGSI 1-2)

Quote

"I have only lifted money from the ATM about 5 times due to needing money before getting paid at the end of the month as I use my bank card all the time. I did put the money I had lifted into my bank." (Female, 49, PGSI 3-7)

Quote

"I have gone overdrawn and paid for shopping on my credit cards where I would never normally do this – this has been a result of COVID and the ban on credit cards." (Male, 47, PGSI 3-7)

Displacement to unlicensed gambling sites​

Metric
Gamblers aren’t displaced to unlicensed gambling sites or black market sources
Concern
Gambling websites that are not licensed to operate in Great Britain may accept credit cards but put customers at higher risk as they will not offer the same protections as the regulated market
Assessment
We have not identified any displacement to unlicensed websites as a result of the ban

Our sources, which include reported use of unlicensed websites in GB, have not identified any displacement to black market sources as a result of the credit card ban, although the motivations of the individual for gambling with an unlicensed operator are rarely known.

The rate of reports we have received has remained stable throughout the period that the ban was introduced, although consumers are unlikely to report behaviours to us if they have knowingly sought out an unregulated operator.

Inconvenience to leisure gamblers​

Metric
The inconvenience to leisure gamblers is minimised
Concern
The ban was intended to reduce gambling-related harms for those gambling with borrowed money whilst minimising the impact on those that gamble without experiencing harms
Assessment
The ban has helped some gamblers control their gambling without seriously inconveniencing others

The consumer voice research identified that overall awareness of the ban, even amongst credit card gamblers, is reasonably low. Most of the gamblers used multiple methods of payment and could replace their credit card payments with a viable alternative, for example, a debit card.

The research found that there were 2 main attitudes towards the ban amongst former credit card gamblers:

Opinions are broadly positive and, for some, the ban has increased awareness of the amount being spent on gambling.

The research concluded that the ban does not appear to have drastically changed overall gambling behaviour and claimed spend but there are indications that gamblers are not falling into debt as frequently or as severely. It has removed a gambling temptation from the minds of some gamblers.

Quotes from the consumer voice research include:

Those that feel less tempted to spend money gambling:

“I use my bank card / my own money, which is definitely better than using a credit card as it’s money I actually have” (Male, 25, PGSI 3-7).

“Any measure that can help people avoid developing a gambling problem has to be applauded. It can remove the temptation for people who might otherwise reach for their credit cards in a vain attempt to recoup any losses” (Male, 56, PGSI 3-7).

“I would say it has been a positive thing for me as it has removed any chance of me getting into debt by using one (a credit card) to gamble with money I don’t have” (Male, 56, PGSI 3-7).

“It’s actually done me a favour as I don’t spend when I don’t have my wages as much. I think it was a really good thing to do” (Female, 25, PGSI 3-7).

“It is positive as I won’t use it if there is no money in my bank where I would probably use it if there wasn’t a ban on it” (Female, 49, PGSI 3-7).

“I still make withdrawals from my credit card when I can’t use my debit card. Inconvenience is that it is harder having to go to the cash point first and then buy lottery tickets” (Female, 32, PGSI 0).

“Moving money over has caused me to have to add an extra step for payment. I wouldn’t exactly call myself ‘inconvenienced’, however” (Male, 52, PGSI 1-2).

“I think it has helped people but, at the same time, I just used a different card to gamble with so if people want to place bets, they will find a way to do so even with the ban in place” (Male, 21, PGSI 3-7).

When asked how the ban on gambling on credit cards had affected individual’s gambling in the Online Tracker of June 2020, responses included individuals who:

Welcomed the additional friction to spending with borrowed money:

“It made it harder for me to gamble because I cannot get access to funds which otherwise were freely available to me without any hassle. The ban has made it harder for me to gamble irresponsibly, which is a good thing.”

“I am more aware of how much I spend as it’s more ‘real money’ to me so I need to be careful of my expenditure.”

Are now gambling within their limits or have reduced the amount of time and money they spend gambling:

“I now bet less because it comes out of my account and feels like real money.”

“It cut off a means to gamble and get myself into deeper debt.”

“It’s stopped me from spending more money, and creating more interest on my credit cards.”

Highlighted their use of workarounds or use of other forms of borrowed money for gambling:

“For several sites, I have had to change the method of payment to a normal bank card. It has forced me to use my overdraft facility a few times instead of the credit card.”

“I stopped using my credit card to fund my gambling directly, but I still can withdraw money from any ATM and use the money the way I like.”

Conclusions and next steps​

Having monitored the metrics identified in the Theory of Change model since the prohibition on gambling with credit cards was introduced in April 2020, no evidence has been identified so far that would support a requirement for significant remedial action.

The ban has been successfully introduced and identified changes in financial and gambling behaviours for those who previously gambled using credit cards have, on the whole, been positive.

The majority of those who have changed their behaviours have reduced their reliance on borrowed money to gamble, the inconvenience to leisure gamblers has been minimised and there is support amongst gamblers with a range of gambling intensity for the introduction of the credit card ban.

However, it is also clear that the awareness of legal workarounds is reasonably high and those that are sufficiently motivated to gamble with borrowed money are likely to find a way to do so, albeit whilst experiencing greater friction. Ongoing monitoring of behaviours is important in case the end of lockdown restrictions brings about an increase in more harmful forms of funding gambling activity.

NatCen have been commissioned to complete a full evaluation of the impact of the credit card ban by Greo. The evaluation contract began in June 2021 with fieldwork for qualitative and quantitative data currently underway and is scheduled to conclude at the end of February 2023.

The metrics that will be considered as part of the full evaluation are longer-reaching and complex than those considered in this monitoring phase; they will require additional sources of information and co-operation of multiple stakeholders.

In particular, support from the financial industry would assist the completion of the evaluation. Certain identified metrics can only be informed by data held by financial services bodies and the co-operation of one or more financial bodies representative of GB consumers would assist in evaluating the impact of the prohibition of gambling on credit cards.

Appendices​

Appendix 1: ToC Participating Organisations

The following organisations kindly contributed to the development of a Theory of Change in a workshop session held in January 2020 and hosted by the Gambling Commission:

In addition, the Advisory Board for Safer Gambling provided input by correspondence.

Appendix 2: Online Tracker Survey Questions

Online Tracker Survey Questions (December 2018 and March 2019)

Ask all who have gambled on at least one product

Q70. Have you used any of the following methods specifically to fund gambling activity in the last 12 months? (tick all that apply)

  1. Credit card
  2. Overdraft facility
  3. Payday loans
  4. Other loans
  5. Family and friends
  6. Other (Please specify)
  7. None (Exclusive).

Ask for all options selected at Q70

Q.71. Again, thinking specifically over the last 12 months, and the methods you have used to fund gambling activity, how have you gambled? (one answer per row)

Methods used to fund gambling activity over the last 12 months (Dec 2018 and Mar 2019)
Gambling in PersonGambling OnlineBoth in Person and OnlineCan’t remember
Credit Cards
Overdraft Facility
Payday Loans
Other Loans
Family and Friends
Other

Online Tracker Survey Questions (September 2019)

(Ask all who have gambled on at least one product)

Q70. Have you used any of the following methods specifically to fund gambling activity in the last 12 months? (tick all that apply)

  1. Credit card
  2. Overdraft facility
  3. Payday loans
  4. Other loans
  5. Family and friends
  6. None (Exclusive).

(Ask for all options selected at Q70)

Q.71. Again, thinking specifically over the last 12 months, and the methods you have used to fund gambling activity, how have you gambled? (one answer per row).

Methods used to fund gambling activity over the last 12 months (September 2019)
Gambling in PersonGambling OnlineBoth in Person and OnlineCan’t remember
Credit Cards
Overdraft Facility
Payday Loans
Other Loans
Family and Friends
Other

(Ask for all options selected at Q70)

Q72. We are interested in finding out why people use borrowed money for gambling. You have reported that you have used specifically to fund gambling activity in the last 12 months, can you please outline why you chose to use this/these?

(Open response - uncoded)

Online Tracker Survey Questions (December 2019)

(Ask all who have gambled on at least one product)

Q70. Have you used any of the following methods specifically to fund gambling activity in the last 12 months? (tick all that apply)

  1. Credit card
  2. Overdraft facility
  3. Payday loans
  4. Other loans
  5. Family and friends
  6. None (Exclusive).

(Ask for all options selected at Q70)

Q.71. Again, thinking specifically over the last 12 months, and the methods you have used to fund gambling activity, how have you gambled? (one answer per row)

Methods used to fund gambling activity over the last 12 months (December 2019)
Gambling in PersonGambling OnlineBoth in Person and OnlineCan’t remember
Credit Cards
Overdraft Facility
Payday Loans
Other Loans
Family and Friends
Other

Online Tracker Survey Questions (March 2020)

(Ask all who have gambled on at least one product)

Q70. Have you used any of the following methods specifically to fund gambling activity in the last 12 months? (tick all that apply)

  1. Credit card
  2. Overdraft facility
  3. Payday loans
  4. Other loans
  5. Family and friends
  6. None (Exclusive).

(Ask for all options selected at Q70)

Q.71. Again, thinking specifically over the last 12 months, and the methods you have used to fund gambling activity, how have you gambled? (one answer per row)

Methods used to fund gambling activity over the last 12 months (March 2020)
Gambling in PersonGambling OnlineBoth in Person and OnlineCan’t remember
Credit Cards
Overdraft Facility
Payday Loans
Other Loans
Family and Friends
Other

Online Tracker Survey Questions (June 2020)

(Ask all who have gambled on at least one product)

Q70. Have you used any of the following methods specifically to fund gambling activity in the last 12 months? (tick all that apply)

  1. Credit card
  2. Overdraft facility
  3. Payday loans
  4. Other loans
  5. Family and friends
  6. Mobile phone account (adding the cost of gambling to your mobile phone bill to pay at a later date)
  7. None (Exclusive).

(Ask to all who select codes 1-6 on Q70)

On the 14 April 2020 a ban came into force which prevents adults from gambling in Great Britain with a credit card. The ban applies to online and in-person gambling products, with the exception face to face payments for lotteries.

QCREDIT2: To what extent do you agree or disagree that the ban on gambling with a credit card has had an impact on the way that you fund your gambling?

SINGLE CODE: Strongly agree/Tend to agree/Neither/Tend to disagree/Strongly disagree/Don’t know

(Ask to all who strongly agree or tend to agree in QCREDIT2)

QCREDIT3: In your own words, please explain how the ban on gambling with credit cards has impacted how you fund your gambling.

Open ended

Online Tracker Survey Questions (September 2020)

(Ask all who have gambled on at least one product)

On the 14 April 2020 a ban came into force which prevents adults from gambling in Great Britain with a credit card. The ban applies to using a credit card to gamble online and in-persons, with the exception of buying tickets for lottery draws or scratchcards face to face in retail premises.

Q70(New). Have you used any of the following forms of borrowed money specifically to fund gambling activity a) in the last 12 months and b) since April 2020 (i.e. when the credit card ban came into force)? (tick all that apply)

Forms of borrowed money specifically to fund gambling activity
In the last 12 monthsSince April 2020 (when the credit card ban came into force)
Credit card to directly fund gambling (e.g. depositing funds into an online account using a credit card or using a credit card in a gambling establishment)
Credit card to indirectly fund gambling (e.g. withdrawing cash from an ATM using a credit card to pay for gambling)
Overdraft Facility
Payday Loans
Other Loans
Family and Friends
Mobile phone account (adding the cost of gambling to your mobile phone bill to pay at a later date)
Other

(Ask to all who have gambled on a credit card in the last 12 months (Q70(NEW) Code 1)

QCREDIT4: We are interested in how you have changed the way you fund your gambling since the ban on using a credit card to gamble came into force in April 2020 and whether this is as a result of the ban or because of something else.

Since the ban came into force in April 2020, which of these statements, if any, apply to you?

Funding your gambling since the ban on using a credit card to gamble
Yes – as a result of the credit card banYes – as a result of something else (e.g. saving money, unemployment, furlough etc)No (Exclusive)
I have stopped gambling altogether(Hidden to respondents who have gambled in the last 7 days or 4 weeks)(Hidden to respondents who have gambled in the last 7 days or 4 weeks)(Hidden to respondents who have gambled in the last 7 days or 4 weeks)
I gamble with money that is available to me (i.e. not with borrowed money)
I gamble with other types of borrowed money instead of a credit card (e.g. loans, overdraft etc)

Online Tracker Survey Questions (December 2020 and March 2021)

(Ask all who have gambled on at least one product)

Q70(NEW). Have you used any of the following forms of borrowed money specifically to fund gambling activity in the last 12 months? (tick all that apply)

  1. Credit card to directly fund gambling (e.g. depositing funds into an online account using a credit card or using a credit card in a gambling establishment)
  2. Credit card to indirectly fund gambling (e.g. withdrawing cash from an ATM using a credit card to pay for gambling)
  3. Overdraft facility
  4. Payday loans
  5. Other loans
  6. Family and friends
  7. Mobile phone account (adding the cost of gambling to your mobile phone bill to pay at a later date)
  8. None (Exclusive).

(Ask to anyone who has gambled with credit in the last 12 months (Code as at Q70(NEW). Only pull through the forms of credit they have used)

On the 14 April 2020 a ban came into force which prevents adults from gambling in Great Britain with a credit card. The ban applies to using a credit card to gamble online and in-persons, with the exception of buying tickets for lottery draws or scratchcards face to face in retail premises.

QCREDITWHEN: When did you use this form of borrowed money to fund gambling activity?

When did you fund your gambling since the ban on using a credit card to gamble
Before April 2020 (i.e before the credit card ban came into force)Since April 2020 (when the credit card ban came into force)Both before April 2020 and since April 2020
Credit card to directly fund gambling (e.g. depositing funds into an online account using a credit card or using a credit card in a gambling establishment)LOGIC – Only applicable for those who have purchased NL tickets or scratchcardsLOGIC – Only applicable for those who have purchased NL tickets or scratchcards
Credit card to indirectly fund gambling (e.g. withdrawing cash from an ATM using a credit card to pay for gambling)
Overdraft Facility
Payday Loans
Other Loans
Family and Friends
Mobile phone account (adding the cost of gambling to your mobile phone bill to pay at a later date)
None (Exclusive)

(Ask to all who have used a credit card to directly fund gambling before April 2020 (Row 1, code A and C at QCREDITWHEN)

QCREDIT4: We are interested in how you have changed the way you fund your gambling since the ban on using a credit card to gamble came into force in April 2020 and whether this is as a result of the ban or because of something else.

Since the ban came into force in April 2020, which of these statements, if any, apply to you?

When did you use this form of borrowed money to fund gambling activity
Yes – as a result of the credit card banYes – as a result of something else (e.g. saving money, unemployment, furlough etc)No (Exclusive)
I have stopped gambling altogether(Hidden to respondents who have gambled in the last 7 days or 4 weeks)(Hidden to respondents who have gambled in the last 7 days or 4 weeks)(Hidden to respondents who have gambled in the last 7 days or 4 weeks)
I gamble with money that is available to me (i.e. not with borrowed money)
(LOGIC– Only applicable to those who have selected any other form of borrowed money since the ban (QCREDITWHEN row 2-7 codes b/c)
I gamble with other types of borrowed money instead of a credit card (e.g. loans, overdraft etc)

Online Tracker Survey Questions (June 2021)

(Ask all who have gambled on at least one product)

Q70(NEW). Have you used any of the following forms of borrowed money specifically to fund gambling activity in the last 12 months? (tick all that apply)

  1. Credit card to directly fund gambling (e.g. buying tickets for lottery draws or scratchcards in retail premises) (LOGIC – Only applicable for those who have purchased NL tickets or scratchcards)
  2. Credit card to indirectly fund gambling (e.g. withdrawing cash from an ATM using a credit card to pay for gambling)
  3. Overdraft facility
  4. Payday loans
  5. Other loans
  6. Family and friends
  7. Mobile phone account (adding the cost of gambling to your mobile phone bill to pay at a later date)
  8. None (Exclusive).

Appendix 3: 2CV Questions

  1. Gambling, Spend & Covid-19:

Has Covid-19 had any impact on the amount of money you spend or stake when gambling? Has this gone up/down?

Has Covid-19 had any impact on the way you pay for gambling? We’d encourage you to think about the different moments of the pandemic and which payment methods you may have used at different points

  1. Did you use a credit card to gamble before the credit card ban in April 2020? (Y/N)

Please note – by ‘use a credit card’ we mean putting funds into an online gambling account with a credit card, using a credit card to add funds to a digital wallet which was then used to gamble OR paying with a credit card in a gambling establishment. We do not mean using a credit card to withdraw cash from an ATM which is then spent on gambling.

  1. How you fund your gambling now. We’d like to know:

Was credit card your primary method of payment before the ban? Or did you use a mix of payment methods? If so, please specify?

For what activities and under what circumstances did you use a credit card over other methods of payment? For example, you may have used a credit card for certain gambling activities but not for others, please specify

How do you now pay for gambling instead of a credit card? Has this caused any inconvenience? This could still include, using a credit card indirectly by withdrawing cash from an ATM using a credit card.

How (if at all) have you substituted your credit card with other forms of borrowed money since April 2020? What has been the main reasons for this? Has this been as a result of the credit card ban? Or Covid-19? Or both? This could include loans, payday loans, an overdraft, borrowing from friends or family, loans sharks, paying via your phone bill or something else. Feel free to write ‘N/A’ if you have not gambled with borrowed money. to spend money on, etc.

  1. Your thoughts on the credit card ban. Please tell us:

What are your thoughts on the credit card ban? Do you think that the ban has helped/could help you or other people? Why/why not?

Thinking about your gambling activity since April 2020 – how (if at all) has your gambling activity changed? Have you gambled any differently as a result of the ban? You may like to think about the types of games you play, where you choose to play and when etc.

  1. Impact of credit card ban on gambling time and spend. Continuing to think about your gambling activity since the credit card ban in April 2020:

Has the ban impacted the amount of time you spend on gambling? Think about how often, at what times you gamble and how long each session usually is (has this gone up/down)?

How about your gambling spend? Has the amount of money you spend or stake when gambling been impacted by the ban? Has this gone up/down at all?

How (if at all) has the credit card ban positively or negatively affected you and your lifestyle? How about the lifestyle of your friends/people you gamble with? Can you share any examples?

How (if at all) has the credit card ban positively or negatively affected your overall financial situation? Think about things like your savings; the things you can afford to spend money on, etc.