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Report

Annual report and accounts 2024 to 2025

The Gambling Commission's 2024 to 2025 annual report and accounts. For the period 1 April 2024 to 31 March 2025.

Governance statement for the year ended 31 March 2025

This section sets out the internal control and risk management systems in place within the Gambling Commission, and the structures in place to review the efficacy of those systems.

Governance framework

The Commission has complied with government guidance for corporate governance in Arm’s Length Bodies (ALBs). These requirements are primarily codified in the framework agreement with the Department for Culture, Media and Sport (DCMS), and the Commission’s governance framework.

The Commission meets the requirements of government guidance for corporate governance by:

  • setting out and publishing a governance framework
  • ensuring decisions are supported by effective papers and recorded in minutes
  • provision of regular core reporting to the Board, Executive Committee and other committees, including financial and operational performance, and risk
  • annual effectiveness reviews of the Board and committees
  • maintaining skills analysis and succession plans to inform Commissioner recruitment to support the public appointments process to ensure a strong mix of knowledge and experience at board level
  • managing an up-to-date declaration of interest register and ensuring interests are managed appropriately.

The Commission’s governance framework, including a scheme of delegations (general, financial and regulatory), code of conduct, anti-fraud and corruption, complaint and Speak Up policies are published in the Corporate Governance Framework.

Board effectiveness for 2024-25 was reviewed internally and tested the Commission against the relevant Cabinet Office guidance Board effectiveness reviews: principles and resources for arm’s-length bodies and sponsoring departments (opens in new tab).

The 2024 to 2025 Board Effectiveness Review (BER) focused on the following areas:

  • performance of the board
  • board assurance
  • the relationship between the board and executive team
  • Commissioners' ways of working
  • quality and timing of papers and presentations to the board
  • board succession planning.

A BER report was shared with the Board in May 2025. An action plan to address the recommendations in the report was discussed and approved by the Board, with implementation planned during 2025 to 2026.

Decision-making and scrutiny

The Board of Commissioners, led by the Interim Chair, Charles Counsell, oversees the business of the Commission. The day-to-day activity of the Commission is managed by the Executive Committee, led by me as Chief Executive and Accounting Officer.

Commissioners are responsible for the strategic direction of the organisation and oversee delivery of the Commission’s business plan.

Meetings of the Board of Commissioners are governed by the Rules for the conduct of business and provide the opportunity for robust and constructive challenge and debate amongst board members and senior management.

Discussions and decisions at Board (and Committee or Executive Committee) are almost always supported by written papers. A minute of all Board, Committee and Executive Committee meetings is taken, and actions and decisions are logged and tracked.

During the year, formal board meetings focused on key themes including the implementation of the new Corporate Strategy, the full implementation of the 4NL Licence, progress of key projects being delivered across the organisation, including, but not limited to, implementation of the recommendations set out in the Gambling Act Review White Paper, and developing how the Commission manages risk at an organisational level. Risks relating to 4NL litigation were directly reviewed, challenged and scrutinised at Board level during the year. More detail on these risks is set out in the Risk section.

The Board continues to make use of several sub-committees of Commissioners and, in some cases, Commission employees, to undertake more detailed scrutiny or to make delegated decisions. Commissioners also retain direct responsibility for some regulatory decisions through the regulatory panel process.

The membership and remit of these committees are outlined as follows:

Committees and sub committees

Board

Chair: Marcus Boyle (until 31 January 2025).

Interim Chair: Charles Counsell, OBE (from 1 February 2025).

Senior Independent Director:

  • Catharine Seddon (up to 10 April 2024)
  • Charles Counsell (from 11 April 2024 to 31 January 2025)
  • David Rossington (from 1 February 2025 to present).

Members of the Board:

  • John Baillie (up to 10 April 2024)
  • Lloydette Bai-Marrow
  • Stephen Cohen (up to 11 November 2024)
  • Charles Counsell OBE
  • Helen Dodds
  • Sheree Howard
  • Claudia Mortimore
  • Helen Phillips
  • David Rossington
  • Andrew Rhodes
  • Catharine Seddon (up to 10 April 2024).

In 2024 to 2025, the Board has had particular focus on implementing changes resulting from the Gambling Act Review (GAR) and the implementation of the new National Lottery licence. The Board has also overseen the performance of the Commission at a financial and strategic level.

Audit and Risk Committee

Chair: Sheree Howard.

Members:

  • David Rossington
  • Sheree Howard
  • Helen Dodds.

Independent member:

  • Chris Andrew (until 31 December 2024)
  • Rachel Sexton (from 1 January 2025).

Remit: assurance of financial and risk management processes and structures, including engagement with internal and external audit.

The Audit and Risk Committee (ARC) supports the Board and the Accounting Officer in their responsibilities by monitoring the integrity of the Commission’s annual statutory financial statements, reviewing the Commission’s governance, internal control and risk management systems, and by reviewing the internal and external audit services.

In 2024 to 2025, the ARC has also been involved in work to improve the Commission’s operations teams and its IT resilience.

Remuneration and Nominations Committee

Chair: Lloydette Bai-Marrow.

Members:

  • Lloydette Bai-Marrow
  • Helen Phillips
  • Catharine Seddon (until 10 April 2024)
  • Charles Counsell (until 11 December 2024)
  • Claudia Mortimore (from 11 December 2024).

Remit: the Remuneration and Nomination Committee supports the Board and Accounting Officer in their responsibilities for remuneration and performance management, senior appointments and succession planning.

In 2024 to 2025, the Remuneration and Nomination Committee were particularly involved in developing the pay and reward strategy and the employee value proposition.

National Lottery Committee (closed 11 September 2024)

Chair: Helen Dodds.

Members:

  • Helen Dodds
  • Sarah Gardner
  • Claudia Mortimore.

Independent member: Victor Olowe.

The National Lottery Committee was closed on 11 September 2024. Its purpose was to advise the Board and the Chief Executive in relation to the exercise of certain Commission functions under the National Lottery etc. Act 1993 (opens in new tab). The Committee had decision making powers in a number of areas delegated to it by the Board. A significant part of the Committee’s business was engagement with and review of the National Lottery operator’s strategy and performance.

The Committee’s main focus before closing was the management of the operator’s exit from the Third Licence and the closedown of the Commission’s 3NL operation. On 19 March 2024, the Board agreed that the National Lottery Committee would close in September 2024, by which time the significant majority of 3NL activity had been completed.

Regulatory Panel

Not a standing committee.

Remit: convened to make regulatory decisions in respect of operator and personal licenses, and enforcement action. The Panel is the final stage of internal decision making. Licensees and applicants have recourse to the First Tier Tribunal (Gambling) to appeal regulatory decisions of the Commission.

The Regulatory Panel determines some licence applications and deals with significant regulatory decisions which may include the revocation of licences. The Regulatory Panel sat once in 2024 to 2025, to hear a case in respect of a personal licence revocation.

Executive Committee

The Executive Committee leads the management of the Commission, making decisions about projects, policy, procedure, issues and cases which cannot be resolved at an operational level as they are novel or contentious, or significantly affect the Commission’s finances or staff.

The scope of the Executive Committee therefore extends to:

  • strategic leadership of the Commission
  • collective concentration on strategic issues affecting the Commission
  • scrutiny and challenge of Commission policies and procedures
  • review of business delivery, operational and financial performance.

The Executive Committee also agrees items for presentation and escalation to the Board of Commissioners.

Senior Independent Director

The Senior Independent Director (SID) holds an important role within the governance structure. Consistent with the UK Corporate Governance Code and with DCMS guidance, the Board has appointed a Senior Independent Director from among its current members.

The role of the SID is to provide a Board-level lead for high standards of governance, act as a sounding-board for the Chair and act as a route to resolve any concerns about the operation of the Board.

Expert Groups

The Commission draws on other areas of specialist knowledge via its 4 expert groups. Members of these groups do not have any delegated powers but do help to inform Commission policymaking and practice. Members of expert groups are bound by their respective codes of conduct and the Commission’s Managing Conflicts of Interest Policy.

Advisory Board for Safer Gambling

The Advisory Board for Safer Gambling (ABSG) provides advice to the Commission on issues related to safer gambling and the prevention of gambling-related harms, as well as taking a prominent role in helping the Commission to build our research and evidence base. The ABSG was chaired by Dr Anna van der Gaag CBE until 31 March 2025. She was replaced by interim chair Dr David Zendle from 1 April 2025.

Digital Advisory Panel

The Digital Advisory Panel (DAP) comprises experts primarily from the digital sector, and includes specialists in networks, AI, and statistics. The DAP provides the Commission with advice on matters regarding technology, digital trends and the implications for the Commission as a regulator. The DAP is chaired by Andy Payne OBE.

Lived Experience Advisory Panel

The Lived Experience Advisory Panel (LEAP) provides advice based on its members’ personal lived experience of gambling harms.

LEAP members are appointed by the Commission based on their individual personal experience of gambling harms. The group’s membership, collectively, is designed to provide perspectives from experience of a range of gambling harms. Gambling harms take many forms and can result from people’s own gambling or from the gambling of somebody else – such as a family member.

The LEAP is co-chaired by Susan Cox and Leon Green.

Industry Forum

The Industry Forum (IF) provides the Commission with insight into the views of industry about the Commission's plans, the quality of Commission services, and the wider environment in which gambling operators work.

The IF is chaired by Nick Rust OBE.

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