Progress Report on the National Strategy to Reduce Gambling Harms
Create a league table measure progress by operators
We know from other regulated sectors that transparency is an important driver of change. The National Audit Office report stated that a wider range of tools are needed to drive change92. For online gambling, the opportunities for using data are a particularly important area to focus on. We recommend, therefore, the Gambling Commission introduces a ‘safer gambling league table’ to be populated by new mandated metrics from the industry.
The principle of an operator league table
Our key recommendation is that operator data is published in a league table format with aim of increasing transparency and, through this, incentivising greater progress towards a safer online gambling market. Details of what this would include for online and land-based activities will differ, but the principle of increasing transparency applies to both.
Publishing data in this way is used routinely in other regulated industries to maintain and improve standards. Examples include:
- Care Quality Commission, who publish data on a range of metrics related to hospital performance, patient care and outcomes93.
- The water regulator, Ofwat, who publish data on performance indicators with financial incentives attached to good performance94.
- The Solicitors Regulation Authority, who publish data on diversity characteristics of law firms employees with the aim of promoting a more representative legal workforce95.
In all of these examples, the transparency created by publishing data means regulated businesses are open to increased scrutiny, not only by the regulator, but from a wider range of stakeholders and the public as a whole. This scrutiny means that businesses are incentivised to maintain higher standards – this can help them attract customers, protect share value and demonstrate corporate values.
At this stage we do not have firm view on the specific metrics which should be included in the league table. In a data rich sector, such as online gambling, there is a wide range of possible options, and different gambling activities would require different metrics in order for comparisons to be meaningful. We recommend a working group is established to agree these. This group should be made up of a wide range of experts from across the sector, and must include people with lived experience. The Commission would also need to examine unintended consequences of these metrics and any potential perverse incentives they might create.
We propose four categories of metrics to be considered as a starting point: affordability checks, Gross Gambling Yield metrics, time spent gambling online and warning labels. Each of these are discussed below – but these and other options should be considered in more detail by the working group tasked with identifying the most effective safer gambling metrics.
At their evidence session in the House of Lords96, industry leaders asked the Commission to take the lead on affordability checks, suggesting there should be a standard across the industry. The GVC CEO, suggested that “if we can tackle the [affordability] issue and get it right then the numbers of problem gamblers would come down significantly”
Whilst there appears to be broad consensus on the need for affordability checks, there is less agreement on how best to develop such standards. Industry leaders view their own internal processes as commercially sensitive.
There is little agreement on what constitutes ‘affordability’ or level of spend, and there will of course be wide variation across different gambling activities. Another barrier to progress is finding ways to monitor a single customer spend across operators. However, the Commission could consider a number of options;
- Require operators to publish the number of customers to lose £100 or more in a day, and the proportion of these who have received an affordability check. The figure of £100 could be reduced in future years once a reporting process has been established.
- Require operators to publish the percentage of gamblers with cumulative losses of more than £500 per month.
- If either or both of those options are implemented, then operators should also make the full distribution of daily and monthly losses and affordability checks available.
- Require operators to publish the actions taken as a result of these affordability checks – e.g. the % where a hard loss limit is subsequently implemented or gambling by a customer is suspended.
- Where customers are being sent incentives – such as bonus offers - require operators to publish the % of these customers who have received an affordability check.
Gross Gambling Yield
Gross Gambling Yield is the amount retained by operators after payment of winnings (before the deduction of operating costs). Any profitable gambling business is built upon the creation of GGY. Gambling expenditure (i.e., losses) has been shown to be a strong predictor of gambling-related harm97. Even small increases in gambling expenditure are linked to gambling-related harm, providing evidence that gambling-related harm is broad-based and is not limited to a small fraction of gamblers. An operator could reduce its per-customer GGY either by decreasing its house-edge, or by encouraging customers to play more slowly or for shorter amounts of time. These are all game design features operators may be incentivised to maximise without the use of such a league table metric.
The Commission routinely publishes overall GGY for all operators. We propose the Commission goes further and requires more detail on GGY. The risk of harm is greater where a large part of revenue derives from a small number of players.
Proposals for consideration by the working group might include:
- All operators could be asked to provide informative data on their GGY per customer or yield per head compared with totals. Total GGY per-customer is influenced by the house-edge, speed of play, and length of play. GGY as a fraction of the total amount bet is equivalent to the house-edge. Just publishing this statistic would still provide operators with an incentive to encourage customers to play faster or for longer periods of time.
- All operators could be asked for the percentage of GGY extracted from the top 10% of account holders.
- All operators could be asked to provide metrics that illustrate the degree of concentration of spending among its customers.
Time spent gambling
Gambling-related harms are not always financial – time spent gambling, at the expense of time with family, friends, or in employment are often highlighted as significant causes of harm98.
To recognise this, we recommend an operator league table also includes metrics on time spent gambling. Total time spent gambling online per week, or average time spent gambling online for the top 10% longest playing customers, would provide a good insight into potentially harmful periods of play.
The effectiveness of warning labels and safer gambling signposting is not clear cut, and research on this is mixed99. However, in the interests of promoting greater transparency and accessibility, we advocate further exploration is undertaken of both warning labels and safer gambling messages. Unlike the three categories above, this category would not involve operators publishing their own data but would involve the Commission in making an assessment of operators’ performance and publishing the results.
Operators would be ranked according to the number of products displaying clear and demonstrably effective warning labels on their products. In addition to clear displays of warning labels, operators could also be ranked on the prominence of their signposting to helplines, or use of pop-ups.
The categories above are a starting point – methodologies for calculations will need further exploration and consultation and consideration given to how to weight the different metrics in a composite score to determine league position. In the longer term, the Commission could consider using star ratings and/or financial incentives (a percentage of licence rebate if an operator achieves a certain rating on the safer gambling league table).
92 Gambling Regulation: Problem Gambling and Protecting Vulnerable People, National Audit Office, February 2020.
93 Care Quality Commission, Publications
94 Ofwat - website
95 Solicitors Regulation Authority – Law firm diversity
96 Gambling industry committee, Parliamentlive.tv, (response at 16.50), February 2020
97 The relationship between player losses and gambling‐related harm: evidence from nationally representative cross‐sectional surveys in four countries. Markham, Young, Doran, 2016.
98 Measuring gambling-related harms – a framework for action, Wardle, Reith, 2018
99 Equivalent gambling warning labels are perceived differently, Newall, Walasek, Ludvig, 2020.
Framework for measuring harm reduction Next section
Last updated: 19 August 2021
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