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October 2019: Industry Challenges

Phase one of the Gambling Commission’s Industry Challenge initiative, set at our industry briefing in October 2019.

  1. Contents
  2. Foreword


We exist to safeguard consumers and the wider public. We do that by regulating gambling, including the National Lottery, and giving advice and guidance about how to make gambling fairer and safer.

We put consumers at the heart of our approach, which requires us to strike a balance between the enjoyment people get from gambling and the risks that gambling can present. Managing those risks is not just the responsibility of the individual consumer. That is why we assess risks by looking at the providers of gambling, the products that are offered and the places in which people gamble.

Our approach allows us to respond to emerging risks and issues, whilst constantly seeking ways to drive up standards. This is especially important due to the challenges and opportunities online gambling and smartphone technology are bringing and the effect that is having on consumer behaviour.

We must ensure consumer safety remains a number one priority by working with the industry, service providers for people affected by gambling related harms and people with lived experiences to maintain high standards for consumers to enjoy gambling at their leisure and safely at all times. Therefore, in October we set out three challenges to the industry. This report provides an update on those challenges and explains our next steps.

We invited operators to participate in an ambitious program of collaboration in the hope that we could raise standards for consumers by bringing a more diverse range of perspectives to bear on some difficult issues. This initiative concerned some commentators, for reasons I understand. It was an experiment, but we judged it to be worth trying if it resulted in improvements that would better protect consumers.

Whilst there is much more to do, which we will address, we judge the experiment to have been a partial success, as in some important areas the result of the challenges will help us make gambling safer, faster.

Over recent years, the Commission has raised standards both through a much tougher compliance and enforcement regime and through changes to the Licence Conditions and Codes of Practice (LCCP). However, to make gambling safer at pace, last October we challenged operators to tackle three key areas that had the potential to make gambling safer for consumers, including vulnerable groups.

Those areas were:

  • incentives for high value customers, often referred to as VIPs
  • game and product design
  • the use of advertising technology, or 'Ad-Tech', to protect children, young people and vulnerable adults online.

For collaboration to be successful it requires a full diversity of opinions. Before setting the challenges, we took advice from our Digital Advisory Panel and the Advisory Board for Safer Gambling on online harms. Their advice was grounded in evidence and experience and understanding of where the risk of harm lies. We chose the areas that we considered would address significant risks to vulnerable groups and adopted a new approach, based on industry collaboration, in order to see where improvements could be made more quickly.

We also engaged with other stakeholders, including with GamCare (opens in new tab) who ran a survey with their users on each of the areas of work and met with Experts by Experience to talk in general terms about the issues associated with the challenges, before final proposals from industry were formed. The work on these challenges is far from done and further involvement from Experts by Experience will be vital as we move to a connected set of consultations.

Since our announcement at the end of April, we have continued to engage with experts by experience, who have provided further feedback and challenge as the industry proposals were published.

Ahead of that, a range of steps are underway, such as elements of the ad-tech work like the adoption of a common list of industry negative search terms, which will help shield vulnerable groups from online gambling ads. All of that can and will happen in parallel with the Commission’s plans to consult in order to ensure that standards are raised, and operators are pushed to go further than the current proposed actions go.

In these unprecedented times caused by the impact of Covid-19, we have pushed the industry to make necessary changes to keep consumers safe from harm. We have seen that changes can be made speedily. There is no reason why the industry can’t up the momentum to make lasting changes for safer gambling, and we will ensure they do.

Much more work remains to be done. Gambling can and must be made safer and we are determined to build on the progress that has been made and introduce other changes in the near future. So, thank you to those who have worked with the Commission to make the progress discussed in this update and thank you to those who will be helping us as we go forward with the next steps. Working together, I am sure we will continue to make gambling safer.

Foreword by Neil McArthur, the Gambling Commission’s Chief Executive.

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