Introduction:

Following several false dawns and rumours of imminent release, the much-anticipated gambling review white paper was published by the UK Government on April 27th 2023. Given the breadth of topics which needed to be covered, and the potential for this to fundamentally alter the UK betting and gaming market for the first time in nearly 20 years, at over 90,000 words the final document is unsurprisingly heavy. To make it more digestible, we have summarised the key points for online operators and provided commentary below.

Cyclickal:

Cyclickal are betting and gaming growth specialists. We partner with business leadership and their teams to drive acquisition efficiency, improve prediction and nurturing of customers and increase engagement and user value. With decades of experience in the UK market we can help your business navigate the challenges arising from the changing regulatory landscape. If you would like to discuss any of the points raised in this article in further detail, please contact gerry.murray@cyclickal.com

Background:

This white paper is designed to help comprehensively reshape gambling policy for the UK, for the first time since the Gambling Act of 2005. 18 years on, the prevailing view is that existing policy has become outdated, owing to improved technology, activity shifting online, and better understanding of problem gambling behaviour.

The Gambling Commission has regularly intervened, the headline-grabbers being £2 stake limits on fixed-odds betting terminals, banning the use of credit cards for betting, removing reverse withdrawals for online operators, and enforcing changes to slots game design. However, the industry perception of the Commission is that their guidance has been ambiguous and enforcement uneven, in addition to which the public – and government – perception is that they are powerless in the battle to prevent exploitative behaviour by operators.

Those negative perceptions have been a major driver of the push for this paper. It is undeniable that media coverage of the betting and gaming industry in the UK has become increasingly hostile since the 2005 Act. The debate as to whether this coverage has been balanced and fair is now largely irrelevant in terms of its impact on the white paper and the industry moving forward: the fact is, pressure had been mounting on successive governments to be ‘seen to act’ to control what was perceived to be gambling’s increasing prevalence in society, its ubiquity in high-profile sport, and its contribution to what is now being framed as a ‘public health crisis’. The popular UK view is the industry had many chances to prove it could self-regulate and failed. The consistent announcement of UKGC fines and steady flow of stories detailing gambling harm reinforces this with every new story.

The white paper follows a ‘call for evidence’ which began in 2020 and received around 16,000 individual submissions, to complement ministerial meetings with numerous industry stakeholders over the past two years. Unfortunately, this process has coincided with a volatile political period for the UK government, resulting in a high turnover of ministers with influence over the document. The UK cost of living crisis has also predictably raised the prominence of affordability as a key theme of the paper. In addition, the drive to ‘reshape policy’ has also coincided with COVID lockdowns, which accentuated and accelerated some of the key trends the white paper states it aims to solve.

The stated aim of the paper is to make UK gambling policy ‘fit for the digital age’ and references the desire to strike the right balance between personal freedoms and choices, whilst increasing protection from harm and addiction. It clearly states a desire to pay particular attention to protecting children and young adults, and also notes that state intervention should be designed to prevent (rather than cure) addiction and harm. This balance is the critical one in all the recommendations, particularly for a Conservative-led government which is anxious to avoid being seen as anti-business, anti-growth or overly interventionist, but which also cannot afford to be on the wrong side of more negative coverage from a media sector which regards gambling as an easy target across the board.

Cyclickal’s Executive Summary: General Themes

This is just the start of the second half… Consultation, consultation, consultation

The key headline to take from the publication of the white paper is that this does not represent the final solution or recommendation for new policy, this is just the beginning of the second stage. Of the 17 key policy proposals outlined in the document, 14 now require further consultation led by either the Department for Culture Media & Sport (DCMS) or the Gambling Commission (GC). What this means in reality is that the period of relative ambiguity for operators will continue for a little while longer. The indicative timeline which has been set out suggests that matters will be concluded by the middle of 2024, but with so much still to do that feels like an ambitious aim.

The rules may change… Political uncertainty

With consultation comes the potential for change. As previously referenced, ministerial positions have churned constantly since this process started in 2020, and the Secretary of State for Culture, Media and Sport has had less job security than a Premier League football manager. Five ministers have held the position in that time and it is therefore odds-against that The Rt Hon Lucy Frazer KC MP stays in post long enough to see this through to conclusion. At a broader level, a General Election could be called at any point in the next 18 months, and with the Conservatives projected to lose power, the potential for new views and further delays as a new administration of whatever hue settles in is almost certain.

The benefit of declaring  early… What the front of shirt concession tells us

Given the backdrop of political upheaval and the level of consultation ahead it could and likely will be in the interests of major UK players to make some quick and clean concessions. The most significant risk for losing control of future policy will come from any recommendation which requires legislation and therefore debate and scrutiny in the House of Commons and House of Lords.

There has already been evidence of this tactic with Premier League front of shirt sponsorship being ‘conceded’ shortly before the white paper was published. In reality, no tier one operator in the UK is currently using that route to grow their brand, but it remains one of the biggest drivers of negative press coverage, particularly given the League’s popularity with younger audiences. Of the betting brands currently on the front of a Premier League shirt, only Betway could credibly make a case that they have made a concerted effort to grow a brand in the UK market in recent years, so conceding this from the 25/26 season was an easy PR win, which it is hoped will protect the value of sleeve sponsorship, LED boards, and most importantly TV advertising during live games.

Despite the headlines this news generated, it’s actually one of the lowest impact elements of the white paper for UK brands, but the tactic of conceding something relatively minor early, to protect something more valuable in the longer term, demonstrates that some lessons were learned from how the £2 stake limits for FOBTs was handled – a fight where the industry dug in for too long and ended up with the worst possible outcome.

It’s nearly time for a change…  The UK market reset

The optimistic view has been that there is an industry benefit of the white paper in levelling the playing field – at least for larger and responsible licensed operators. Given the guidance around how affordability levels for UK operators should be implemented was grey at best, standards were not the same across the board. Some operators (potentially smaller and less under the microscope of the GC) with a greater appetite for risk have been able to implement affordability checks at higher levels, later stages and based on more lenient definitions than larger and more responsible operators. This means they have not yet seen as much of a negative impact on expected customer value than those who have acted sooner and more definitively to meet what is expected to be coming. While their decisions may mean that the future hit is harder and that their pain is still to come, it does mean that for the short term, the market for acquiring new customers in the UK is distorted.

On one side, the less risk-averse can afford to pay higher CPAs, confident in the knowledge that their hopes of ROI are not scuppered by having to request documents (that they’ll rarely receive back) and ultimately block activity from higher value customers. On the opposite side of the spectrum, those who have acted earlier have been having awkward conversations with agencies, partners and affiliates about the need to reduce their acquisition cost, as the prices no longer reflect the customer value. It stands to reason that eventually the market will catch up with the reality of the impact on customer value from the regulatory changes which have hit the UK in recent years (and those still to come), but there is currently little incentive for a casino paid search aggregator to drop their CPAs when enough brands are still prepared to pay and able to monetise customers at the old price.

A draw isn’t a bad result…  After all the build-up, the result could have been a lot worse

While there is an awful lot of detail still to come – most notably in how low stake limitations are set and how soon affordability checks are required – the result for the industry could have been much worse. The introduction to the white paper sets out the objective of trying to strike the right balance between personal freedoms and improved player safety, and in most cases that has been met.

Five years ago, the prospect of £10 stake limits on slots and affordability checks on customers spending £2k in 90 days would have set alarm bells ringing in most operator boardrooms, but the reality is that most responsible businesses have been planning for this and have already taken many of the steps required to meet what is coming. It is also an often neglected point that you almost certainly do not want customers playing at above £10 a spin in a world where they can only lose £2k inside 90 days, as when the big win hits, there’s no chance of the customer ever playing that money back through.

Things could still get tougher, but for now the white paper seems a relatively balanced proposal.

Cyclickal’s Executive Summary: Online protections – players and products

It’s financial vulnerability, not affordability… Tackling unaffordable gambling

Alongside stake limits this was the section of the white paper most people headed straight for, and following the general theme, things could have been much worse. Doomsday scenario stories of limiting losses at levels under £200 per month had been mooted in the build up, but instead the white paper lists four more prescriptive levels at which they plan to formalise checks, as follows.

1. Tackling financial vulnerability. At a relatively moderate level of either £125 net loss within a rolling month or £500 inside a rolling year, operators should conduct a financial vulnerability assessment. Most larger operators are already meeting this requirement via third party checks from the likes of TransUnion and receive clarification on whether a player is bankrupt, has an outstanding County Court Judgement or lives in a postcode with particularly low affluence. The suggestion in the white paper is that around 20% of players would meet these thresholds, although our experience is that this figure would be higher for casino led operators. Many brands are actually exceeding this requirement already by checking at either registration or first deposit rather than low net loss levels, and these checks are almost instant and happen without any required customer action, so this point really shouldn’t be seen as a major negative. It’s also questionable from a commercial and regulatory risk perspective what value highly vulnerable players provide to businesses, so expect to see more brands cutting out this problem at source moving forward.

2. Binge gambling. Following the same lines as point 1, the white paper sets out a defined loss level for which ‘enhanced spending checks’ would be required, and in the case of binge gambling the bar has been set at losses exceeding £1k in a rolling 24-hour period. This is where financial vulnerability becomes more interesting, as unlike the frictionless checks required to detect bankruptcy or outstanding CCJs, the solution is not yet readily available and therefore cannot be credibly described as frictionless. The paper says more detail will come following consultation, and that work is ongoing with the financial services industry to solve this via either credit agency data or potentially open banking, but it is slightly concerning that they acknowledge when the required information is not available in a frictionless fashion ‘information may need to be collected directly from the customer’. In the short to medium term it is likely that operators will still be chasing, but in most cases not receiving, payslips and bank statements.

3. Sustained heavy losses over time. All the same points above relating to binge gambling also apply to the paper’s next proposed threshold of £2k or more in losses over a rolling 90-day period. The level at which this check is placed is broadly in line with where most operators are currently conducting enhanced due diligence, so again it is not likely to be a major change for most responsible UK operators. However, this section does highlight another key point related to ‘financial vulnerability’ checks. As mentioned in the general themes overview, prescriptive limits for everyone should be viewed as a positive – it levels the playing field for all – but there is a critical difference between prescribing the level for conducting a check and setting out clear instructions on what action should then be taken. The paper asks that ‘Personal Management Licence (PML) holders should be more clearly accountable for ensuring that these checks are completed at the right time for all customers and that appropriate action is taken based on the findings.’ What the paper does not define and specifically says it will not look to define, is what that action should be. The interpretation of whether action was appropriate will remain the GC’s responsibility, and as a result it will not remove the detailed scrutiny on processes in this area when licence holders are audited.

4. Young adults. The white paper is nice and simple when dealing with this point, as the recommendation is that all the thresholds for checks above should be halved if the player is 18-24.

Slowing down slots… Safer game design and stake limits

Work has already been done on slowing down the speed of slot games in the UK and while the white paper noted that this will continue (highlighting that the Government is considering further reductions in speed, mandating that loss levels during sessions are displayed, and removing the capability to play multiple games at one time) it is the potential for setting fixed stake levels for slots which was the headline everyone looked for.

Following a call for operator data, the paper set out the belief that while evidence of a clear causative effect is limited, there is sufficient evidence of an association between higher staking on slots and risks of harm. Based on this, it is believed that action is required on a precautionary basis.

A segmented approach to stake limits, applied based on an individual’s unique circumstances (‘financial vulnerability and markers of harm displayed’) was ruled out at this stage, and therefore a universal stake limit is coming – although at what level, we’re still unsure.

Currently the range under consultation is between £2 and £15 and positively there are some suggestions in the paper’s wording that the final decision won’t fall at the lower end. Estimations are that a £2 catch-all limit would cut revenues by 23%, so this still has potential to bite hard. The paper acknowledges that online play offers the operator a much greater level of insight into a customer than ‘anonymous’  offline activity, and also notes that online slots are more closely aligned to B1 casino machines where the limit is £5, than B2 and B3 where the level is £2. £5 limits were the general prediction before the paper was published, and it would not be a surprise if that is where things settle.

Once again, under 25s will be carved out from the wider levels and their range is being considered between £2 and £4, but given the general tone of the paper it would be wise for operators to avoid planning any happy 25th birthday promotions if they want to stay in the good books.

Products outside of slots got a pass and won’t have universal limits applied. The data shared in the report suggested that products like roulette are less susceptible to ‘binges’ than slots and that they also offer a customer a longer time of reflection given the average spin is 21 seconds. This will again be a relief, as the estimation is that a £2 limit on table games would have wiped out over 90% of the product’s revenue in the market, but in our view does not mean levels should not still be reviewed. As noted above, when spend thresholds are altered, stake sizes need to move in-line with these to ensure the optimal commercial balance.

Stake factoring… Limiting winners will continue

One of the hotter topics for punters in the lead up to publication was whether the white paper would address what is perceived to be an unfair practice in the industry of restricting winning accounts from continuing to bet. Twitter is awash daily with complaints  of operators limiting customers’ bets after relatively modest wins or in some cases refusing to take any further activity.

While the paper acknowledges that this practice could potentially send some bettors to the black market to ‘get on’ and states that operators should be transparent in their approach, the conclusion is that blocking winners does not equal discrimination. The summary points out that operators can make commercial decisions and also often have valid reasons for restricting accounts (suspicion of cheating being one cited), so this contentious issue has been pretty quickly batted away.

Cyclickal’s Executive Summary: Marketing & advertising

The balls in your court… Affiliate marketing is the industry’s problem to solve

While the Premier League front of shirt concession may have generated a significant amount of coverage ahead of the publication of the paper, the reality is advertising and marketing got off relatively lightly – at least for now. The glaring omission for any genuine attempt to better control the responsible practices would have included stricter controls on affiliate marketing and affiliates themselves. Despite the report noting that c. 40% of customer acquisition for the sector comes from affiliates, and many respondents noting it was an area which presented particular risk, it was made clear that there was no desire for the Gambling Commission to take on any responsibility to police this further. While the case is argued that this is already the ASA’s responsibility (‘placing additional duties on the Commission would lead to duplication’), the real reason is that it’s just too difficult and too large a sector for them to police: ‘the size of the sector means that it (having to regulate affiliates too) would distort the Commission’s remit’. For now, it will continue to be the operator’s job and it will continue to be the relatively uncontrolled marketing channel with the potential to drive negative press and further fines and enforcement.

Protect yourself at all times… Making advertising smarter and safer

This is another area which will ultimately be resolved via further consultation and the next iteration of the Industry Group for Responsible Gambling ( IGRG) Code, however once again the areas of focus were made clear.

 Firstly, there was a request that operators make better use of available, existing technology to ensure they are targeting those aged over 25 via digital advertising. On social media platforms and via most sophisticated programmatic campaigns that request is relatively easily met. The only potential risk the industry would be exposed to here is if this point were to escalate further during consultation and move to having to prove that operators are not targeting those under 25 (at a predefined level). Dutch regulators have already made such requests of operators, and the nightmare scenario for UK-focused marketing teams would be having to request regular demographic breakdowns of audiences from every site their ads could potentially appear on. For now at least, this is a relatively minor issue.

The second point, requesting improvements from online platforms, i.e. giving the user an option to opt-out of seeing gambling adverts, improving their algorithms to better control who sees these ads and providing more signposting for support are all worthy points to add, but even the white paper acknowledges that this is falling outside their remit to control. ‘Governing all actors across the online advertising supply chain is a larger issue to be addressed through the Online Advertising Programme’.

It was also encouraging for operators to see that broadcast advertising (and to a large degree sports sponsorship) was left alone. Concessions have already been made here, such as the whistle-to-whistle live football ban and the work towards a socially-responsible sponsorship code, so further restrictions were not seen as proportionate. The fact that the paper identified broadcast media in particular as being of lower potential risk, rather than applying an aggressive blanket approach to all advertising channels, is further evidence that a relatively balanced approach has been taken to each issue.

Turning the negative into a positive… Reducing the reliance on bonuses

The white paper proposes four principles related to direct marketing and promotional offers which they will explore through further consultation. None of these were major surprises.

1. Opt-ins available and made clear for all offers and promotions, and not be bundled in with T&Cs or privacy policies.

2. Customers should be able to easily change their preferences at any time.

3. Operators should give the option to customers to choose how they are communicated to – text, email and push notifications should all be configurable.

4. Customers should be able to tailor the offers they receive – for example, just because I want to receive horse racing promotions, shouldn’t mean I am bombarded with casino offers.

Cyclickal’s view here is that what is being proposed is ultimately what the industry should be doing anyway – utilising first party data to ensure we are communicating to customers based on the device, products and at a time that they prefer. Our experience is that there is too much reliance placed on broad, mass market offers to unqualified existing customer bases, and that this approach has contributed to the fact that the vast majority of emails sent are left unread anyway. Sending more tailored and qualified offers and promotions has to be beneficial in the long-term. It is also self-evident that other requirements from the white paper will impact operator profitability  – more process, more third party tech, and further affordability/stake restrictions – and that therefore anything that focuses attention on reducing ‘free bet’ costs and increasing efficiency is also likely to yield long term benefit.

For those who truly succeed in the UK moving forward – and other regulated markets heading in the same direction – this should kick-start a renewed focus on ways other than free bets to drive engagement. New product development, exclusive content and investment in brand can also generate loyalty – but admittedly they are a lot more difficult to deliver than 10 free spins.

With the news that land-based casinos will now be able to offer sports betting in their venues, a push for innovation is going to be needed for online operators regardless. It’s unlikely that the tide of offline to online revenues will dramatically reverse because of this decision, but COVID undoubtedly drove more regular retail customers to the online world and this new ruling opens up the potential for some to be lured back. A stream of free bets, deposit match bonuses and cash-back deals might manage the issue in the short-term, but it’s not the sustainable solution.

Government led campaigns… A new approach to safer gambling messaging

The final key topic impacting marketing activity was the approach to safer gambling messaging, and while there was a suggestion that new ways of communicating product risk may be required – e.g. ‘Players of this game lose £7 for every £100 based on average’ – the main headline was the intention of the Department of Health, Department of Culture, Media & Sport, and the Gambling Commission, to take more of a lead on this topic. Their view is that industry-led campaigns alone aren’t sustainable long-term and that their efficacy is questionable, and the intention is to create more ‘systematic’ messaging to promote safer gambling, independent of the industry.

The paper highlighted the belief that positive campaigns focused on taking control were more successful in changing behaviour than those leading with the negative impact of gambling harm: ‘For example, Ipsos MORI’s evaluation of GambleAware’s Bet Regret campaign found positive results, with the campaign reaching over 60% of its target audience after two years and motivating behaviour change in a significant portion of that demographic. 38% reported they were trying to ‘tap out’ before placing a bet and 24% reported that they were actively using ‘tapping out’ to help cut down on their gambling’. So, the expectation is that more of this style of campaign is to come.

It is highly likely that the industry will be required to fund this activity, even if they have less of an input on the direction of messaging moving forward, but for now the main requirement of operators will be a more rigorous adherence to the existing commitment to make 20% of TV and radio advertising focused on safer gambling and not via branded ads with calls to action, as these got a slap on the wrist – ‘Branded ‘safer gambling’ ad spots containing calls to action such as ‘enjoy award-winning online casino safely’ were also heavily criticised.’

Cyclickal’s Executive Summary: The Gambling Commission’s powers and resources

Everyone’s unhappy… The approach to enforcement

The industry thinks the GC needs to be more transparent, evaluate its work more effectively and develop a better working relationship with operators. This was well known before the ‘calls for evidence’ via regular criticisms of uneven enforcement and vague guidance. On the other side, non-industry respondents made it clear that they believe that the GC should be handing down bigger fines to operators. The general view was that despite fines totalling over £60m in 2022/23, most big players saw this as a ‘cost of doing business’. In short, nobody was singing the praises of the work the GC has been doing.

In light of this, the recommendation is that the GC needs more resources, funded through additional fees. That money appears to be earmarked for improved data systems and more staff aimed to be placed as dedicated account managers for the largest operators. How this plays out remains to be seen. The optimistic outlook is that a consistent relationship and dialogue with operators who make up the lion’s share of the market can only be a good thing and should help address some of the industry’s criticisms, especially on the point of developing a ‘better working relationship’. However, that focus on the bigger players does open up the potential for further criticism of an uneven approach to regulation.

On the subject of fines, it is noted that the GC can now consider an operator’s group finances, as opposed to solely their UK operation, when setting what they believe to be the appropriate punishments. That may lead to some bigger, headline-grabbing fines in the future, but given that total fines have grown from £1.7m in 2017 to £60.7m in the last year, things had already been clearly moving in that direction.

Clamping down… The GC approach to the unlicensed market

The looming threat of the black market as regulatory headwinds stiffen has often been overstated, but that does not mean it does not exist. Reports from other regulated markets such as Sweden have suggested that if you get the balance of enforcement of licensed operators and policing of the unlicensed wrong, up to 30% of the market could move outside the regulator’s control. With the industry preparing for harsh affordability and stake limits and further restrictions on marketing, tougher action to clamp down on the black market was a requirement.

The paper has set out a plan for the GC to receive statutory powers (when parliamentary time allows) so they can force internet service providers, payment providers and providers of ancillary services to cease activities with unlicensed businesses targeting the UK. Currently the paper estimates that the black market is only around 2% of total revenue, and also acknowledges that many sites pop up and down quickly, so this will not suddenly generate a healthy bump of revenue back into the regulated market. But it is a step in the right direction, and does offer some protection moving forward.

Fees are going up… GC Fees and research, education and treatment

To fund the extra resource needed to police the licensed and unlicensed UK market, the GC are going to need increased fees and they now intend to have the ability to review and reset these annually. The paper indicates that this may lead to annual raising or lowering of fees that operators pay, but it would be a safe bet to suggest that these will only head in one direction.

The paper also indicates that, following consultation, a new mandatory levy to fund research, education and treatment is required with the ‘aim…to improve the provision of high-quality research on gambling and align treatment services commissioned by the NHS and third sector, ensuring those experiencing gambling-related harms are able to access the treatment and support they need when they need it.’ Further details on how much and when these fees are due to kick-in will come later in 2023.

Cyclickal’s Executive Summary: Dispute resolution and consumer redress

Empowering consumers with a new consumer friendly system… A gambling ombudsman

Currently there are around 2,000 customer complaints per year relating to social responsibility, gambling harm and safer gambling which fall outside the scope of Alternative Dispute Resolution providers. Moving forward the aim is to give consumers a more user-friendly solution and avoid them getting caught up in costly court action with operators.

Initially, the government is asking that the BGC, as the leading industry trade body, puts the foundations in place for this, and is also not making it a statutory requirement. However, the conclusion ends with a very clear warning that if the government is not happy with what it sees, then it will quickly look to legislate.

Key white paper proposals and next steps

Given the heavy reliance on follow up consultations and in some instances a requirement for legislation, below is a summary of the key policy proposals, the proposed method of delivery and a guide to when next steps may commence:

Key policy proposals summary

Policy Proposal: More prescriptive rules on when online operators must check customers’ financial circumstances for signs their losses are harmful. These start with light touch checks at moderate spend levels (we propose £125 net loss within a month or £500 net loss within a year) and escalate to more detailed checks for the highest spenders (we propose £1,000 net loss within a day or £2,000 net loss within 90 days).

Proposed delivery vehicle: Gambling Commission powers

Next steps: Gambling Commission consultation in summer 2023

Policy Proposal: A stake limit for online slots games (which evidence suggests is the highest risk product) bringing them more in line with the land-based sector. Subject to consultation, the limit will be between £2 and £15 per spin, and we will also consult on measures to give greater protections for 18 to 24-year-olds who the evidence suggests may be a particularly vulnerable cohort. This will include options of a £2 limit per stake; a £4 limit per stake; or an approach based on individual risk.

Proposed delivery vehicle: Secondary legislation

Next steps: DCMS consultation in summer 2023

Policy Proposal: Making online games safer by design by reviewing game speeds and removing features which exacerbate risks.

Proposed delivery vehicle: Gambling Commission powers

Next steps: Assessment of initial impact of changes to make online slots safer by design in spring 2023, followed by consultation in summer 2023

Policy Proposal: Subject to trial outcomes, Commission to consult on making data sharing between online operators on high risk customers mandatory for collaborative harm prevention.

Proposed delivery vehicle: Gambling Commission powers

Next steps: Initial trial results expected summer 2023

Policy Proposal: Improvements to player-centric tools. For instance the Commission will consult on increasing the uptake of these tools, including whether it is appropriate to make online deposit limits mandatory or opt-out rather than opt-in.

Proposed delivery vehicle: Gambling Commission powers

Next steps: Gambling Commission consultation in 2023

Policy Proposal: Ensuring that incentives like bonuses and free bets are constructed in a socially responsible manner that does not exacerbate the risk of harm.

Proposed delivery vehicle: Gambling Commission powers

Next steps: Gambling Commission consultation in 2023

Policy Proposal: Strengthen informational messaging including on the risks associated with gambling.

Proposed delivery vehicle: Government

Next steps: Government working group to commence summer 2023

Policy Proposal: The Premier League has agreed to voluntarily end front-of-shirt sponsorships by gambling firms.

Proposed delivery vehicle: Voluntary commitment

Next steps: Implemented from the end of the 25/26 season

Policy Proposal: Reviewing Gambling Commission fees to ensure it has the necessary resources to make more use of data in active enforcement and deliver commitments in this white paper. When Parliamentary time allows we will also give it new powers against the black market and replace the inflexible system of how fees are changed.

Proposed delivery vehicle: DCMS consultation on reviewing fees in 2024

Policy Proposal: Introducing a statutory levy paid by operators in scope directly to the Gambling Commission to fund research, education and treatment of gambling harms.

Proposed delivery vehicle: Secondary legislation

Next steps: DCMS consultation on design and scope in summer 2023

Policy Proposal: A new ombudsman to deal with disputes and provide appropriate redress where a customer suffers losses due to operators’ social responsibility failure.

Proposed delivery vehicle: Voluntary initially, with legislation if needed

Next steps: Process for appointment to commence spring/ summer 2023. We expect the ombudsman to be accepting complaints within a year

Policy Proposal: Working with the sector and closing remaining gaps so that under 18s can do no forms of gambling either online, via fruit machines that pay cash, or on widely accessible scratchcards. Legislation when Parliamentary time allows.

Proposed delivery vehicle: Voluntary action and secondary legislation, followed by primary legislation when Parliamentary time allows.

Next steps: DCMS consultation on secondary legislation on cash pay out machines summer 2023

Policy Proposal: Helping the casino sector through making the rules on machines more consistent, permitting an upper limit of 80 rather than 20 to all casinos which meet rules on size, non gambling space and player protections rather than just a few. Allowing smaller casinos to benefit from more machines on a pro rata basis commensurate with their size, and also permitting sports betting in all casinos rather than just those licensed under the 2005 Act.

Limited change to allow high-end casinos and others transacting with the same group of wealthy overseas visitors to offer credit, subject to protections.

Proposed delivery vehicle: Combination of primary and secondary legislation

Next steps: DCMS consultation on outstanding issues in summer 2023

Policy Proposal: Working with the Gambling Commission to develop specific consultation options for cashless payments on gaming machines, including the player protections that would be required before we remove the prohibition

Proposed delivery vehicle: Secondary legislation and Gambling Commission powers

Next steps: Consultation in summer 2023

Policy Proposal: Relaxing the 80/20 machine rule to 50/50 so there can be an even split between low and medium maximum stake machines.

Proposed delivery vehicle: Secondary legislation

Next steps: DCMS consultation in summer 2023

Policy Proposal: A review of the premises licence fees cap for local authorities. When Parliamentary time allows, aligning the gambling licensing system with that for alcohol by introducing new powers to conduct cumulative impact assessments.

Proposed delivery vehicle: Combination of primary and secondary legislation

Next steps: DCMS consultation in summer 2023

Policy Proposal: Beginning the review of the Horserace Betting Levy to ensure the appropriate level of funding for horse racing is maintained.

Proposed delivery vehicle: Review outcomes will dictate

Next steps: Stakeholder engagement, evidence gathering and analysis spring and summer 2023