The white paper – Proposals to update UK gambling legislation (IV)

We continue to publish extensive extracts from an important project subject to public debate by the British Government, the so-called White Paper.

By Dan Iliovici, Vice-President ROMBET

Benefits of gambling

Gambling can be sociable, can help tackle loneliness and isolation, can enhance the enjoyment of other activities, and can be a valuable pastime in its own right, although quantifying these benefits is inherently difficult.
There are also economic benefits to having a well regulated industry to service this demand.
The gambling sector also contributes significantly to other industries, including sport, advertising and racing. (…)
Gambling can also contribute to tourism, for instance to seaside towns across the country, or high-end casinos attracting wealthy overseas visitors who spend across a number of other sectors while in this country.
Additionally, some gambling products enable charities and other non-commercial organisations such as sports clubs to raise valuable funds. ”

After this clarification, we continue the detailed presentation of the document.

Chapter 1: Online protections – players and products

1.1 The current position

1. The online gambling landscape now is very different to the one which existed in 2005. Online gambling overtook land-based gambling by Gross Gambling Yield (‘GGY’) – the total value of funds staked minus any winnings or prizes paid out – in September 2019 and continues to grow. In the year to December 2022, 18.6% of British adults had gambled online in the last four weeks, excluding National Lottery products, compared to 14.4% in the year to December 2018. This has largely been driven by a channel shift from landbased gambling, where participation has fallen from 24.7% to 19.5% of adults in the same period (excluding the National Lottery). While the lasting impacts of the COVID-19 pandemic remain to be seen, it seems likely that the shift towards online participation, as we have seen in many other sectors, will continue.

2. Perhaps more significant change has occurred underneath this wider channel shift, as new technologies have also reshaped where, when and how people gamble online. In 2015, just 23% of online gamblers had used a mobile phone to gamble online in the previous 4 weeks, compared to 50% in 2020. Online gamblers can now gamble at any time and in any location they choose, and while online gambling from home remains the most popular choice, in 2020 1 in 5 had done so outside the home.

3. Technological change has also enabled innovation in both the betting and gaming product offer. For betting, this has predominantly entailed increased betting opportunities. Not only is there an unprecedented variety of international sports and fixtures to bet on, ‘in-play’ betting (while an event is taking place), ‘request a bet/ build a bet’ (where gamblers pick their own combination of outcomes to wager on) and peer to peer betting exchanges are now widely and frictionlessly used, having been in their infancy or non-existent in 2005. Online gaming products too have changed as the sector has matured, with rapid, stimulating and intense random number generator powered games like online slots becoming increasingly popular and making up a larger portion of operator profits over time. Further change is inevitable.

4. While all gambling carries a risk of harm, there are warning signs that aspects of online gambling in its current form are associated with particular risks for consumers, including the 24/7 accessibility via mobile devices; the ease of access to funds and use of digital monies; the ability to gamble without some element of direct human supervision, including when intoxicated; and the immersive nature of online activities in general. According to the 2018 Health Survey for England1, excluding National Lottery draws, 4.2% of people accessing any online gambling were experiencing problem gambling, compared to 1.3% of people accessing any gambling activity. These trends have also been identified in evidence highlighted by PHE2. While drawing on predominantly cross-sectional evidence from multiple jurisdictions, a metaanalysis of research around the risk factors for harmful gambling3 found that ‘internet gambling’ had the strongest association with problem gambling, exceeding any other product type and various demographic or socioeconomic factors. Online gambling is also increasingly flagged by individuals accessing treatment or support services: in 2021/22 around 75% of patients of the National Gambling Treatment Service across Great Britain primarily gambled online, and 84% of GamCare helpline callers mentioned online gambling against 30% for offline.

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5. Some academics, treatment providers and groups with personal experience have also argued the environment of online gambling and certain structural characteristics of online products are inherently risky for all customers, and particularly for those who are otherwise vulnerable. For example, 40% of online gamblers who had experienced mental health problems agreed they did not feel like they were spending real money online, compared to 26% of those with no experience of mental health problems. We also received evidence from charities that people facing challenges like social isolation or cognitive dysfunction (such as following a brain injury) could be particularly attracted to remote gambling opportunities and fail to understand or properly assess the risks.

6. However, the online environment also provides many opportunities to make sure people are gambling safely. All online play is account-based, and recent years have seen significant strides in the development of harm detection algorithms which monitor every aspect of a customer’s gambling to spot signs of risk and trigger interventions without human input. Equally, customers can be easily empowered with a range of tools like financial limits which are inherently harder to implement offline.

7. Our vision for remote gambling is that the risks are mitigated, and that we maximise the use of technology and data to protect people in a targeted way at all stages of the customer journey. The proposals outlined will deliver:

● New account level protections to make sure operators are adequately protecting all online gamblers

● Measures to make online products safer by design, including controls on structural characteristics like speed and stake

● Steps to empower all online gambling customers to understand and control their gambling

● A new approach to specific issues which are part of the changing landscape in the ever-innovating online gambling environment.

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1. https://digital.nhs.uk/data-and-information/publications/statistical/healthsurvey-for-england/2018/health-surveyfor-england-2018-supplementary-analysison-gambling

2. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1020749/Gambling_risk_factors.pdf#page=107

3. https://onlinelibrary.wiley.com/doi/full/10.1111/add.15449

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