Non-remote casino legislative changes
We believe that these proposals will meaningfully reduce harms without disproportionate impacts on the sector’s ability to compete. Our intention is that these measures will directly address the advertising and marketing practices that are most strongly linked to harm. These measures will be in addition to the forthcoming introduction of requirements to not target any direct marketing at those showing strong indicators of risk, as outlined in the Gambling Commission’s requirement 10. For example, a horse racing bettor may wish to receive updates from an operator on the latest odds for upcoming races, but not online slots spins, or a sports bettor may consent to promotional offers around major events, but not want to receive marketing for bingo games.
However, as outlined below, more deprived communities have higher rates of people experiencing problem gambling. When all forms of gambling are considered together, participation is higher among men (57.4% of men surveyed in England between 2012 and 2018 had gambled in the previous 12 months) than women (50.7%). The National Lottery has had a broad customer base since its launch in 1994 and remains the most popular gambling product (see Figure casino not on gamestop 2 below).
The tables below outline current and proposed space requirements for 2005 Act casinos, and 1968 Act casinos which seek to increase their gaming machine entitlement above 20 (including at least one Category B machine). As gaming machine allowances and machine to table ratios for 1968 Act casinos and Small 2005 Act casinos converge, more consistent size requirements should apply across the two types of licence to ensure a degree of fairness and consistency. It was also noted from the call for evidence that where other jurisdictions apply a machine to table ratio, all currently permit a greater proportion of gaming machines in comparison to Great Britain. 1968 Act casinos that are smaller than the configurations of a 2005 Act Small casino but have a gambling area equal to or greater than 280sqm will be able to increase their gaming machine allocations on a pro rata basis commensurate with gambling area. 1968 Act casinos that have a gambling area of at least 500sqm will be eligible for the same number of machines as permitted in a Small 2005 Act casino.
The information that an ombudsman collates can assist the industry in supporting vulnerable consumers whilst also providing feedback to inform processes aimed at reducing detriment. While we do not expect this overall volume of complaints in gambling, especially as complaints to the FOS around businesses’ customer services accounted for over 35,000 cases alone, a significant increase is likely. We understand, however, that the current number of complaints is not necessarily representative of the quantum of complaints, including those regarding social responsibility, that could be received if a single new body or function was created to handle them and consumers had confidence in it. Separate data on the scale of the issues comes from the Gambling Commission’s contact centre, which received 1,305 ‘Safer Gambling tools / customer interaction’ complaints in 2020 to 2021 (15% of total complaints) and 800 in 2021 to 2022 (14% of total complaints). The Independent Betting Adjudication Service (IBAS) is the largest ADR provider in the gambling sector, handling around 80% of ADR disputes. Of the 5% of complaints made directly to operators that go to ADR, it appears that c.6% related to social responsibility failings and therefore fell outside the scope of the existing arrangement.
For this reason, submissions from members of the public which came via 38 Degrees accounted for 94% of all submissions of the Act Review call for evidence by volume. However, where the evidence is pertinent to policy development, suitably anonymised excerpts have been included throughout the white paper. We do not intend to publish in full all of the submissions to the call for evidence as a number of respondents provided information on a confidential basis. Finally, treatment providers, most notably NHS clinicians and third sector gambling treatment specialists, provided 8 submissions. 18 sports and racing bodies provided targeted submissions on aspects of the call for evidence which overlapped with their sport, mainly on advertising and sponsorship. The All Party Betting and Gaming Group did not make a collective submission, but individual members provided evidence independently.
Millions of people enjoy gambling every year – whether that be putting money on a horse, playing at a casino, or a bet on the football – and much of this is now done through smartphones. All casinos we recommend are UKGC-licensed and provide deposit limits, reality checks, cool-off periods and self-exclusion. All casino gambling is a negative-expectation activity — treat it as entertainment, not income. Our checks focus on UKGC licensing, bonus terms, payout information, payment options, game libraries, mobile experience and responsible gambling tools. Cross-operator data-sharing so harm indicators follow the player.
A financial risk model must help protect those vulnerable cohorts for whom even relatively modest gambling losses could be in itself harmful, for example by limiting income available for necessities. The Gambling Commission published a consultation and call for evidence on issues around customer interaction, including preventing harmful or unaffordable losses, in December 2020. The obligations on remote operators to monitor account activity and intervene where individuals display signs of potential harm are a cornerstone of the current package of protections online. While there are real complexities that make it difficult to pinpoint a precise figure, the weight of the evidence suggests that those being harmed by gambling are overrepresented among those with high gambling spend. In responses to our call for evidence, estimates of the Gross Gambling Yield derived from harmful gambling varied significantly, as they have in previous evidence such as that reviewed by the knowledge exchange GREO in 2019, which found estimates range between 15% and 50%. Some submissions pointed out that a reliance on a high spending minority is not unusual in other sectors (such as air travel) and that higher than average spending on gambling is not in itself evidence of harm as discretionary income varies significantly across individuals.
Conversely, a number of think tanks and campaigners have proposed far more expansive SCV solutions, involving the pooling of every customer’s online and potentially offline play data for analysis by an independent public body which flags concerns and directs operator interventions. As part of the trial, codes of practice are being developed to ensure operators respond appropriately when they are notified of customers in this situation. While supportive in principle, industry initially had concerns regarding potential data protection and privacy implications. For example, a person showing signs or disclosing that their gambling is out of control could have their account closed by one operator doing the right thing to prevent harm, but within minutes they could have a new account with a different operator and a ‘blank slate’.
Replacing industry ownership, the Department for Culture, Media and Sport and the Department of Health and Social Care will work together with the Gambling Commission, drawing on public health and social marketing expertise, to establish the most effective messaging and how it should be used. The Online Advertising Programme will explore further mechanisms to reduce harm from advertising across all sectors. Certain types of competitions and prize draws which offer significant prizes such as a luxury home or car now operate online in ways which could not have been foreseen in 2005.
A new approach to safer gambling messaging
We know from the evidence available that while public health campaigns cannot be used as a universal solution to reduce gambling-related harm, with effective targeting they can help raise awareness among target audiences and promote behaviours to mitigate harms. In the shorter term, industry will update the IGRG Code to extend the BGC’s existing commitment of at least 20% of TV and radio ads space being safer gambling focused to all advertising space across online and broadcast media. Once appropriate campaigns and messaging are developed, the Commission will consult on further requirements for gambling operators to engage with and apply the new messaging appropriately alongside product-based information in order to inform and empower consumers. The evidence suggests it would be beneficial to develop systematic messaging, independent from industry, to maximise the information available to consumers and enable them to make informed decisions with a better understanding of the risks. Most respondents, including those within the industry, recognised the need for safer gambling messaging to go beyond a vague ‘play responsibly’ message.
It Is the only form of sports betting not regulated by the UKGC. The Financial Conduct Authority is tasked with regulating spread betting. It is also possible for smaller lotteries to be held without a licence, but these still require registration with the local authority in place. The National Lottery is regulated by the UK Gambling Commission, but there are different legislative components applicable to licensing.
October 2025: deposit limits became a “front door” moment
A further key component of the online advertising landscape is social media, which has been found to have a particular impact on children and young people, and accounts for an increasingly large proportion of their gambling ad exposure. This means it is likely that the minority experiencing serious harm from their gambling are not only seeing more gambling adverts than others, but are also more likely to spend money as a result of seeing them. Evidence submitted by a major charity found that even occasional gambling substantially increased online advertising exposure, with around 40% of those who gambled once a month reportedly being served 4 or more ads a day. Adverts such as TV, radio and online banner ads tend to influence a lower percentage of viewers to begin or increase gambling than those on social media. It is clear that the risks posed by gambling advertising are not uniform across the population, and that people respond to different types of adverts in different ways.
Further information about premises licence fees are outlined in Chapter 5. Therefore, we are consulting on how best to allow casinos to move onto the new regime. If your casino already offers sports betting, what is the GGY from this activity? If this proportion was representative across all casinos, then total casino sector GGY could increase by approximately £1.3 million. The policy could also encourage casinos to invest in broadcasting sport, both in broadcast rights and venue enhancement, which will have additional costs. In practice, venues which include sportsbooks as part of their product offering do not utilise a maximum of 40 — the largest casino by gambling area currently sites 12 terminals.
However, gambling disorder and gambling-related harms are usually attributable to complex interactions between multiple factors. It is important to note that the approach used for gambling will inevitably differ to the approach used for alcohol, not least because of the difference between the licensing objectives for alcohol and for gambling. The findings of a CIA would not remove a licensing authority’s discretion to grant applications for new licences or applications to vary existing licences, where the authority considers this to be appropriate in the light of the individual circumstances of the case. Licensing authorities also have the power to attach licence conditions and remove premises licences if required.
Independent UK casino reviews built on real-money testing, transparent methodology, and editorial integrity. If the operator has breached its licence conditions, report them to the UKGC directly, though the Commission does not arbitrate individual disputes. If unresolved, escalate to the casino’s designated Alternative Dispute Resolution (ADR) provider, which is listed in their terms and conditions.
Over 70% of gaming sessions on a single product type that lasted over 3 hours were on slots, and slots had the highest proportion of players (5.5%) who ever played for longer than three hours. This work will be particularly informed by the Commission’s planned assessment of the changes made to online slots. The Gambling Commission will therefore build on its work on online slot design rules and consider the wider design codes for other online products. Following the Gambling Commission’s work on online slots, we think other products should also be considered with a view towards establishing a coherent system of safer product design standards.
Common ADR providers used by UK casinos include eCOGRA, IBAS (Independent Betting Adjudication Service), and the Gambling Commission’s own ADR scheme. All games offered by UKGC-licensed casinos must be independently tested to ensure fairness. We recommend choosing casinos that offer medium or high protection.
When asked about the impact on GGY from sports betting, all operators stated that this would have either a slight increase or no impact on their overall GGY. It was also highlighted that sportsbooks are a common expectation in casinos in other jurisdictions, and this move would bring Great Britain’s casino experience in line with other countries. The same 12.5% rule that applies in 2005 Act casinos is also proposed to apply for 1968 Act casinos that seek to move onto the new regime. Furthermore, this exemption is tightly drawn to reduce any advantages that these casinos may gain compared to their competitors.
- According to UKGC research, roughly 22% of online gamblers who use credit cards can be classified as problem gamblers.
- Affordability checks are a two-stage system designed to prevent gambling beyond your means.
- However, at this stage we do not know precisely what the GGY benefits will be, as we do not have any evidence on how casinos and players will respond to this proposal.
- Gambling Commission data suggests that at-risk and problem gambling rates among 11 to 16-year-olds have increased since 2014, although significant changes to the survey methodology make year-to-year comparisons difficult.
Opposition tended to come from those who are opposed to any increase in supply of gambling opportunities in land-based premises, while the industry was expectedly supportive. An identical proportion of respondents thought sports betting should be permitted as shouldn’t be permitted in land-based casinos, with a small number selecting ‘I don’t know’. As referenced in our response to the ‘Gaming machine allowance for 1968 Act casinos’ section, we acknowledge concerns from stakeholders about the necessity of a table gaming area requirement given the sliding scale includes a specified number of tables. These products do not count as gaming machines, but neither do they provide any of the benefits of a multiplayer table in contributing to a balanced mix or affording opportunities for social interaction.
The government has already indicated that it intends to examine radical new ways to mainstream and improve ADR across the economy for all types of disputes including consumer disputes, so it is no longer viewed as an ‘alternative’ to court but operates as an integrated part of the justice system. Most submissions called for a gambling ombudsman, though there were significant differences in proposals for how best to design a new system, its remit, powers and the specific details around the desired outcomes of the new arrangements. There may also be particular difficulties if the complainant is vulnerable due to gambling disorder or some other factor. This can be costly, time consuming and potentially inequitable given the resource disparities between the typical complainant and the gambling operator.
We do not currently have sufficient evidence to inform an appropriate percentage increase to the current cap on licensing fees. We believe it is appropriate to increase these fees so that local authorities can cover the costs of their gambling licensing and enforcement activity, and increase activity where needed. They are therefore essential for ensuring that licensing authorities can properly regulate gambling in their areas. Scottish Ministers also have power to set application and annual fees for premises licences, which differ from the fees set out for England and Wales, and are set out in the Gambling (Premises Licence Fees) (Scotland) Regulations 2007.
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