UKGC reveals three-year plan for post-white paper landscape

UK Gambling Commission
Image: Ralf Liebhold/Shutterstock

As the country’s gaming sector prepares for further consultations on a regulatory reform, the UK Gambling Commission has set out six areas for further research and evidence collection.

The regulator unveiled its Evidence Gaps and Priorities programme for 2023-2026 this morning. The programme looks to examine gaps that need to be filled in the evidence around the UK gambling sector to achieve a ‘safer, fairer and crime-free’ industry.

Specifically, the Commission will seek evidence on early gambling experiences and gateway products; the range and variability of gambling experiences; gambling-related harms and vulnerability; the impact of operator practices; product characteristics and risk; and illegal gambling and crime.

“Evidence matters,” Tim Miller, UKGC Executive Director of Research and Policy, asserted. “We all make decisions based on how we understand the world around us, what the evidence is telling us. 

“The bigger the decision and the wider it’s impact, the more likely we all are to want more information before we act. Before the big choices, we all want to fill in the gaps in our understanding. What’s true for us all in our daily lives is just as true for our understanding of gambling.”

Product Risks

In its remit,  the Commission is required to identify new and emerging risks, either from changing consumer behaviours or in relation to industry products. As a regulatory body, it cites the analysis of  product risks and characteristics as one of the industry’s most complex research elements.

To date, existing research has focused on the characteristics of gaming products such as slot games and betting products, highlighting aspects like frequency, audio-visual factors, rewards, information provision, and structural characteristics.

At a user level, research has focused on how individuals interact with different gambling products at various times and their understanding of concepts like probability and randomness.

However, it is recognised that “there is no single homogenous gambling journey”. As such, deeper research is required to analyse product characteristics and whether they increase user risks or experience of potential harms. Product research should include real-time account activity data, survey data, data linkage, or evaluated product trials in live environments.

Questions to determine product risks should cover: understanding if certain product characteristics are associated with gambling-related harms; whether some characteristics disproportionately affect certain types of gamblers; how products can be designed to mitigate risk without compromising enjoyment; and how people’s patterns of play vary between products.

Crime and Illegal Gambling

The Commission’s work related to combating illegal gambling and crime is deemed a key regulatory objective, as factors impact wider society and the Criminal Justice System. 

As an evidence discipline, the Commission seeks to better understand links between gambling and criminal activity, which should be treated separately from crimes committed as a result of gambling harms.

The Commission aims to prevent gambling from becoming a source of crime, disorder, or a support mechanism for crimes impacting society and business such as money laundering, fraud and embezzlement. Research, it noted, should encompass crimes committed in relation to gambling activities, crimes affecting society or gambling operators, and connections between gambling and the criminal justice system.

However, research by the Howard League has uncovered connections between problem gambling and criminal activities, including financial crimes such as fraud and embezzlement.

As such the Commission states that “establishing causality for individual crimes can be difficult when there are many contributory factors or when solely correlational data is available”.

Confronting evidence limitations, the UKGC said it requires deeper research to understand the extent of criminal activity funding gambling, the size and impact of the illegal market, consumer motivations for illegal gambling, and ease of identifying unregulated operators.

Operator practices

Gamblers feel a ‘tension around trust which risks undermining safer gambling messages’, the UKGC asserts, based on its research.

Over the next three years, the Commission has identified the use of detection algorithms to detect consumers at risk of harm as a ‘topic of interest’.

Other areas of focus include the way games function, the location of ‘gambling opportunities’ in-person or through online-choice architecture, and the way information about products is presented.

Again, advertising practices will also come under consideration here after an intense two-year debate around the topic throughout the course of the Gambling Act review.

Specifically, the UKGC wants to determine how directed advertising practices fit into a ‘complex online advertising ecosystem’ and the impact of such marketing on certain groups, particularly those in disadvantaged communities.

The regulator’s objectives in this area are to gain access to operator-held account-level data, conduct research into the role operator practices play in the customer journey and use consumer voice research to see what influences customer trust.

Pathways and gateways

The first focus point for the UKGC is ‘passive influences’ on young people. UK gambling products have a blanket minimum age requirement of 18, recently imposed on society lotteries in the White Paper.

However, there are some similar products which can be used by younger consumers such as coin pusher machines in arcades. The UKGC seeks to examine whether such products can act as a young individual’s ‘first interaction with gambling’.

Esports has again been raised as an area requiring further review. In particular, the UKGC has highlighted video game loot boxes – its policy on this has faced criticism in the past – as a product in need of further research.

The regulator is also interested in how mainstream sports events can influence gambling behaviour at an early age too. For example, one of the suggested questions aims to examine ‘the impact of major betting events’ such as the World Cup and Grand National.

As it stands, the UKGC recognises from its own research that the bulk of gambling activity involving under-16s is informal, such as sweepstakes between family and friends or picking family National Lottery number tickets.

However, the regulator intends to assess if and how this activity ‘normalises’ gambling behaviour among young people. Additionally, although the White Paper had little to say on advertising in comparison to other areas, the Commission still intends to research how marketing adds to the ‘normalisation’ of betting.

Gauging the behavioural range

With over 23 million British consumers gambling at some point in the past four weeks, the scope of some of these people to ‘move in and out’ of harmful betting behaviour is varied, the UKGC asserts.

To better gauge the range of gambling behaviour across the UK market, the Commission hopes to utilise the Gambling Survey for Great Britain to improve its understanding at both the national level and of ‘sub groups’.

Additionally, the regulator aims to further develop its understanding of customer journeys and build up ‘strong foundations’ for future research, such as by establishing recontact samples for longitudinal research.

The Commission’s focus will not just be on gambling-related harm as part of its study of gambling behaviour, however. The report added that the ‘positive consequences’ of betting behaviour will also be examined in its remit.

Understanding of low-risk and high-risk gambling will be an additional focal point, as will deepening the Commission’s knowledge of gambling ‘that can be improved from a regulatory perspective that ensure gambling remains fair and open for everyone’.

Accuracy and Transparency 

Taking on its key evidence themes, the Commission underlined the importance of its approach on the ‘role in delivery’ for the benefit of all UK stakeholders.

Aiming to deliver high-quality accurate evidence across a diverse range of topics, the Commission’s research unit will prioritise data evaluation, transparency on data collection, record keeping and accessibility on how research was conducted. 

The UKGC plans to improve its research and evidence-based principles over the next three years, emphasising transparency and collaboration with the lived-experience community, whilst also strengthening peer review processes, ensuring due diligence, and working with partners to improve all-round evidence gathered on UK gambling.