Dr Philip Newall writes about the public health impact of gambling, and reflects on the promise of the government’s 2023 gambling White Paper.
On 27 April 2023, the UK Government published its White Paper on gambling – “High stakes: gambling reform for the digital age”. This long-awaited document was the government’s response to the 16,000 pieces of evidence submitted in response to its December 2020 call for evidence.
In common with other White Papers, the key recommendations were not enacted immediately upon publication, but have themselves been subject to a number of public consultations from the relevant government department and the regulator, the Gambling Commission. This has felt to many of us working in the area as a frustratingly slow pace of change.
Given that a year has now passed since the White Paper was published, I am writing to give my independent assessment of some key changes thus far. This blog reflects a public health perspective, which highlights the need to reduce the population’s risk of experiencing harm from gambling. In the well-known ‘cliff analogy’, this is expressed as the need to invest in better fences around a high cliff to prevent people from falling off, compared to the alternative of spending money on ambulances to take people who have fallen off the cliff to hospital.
Incremental changes to products and marketing
There have been wide-ranging changes within the gambling industry, and in comparison, more incremental changes to gambling policy. New technologies have delivered new ways to gamble, including mobile devices, video game loot boxes, and cryptocurrencies. This is not to forget more traditional gambling formats, such as lottery tickets, which are still available in any newsagent, high-street gambling machines, and seaside fruit machines, which are still legal for children to use. Many of these gambling opportunities are marketed aggressively to potential consumers, for example, via the ‘gamblification’ of professional sport, social media marketing, and bingo adverts shown during daytime television.
Online slots were singled out in the White Paper as a particularly high-risk gambling product (with 64 mentions in total). Compared to high-street gambling machines, online slots are faster (2.5 seconds per spin, compared to 20 seconds on a high-street roulette machine), more available (24-hours a day, with remote access), and also result in higher losses per £1 wagered (with slot games taking around 10% of all money bet, compared to 2.7% in high-street roulette machines).
In February 2024 the government announced a £5 maximum stake for online slots, which would reduce to £2 for 18–24-year-olds. Campaigners had been hoping for a £2 maximum stake for everyone, to mirror the £2 maximum stake introduced in 2019 for high-street gambling machines. However, even a £2 maximum stake for everyone would have been at best a small step in public health terms.
The maximum stake for online slots acts only on the highest-risk subset of gamblers using one specific gambling product. The maximum stake does nothing to prevent harm occurring from someone who bets only £1 a spin on online slots, let alone someone who bets throughout a football match via an ‘in-play’ betting app on their phone – another new type of gambling invented in the last 20 years, which shows conceptual similarities with slots-based gambling due to its fast and immersive nature. People who tend to lose the most money from online slots also tend to live in more deprived parts of the country, and their losses occur not by betting larger amounts than other gamblers, but by spending more time gambling.
Reliance on industry to regulate itself
Gambling marketing has seen less government-led action, despite this being one of the aspects of gambling that is visible even to non-gamblers. There are two stated reasons for this, which I discuss below.
The White Paper approvingly mentioned the Premier League’s decision to remove gambling logos from the front of football shirts from August 2026 onwards. While strong self-regulatory action would mean that government regulation is unnecessary, a study published later last year suggested that this particular action would only remove around 7% of all gambling logos from an average Premier League football match, due to the preponderance of gambling logos on pitch-side hoardings and in other locations. This change also does nothing to address gambling marketing in other leagues, such as the Women’s Super League or the Scottish Premier League.
The White Paper also said that there is “little evidence of a causal link” between advertising and harm. However, a letter in Addiction, authored by 53 gambling researchers (myself included), argued that this is because of the methodological difficulties in establishing causality given the tools and datasets available to researchers. What some stakeholders call a lack of evidence of harm, could equally be described as a lack of evidence of safety.
What could a more effective public health approach to gambling look like?
A public health approach to gambling could take many forms, as long as it keeps the main feature of acting on as great a proportion of the overall population of gamblers as possible. Two proposals include maximum speed limits and a centralised payment system.
Maximum stake limits only act on the subset of gamblers betting at above the proposed limit on that specific gambling product. By comparison, policies that act to reduce the speed and ease of gambling work no matter how much or little a gambler is staking, and can be inventively applied to a wide range of gambling products.
While the Gambling Commission has placed a minimum spin time of 2.5 seconds for online slots, this minimum spin time could be increased, which would reduce the speed at which people can gamble. Similar minimums could also be placed in other online casino games, which can be played much faster than their land-based equivalents. Even live sports betting can be made slower than it is now. For example, an Australian Government policy forces live in-play bets to be made via telephone call, instead of via the faster and more immersive interface of a mobile phone app.
While much online gambling revenue is hard to track, the government could take control of this issue by introducing a mandatory centralised payment system for all gambling. Since each high-spending gambler has active accounts with an average of six gambling operators, this would be more effective in tracking and limiting the spending of vulnerable gamblers than the current system where this is the responsibility of gambling operators. This system could also be designed in a way that helps all gamblers to keep track of and limit their spend, which would make it a population-based intervention, and could provide a wealth of data for researchers to build a stronger evidence base on effective ways of preventing gambling harms.
Overall, my view is that the changes in UK gambling policy have been frustratingly slow and overly incremental. The forthcoming changes to online slots will leave most gamblers unaffected, and therefore provide no additional protections for most compared to the current status quo. The same is true for gambling marketing, where the industry has misleadingly framed the methodological difficulties of conducting research as a justification to largely support the status quo – even though this status quo is as unsupported by the ‘evidence’ as any other potential arrangement.
by Philip Newall
Dr Philip Newall is a lecturer at the University of Bristol’s School of Psychological Science, and is a member of the Advisory Board for Safer Gambling – an independent advisory group to the Gambling Commission in Great Britain. This blog was written in a personal capacity.
The SSA was pleased to award Dr Philip Newall the Impact Prize in 2023 for making important contributions to the field of addiction, including to gambling policy discussions.
The opinions expressed in this post reflect the views of the author(s) and do not necessarily represent the opinions or official positions of the SSA.
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