The GCF write to the UK Statistics Regulator to raise concerns about figures being presented by the Gambling Commission

What are Harms markers and are they working?

The Gamblers Consumer Forum has written to the UK Statistics Regulator to raise concerns about figures being presented by the Gambling Commission around the number of gamblers who will be impacted by proposed affordability checks. The letter reproduced below seeks confirmation that over 1 million accounts will be impacted by having enhanced checks, and requests comment on the methodology behind the statistics used by the Gambling Commission.


We are writing to raise concerns regarding figures being quoted by the Gambling Commission in relation to the number of individual potentially impacted by affordability checks. We believe that given that Government policy is being dictated by these figures, and therefore, it’s exceptionally important that they are presented with context and caveats clearly reported. We would welcome your views as the statistics regulator as to whether it is the case that certain figures are being represented clearly and is a way that does not underestimate potential consequences. 

As you are undoubtedly aware, the Gambling Commission is currently consulting on measures outlined in the Government’s Gambling White Paper. The proposed policy changes are predicated on the premise that ‘only’ 3%’ of betting accounts would be subject to checks. The CEO of the Gambling Commission has made this claim on several occasions most recently in both the CMS Select Committee and in an open letter to Racing Post readers last week. This figure is being used both to assuage opposition to affordability checks, and as a means to promote the concept of ‘frictionless’ checks, despite the fact, based on evidence where affordability checks are already taking place, this is practically impossible.

In the Gambling Commission consultation papers on page 69 (link), a table suggests 600,000 accounts will be subject to checks through binge gambling and 1 million from ‘significant losses over time’. Although many accounts would meet both these criteria simultaneously, could you confirm firstly that you agree that it will be over 1 million accounts subjected to enhanced checks? 

If that is so, then we would welcome further comment on the 3% claim and how the Gambling Commission, and also the Government who take their figures from the Commission, have arrived at such a figure. We believe this figure is being used to privilege a hypothesis that affordability checks will work, despite their unproven track record in combating addiction, and the underlying fact addiction cannot be characterised by losses. We believe the Gambling Commission using figures to bolster an idea they appear already committed to 1) seriously distracts from clinical methods that will tackle addicting, and 2) undermines trust in the democratic process of the consultation regarding affordability checks, currently being undertaken by the Gambling Commission. 

It is our understanding that the 3% figure in question is based on research conducted by the Commission, looking at 5.86 million accounts operated by an unspecified number of operators between May 2020- April 2021. In the same period there were 32 million active online gambling accounts operated by UK licensed operators. The referenced data is sparse, as it just gives the resultant numbers e.g. for Total number of active customers that reached the following net expenditure during any rolling 24hr period. They give for Loss exceeding £1000 that there were 116,880 active customers. The maths then equates to 116,880/5,867,022 = 0.199 = 2%. There does seem to be a difference between the number of active accounts that the Commission give in their industry data, 32,000,000, and what they are using in this calculation where they consider the number in their sample to equate to 19% of the population, so giving a total number of active accounts as (5,867,022/19*100)  30,879,063. The Commission, we understand, have said that there is no reason that player activity found in these accounts, expected to be from the five biggest operators, should be the same for all operators and also state “each expenditure limit should be considered in isolation from the others”.  However, arguably the biggest limitation goes unmentioned, which was that during this time period the country was in a constant state of varying Covid-19 lockdowns restrictions, which will have undoubtedly affected the patterns of online play.  

We would therefore ask if you would consider it was appropriate for the GC to use this period to conduct this research, and had a period such as May 2019-April 2020 been used instead, would have given a more representative picture of gambling spend than a period of impacted by lockdowns, in addition what level of activity on an account should be taking place for it to be considered active for statistical purposes?

The research also does not appear to have considered the fact that many people have multiple accounts. On that basis, would it again be more appropriate to report the number of people impacted as a percentage rather than number of accounts? We would argue that using the latter only serves to reduce the percentage number but give little indication of the number of individuals who will be subject to checks. 

Whilst in part anecdotal, in a recent Racing Post survey of 9000 active bettors, 16.6% have been asked for documentation as part of an affordability check. It is this variance that concerns us regarding the way the Gambling Commission are using statistics as they themselves have stated their concerns about the ‘misuse of statistics’. 

We look forward to your response to our concerns on this matter. 



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