16
Examination of witnesses
James Grimes, Will Prochaska and Dr Raffaello Rossi.
Q1 The Chair: Welcome to today’s meeting, which follows up on the work of the Select Committee on the Social and Economic Impact of the Gambling Industry. The follow-up inquiry will focus specifically on gambling advertising, marketing and sponsorship. Thank you to James Grimes, Will Prochaska and Dr Raffaello Rossi for attending. The session is open to the public, is broadcast live and is subsequently accessible via the parliamentary website. A verbatim transcript will be taken of the evidence and will be put on the parliamentary website. A few days after this session, you will be sent a copy of the transcript to check for its accuracy. It will be helpful if you could advise us of any corrections as quickly as possible. If, after this evidence session, you wish to clarify any points made during your evidence or have any additional points to make, you are welcome to submit supplementary written evidence to us.
As this is the first evidence session in this inquiry, it is a requirement that members of the committee declare their relevant financial interests orally when speaking for the first time, so that they are on the record.
Given that we have got a lot to get through, I am going to ask each witness to introduce themselves briefly, please, and then we will get into the first question.
James Grimes: Good morning, everyone. My name is James Grimes. I am director of Chapter One, which is a gambling harm prevention programme created by the charity Gambling with Lives, which was set up by and supports families bereaved by gambling suicide. I also founded and led the Big Step campaign to end gambling sponsorship in football, and I have lived experience of a gambling addiction.
Will Prochaska: Good morning. My name is Will Prochaska. I lead something called the Coalition to End Gambling Ads, which is a group of organisations committed to campaigning to stop gambling being promoted. We include in our membership 15 councils, including towns and cities such as Blackpool, Sheffield, Bristol and Southampton. We have got the three leading public health institutions in the country in our membership, as well as a range of mental health charities, specialist gambling support services, credit unions, faith groups and sports clubs.
Dr Raffaello Rossi: Good morning. My name is Raffaello Rossi. I am a senior lecturer in marketing at the University of Bristol, and I am co-director of the Bristol Hub for Gambling Harms Research. I have been looking at gambling marketing and its regulations for the past seven or eight years.
Q2 The Chair: Thank you. I will ask the first question. Since the special inquiry committee reported, a growing body of academic evidence has pointed to the risks of gambling advertising. Since that report in 2020, how has gambling advertising developed? Secondly, how are children—under-18s—being exposed to it? Also, I could pre-empt my supplementary, which is about how young men—over 18, but young men—are being affected by it as well, because in other contexts that has been drawn to my and our attention.
Dr Raffaello Rossi: The gambling industry now spends around £2 billion on gambling advertising each year. What has changed over the last couple of years is that they have created this very integral and complicated ecosystem of gambling advertising across digital, sports, media, everywhere. It makes it very pervasive and hard—almost impossible—to escape for both children and adults.
Three things have particularly changed since the last inquiry. The first one is digital. The gambling industry is now mostly investing in digital marketing—on social media, integrated in gaming, loot boxes and streaming platforms. Everywhere online, it is very hard to escape. Resulting from this huge advertising spend and the digital drive—we need to bear in mind that digital is so much cheaper; advertising online is very cheap compared with TV—the volume has exploded. On social media, for example, we did a study in 2021 where we found there were 1 million UK gambling ads being posted in one year on Twitter only. When we looked at the people who engaged with these gambling adverts, we found that two-thirds of them were under the age of 24. The industry has known this for at least five years. It has been published and been passed on to them. Now there is a new study that has just been published by our colleagues Leon and Philip Newall, looking at social media advertising—paid-for advertising. They found that in one year there were 20,000 paid-for gambling ads that had been viewed 2 billion times in the UK, most from BGC members, and around 60% were breaching their own BGC code on targeting people under 25, which was part of the question.[1]
The final point I want to make is also that the content of these ads has changed. Traditionally, it was a lot of “call to action” advertising that you would look at and understand that somebody was selling something to you, but that is not the case any more. It is much more sneaky; it is much more covert. One technique is called content marketing, which makes up around 50% of the organic advertising on social media. The problem is that our research, which included over 400 children and young people, found that it is four times more appealing to children than to adults. Children, as well as young people, do not quite understand that what they are looking at is actually gambling advertising.
Coming to the end of that, I think these three things have changed fundamentally. It is more digital, it is a higher volume, and the formats have changed. As a result of that, the regulations are really struggling to keep up. We are still in the UK relying on self-regulation and that has not worked in that area. We need to create new digitally focused regulations.
James Grimes: I would just like to add something very briefly. I have spent a long time focusing on sponsorship and advertising in football, and I still think that is a priority issue because of how many young people just love our national sport. Things have got a lot worse since this report. There are many more adverts in many more different platforms, as was already mentioned. That has caused this absolute tidal wave of normalisation, where young people associate gambling as being completely safe and harmless fun, without any understanding of the risks involved. We do work with young people, and the voice of young people often never gets heard in these debates. We did an evaluation of our programme, and this young person said to us, “It is so widespread. It is everywhere, anywhere. There will just be adverts. I can go on my phone. It will just show up straight away. You cannot escape it. I think that the Government should 100% be involved”.
Will Prochaska: I agree with everything that has been said by my colleagues. I simply add that I have an additional concern about the convergence of artificial intelligence and adtech and what that will do in terms of the ultra-targeting of people who are particularly susceptible to unaffordable losses on gambling platforms.
Truth be told, people in the third sector, such as me and the regulators, are typically quite a long way behind the gambling sector. I suspect that this is already being deployed very intensively. It is something that the Government need to get ahead of. The solution in this instance and in the targeting of the type of advertising that Raffaello and James mentioned is to end targeted inducements to gamble and to end any targeting of advertising to people based on any of their characteristics, which are identifiable online. That could be done quite quickly and would help the Government get ahead of what will probably happen in terms of the deployment of artificial intelligence and adtech around the gambling system.
Q3 Baroness Garden of Frognal: You partly touched on my question. Based on existing research, what is your current understanding of the links between gambling, advertising and problem gambling among adults and gambling participation by under-18s? You already touched on this, and this is a hugely serious subject.
James Grimes: I will answer this one first because of my lived experience. I think that that is the wrong question. We should not focus so much on whether gambling advertising causes gambling disorders. The question should be: does gambling advertising cause people to gamble? The more people gamble, the more likely they are to experience harm. I think that there would be consensus from evidence and from people with lived experience that obviously, yes, that is the case.
I will answer it in two ways. I start by talking about the lived experience bit of it. This session is not about gambling-related harms, but obviously, we want to restrict gambling advertising to prevent harm. This is a really serious health issue that is impacting a lot of people, especially young people and young men. We know that suicide is one of the biggest killers of young men, and we know that gambling-related suicide makes up approximately 10% of all suicides.
I represent the charity Gambling with Lives. We support families who have been bereaved by gambling-related suicide. So often, the testimonies of the families demonstrate that, for the people who died, marketing played such a fundamental role in what happened to them. I just mention Arthur Soames. Arthur was 18 years-old and started gambling at 18 through football betting on an online gambling site. Arthur took his life at 19 years old. At the time, he received 80 marketing messages from the gambling company. So the question I pose is: did that advertising help a young person who was struggling with gambling in that situation? The answer is no.
If I may, just very quickly, the lived experience bit is really important. There is evidence out there. Studies from last year showed that people who receive less direct marketing were more likely to not gamble, to gamble less and to experience less harm. A study from the World Cup, which is very timely, as the England team are playing tonight, showed that for those watching ITV compared with the BBC—and ITV has gambling adverts—there was a 16% to 24% higher gambling frequency. In summary, gambling advertising works.
Baroness Garden of Frognal: Did the young man lose an awful lot of money in gambling? He was heavily in debt, presumably.
James Grimes: He was not heavily in debt. One of the key things that we say is that gambling harms and gambling addiction are not just about financial loss. Of course, it is a factor, but it is what it does to people’s brains and well-being.
Dr Raffaello Rossi: I will add one more thing. The evidence base is incredibly clear on the link between gambling advertising and participation. We know that the more people participate in gambling, the more harms we have on a public health and societal level. There has been a misleading framing by DCMS, where it required causal evidence—showing a causal link between gambling advertising and harms. I and 31 other leading researchers in this area co-wrote a piece saying that this framing is completely misleading, because it is simply not possible, due to methodological questions.
In medicine, you can literally group people into two groups. One gets the medicine and the other one does not. You can compare who gets better. Most likely, the effect was down to the medicine they took. For marketing, it does not work like that, because marketing is so socially embedded. We cannot isolate single advertising techniques, because there are too many. On an average day, you see it on your phone, you get a push notification, you see it on the billboards and you see it on TV. All these things come together, and we cannot isolate them. That is why we cannot possibly collect this causal evidence, but it does not mean there is no causal evidence or causal link. It just means we, as researchers, cannot create this.
As a final point, the HFSS ban was introduced in January for fast food and unhealthy foods. Causal evidence was not required for the new legislation to come into force. As of January, there has been a watershed ban and no unhealthy food marketing is allowed. So this requirement was not given to food but it was to gambling, which is problematic.
Will Prochaska: Raffaello is right. This question has been created as a diversionary tactic by the gambling sector to resist regulations on gambling advertising: to question the evidence base and the causation, which most of us in society would take as a given. Advertising gets you to use products. If you use gambling products, you have a very high probability of being harmed by them. This is a natural and logical sequence, yet the gambling sector has managed to convince the Department for Culture, Media and Sport to set this unobtainable bar for evidence.
If you want to understand how important gambling advertising is to the gambling sector, you have to look back at the House of Lords committee report, which found that 60% of profits were coming from just 5% of customers. Since that report was published, further evidence came into the public domain that for online gambling, it is 86% of profits from 5% of customers. This is a very top-heavy business model.
This creates a real problem for the gambling sector, not just a public relations problem, because everybody can see it. The public are really fed up with the gambling sector—poll after poll will show you—but it creates a problem for your business bottom line, because if you are dependent on 5% of your customers for almost all your profits, those customers cannot sustain those losses. They are losing unaffordable sums of money, and the gambling sector burns through them very quickly; they will get help to stop gambling or some of them, tragically, will take their own lives.
Lots of them will register with Gamstop, which is the national self-exclusion register. This is for people who have been harmed by the licensed gambling sector in Britain, and you request not to be allowed to be sold services by them any more. There are now, I understand, 700,000 adults in Britain who are on the Gamstop self-exclusion register. That is 1.3% of the adult population who have had to say, “Please do not sell me any more of your services”, which will tell you all you need to know that this is not a normal set of products that are being offered in the market here. This is a very abnormal set of products.
The problem for the gambling sector is, how do you replace the customers that you are losing? It is losing so many customers each year, because they run out of money. It has taken it all from them. That is why the gambling sector spends £2 billion a year on advertising. So, when it comes to tell us that it is actually just to trade customers between different operators, this is not the full truth; the full truth is that they are having to replace the customers that they have burned through.
Q4 Baroness Gill: The 2020 report recommended that we adopt a public health approach to gambling based on the public health approach and existing research. There are three parts to this question. What lessons can be learned from other countries? What policy recommendations would you make for gambling advertising? What would be the impact of any restrictions on the economy and sport?
Dr Raffaello Rossi: In late 2020, we did a study together with Ipsos, looking at gambling advertising regulations across Europe. We focused on five comparable countries, because they recently—in the last 10 years—regulated their gambling marketing: Germany, Belgium, Italy, Spain, the Netherlands and GB. We found that Great Britain is very different in three key areas. We have by far the strongest evidence base on the relationship between gambling, marketing and harms. In the UK, over the past 10 years, we have published around 500 papers on gambling marketing. This is more than Belgium, the Netherlands, Spain and Italy together. The evidence base is incredibly strong. When talking to experts from these countries, they confirmed in the interviews that they use a lot of our research to make points in their own countries, because they think that our research is world-leading.
The interesting thing is that we found that, although we have the strongest evidence base on gambling, marketing and harms, we have the fewest restrictions. Basically, in the UK—well, in GB—there is not a single form of advertising that is banned. We are the only one, from the countries we looked at, where this is the case. In other countries, you have something like sponsorship being banned, or public advertising and posters being banned, or online advertising or TV and radio advertising being banned. Loads of different forms of it are banned but, at the moment, we do not do this whatsoever. We still focus on the content of each ad. I do not think this is working. I am told I cannot really show a figure, because it is really hard for Hansard, but in this figure what you see is red, which means something is banned in most countries, but for GB is green, green, green and green, so we are extremely liberalised.
The final area where we are an outlier—this links to the potential problem of us just allowing every form of marketing—is that every other country that we looked at used legislation to govern gambling marketing, so if you breach advertising regulations, you can be properly prosecuted and fined. In the UK, we do not do this. We still completely rely on self-regulation through the ASA, the Betting and Gaming Council and sports sponsorship. I think these self-regulatory measures do not work and make us a big outlier.
James Grimes: If I may quote the Secretary of State for this topic, when she was on TV on the weekend talking about the social media restrictions, which had not been announced at the time, she said: “The tech companies have had more than enough time to … create products that keep children safe online. If they are not prepared to do that … they lose their right to market their products towards children and I don’t think the Government should be neutral about that”. I wholeheartedly agree. My question would be: is modern-day gambling in its current form safe? The gambling industry has had every opportunity since this report to improve their products and their environments.
Will Prochaska: I would like to add something about a public health approach, which was the framing of the question. I think that is really important. I am not a trained public health doctor, but in the coalition which I run we have got the three leading public health institutions in the country: the Royal Society for Public Health, the Faculty of Public Health, and the Association of Directors of Public Health. They all take the position that gambling should not be promoted, full stop. We also have the WHO, which has weighed in on this, suggesting that we have a public health crisis and that gambling should not be promoted.
I can confidently tell you that if a Government want to pursue a public health approach to gambling, that starts with gambling not being promoted. That is a core tenet of a public health approach. I will come to the economy, because you mentioned that, but the beauty of this policy of restricting gambling advertising, and I think eventually ending gambling advertising entirely, is that it is a bit of a unicorn in terms of policy. It is really popular with the public; it is really good for public health; it costs the Government almost nothing and will actually boost economic growth.
If I can touch on those in turn, the public health argument is clear. If you allow liberal gambling advertising, you end up with an estimated 1.4 million people in Britain, at any given time, who are experiencing problem gambling, with families ruined, high streets ravaged and children who are addicted. This is undoubtedly a public health crisis, so if you reduce gambling advertising and reduce gambling consumption, you would start to rein that in and see a reduction in harm.
In terms of popular public support, poll after poll, including for the Coalition to End Gambling Ads, has shown that a majority of the public would support a ban on gambling advertising and many more would support restrictions. Over 50% of the public think this is the right thing to do; this is not a radical position. In fact, in my lifetime—this was pre 2007, when the 2005 Act came into force—very little gambling advertising was allowed, so I grew up in a Great Britain where you were not bombarded with gambling ads. It is not a radical position to suggest that we should go back to that situation and rein this in.
In terms of economic growth, we have seen lots of studies by the likes of the Social Market Foundation, NERA Economic Consulting and, most recently, by the University of Sheffield, which was published in February this year, suggesting that if you reduced gambling consumption you would boost economic growth. The University of Sheffield found that a 10% reduction in gambling spend would deliver a £1.25 billion boost to the economy and create 22,000 jobs. This is largely because gambling is a very unproductive activity. It has become more and more digital and tech based.
If you are putting £1 into an online slot machine, which is basically a website designed to extract money from you, it has got a very thin supply chain. It really does not add a lot to economic activity; the same is true for the same slot machine on the high street. These are not productive areas of spend. If you remember my statistic about 86% of profit online coming from 5% of customers, you must assume that almost all that money being put into these online slot machines would be spent elsewhere. These are unaffordable losses which are driving profits and if the money were spent anywhere else in the British economy, it would have a much greater multiplier effect. There is a real opportunity here for government to please and protect the public, and to deliver economic growth. It is difficult to understand why, at the moment, they are still questioning the evidence base.
The Chair: Lord Filkin, did you want to come in with a supplementary?
Lord Filkin: No, it has been perfectly answered by that last evidence.
The Chair: We will move on to Lord Foster.
Q5 Lord Foster of Bath: Before I begin talking about the black market, can I put on the record, as appears in my entry in the register, that I receive assistance for my parliamentary work on gambling reform, including as the chair of Peers for Gambling Reform, from the DGA Group—Dentons Global Advisers—the cost of which is met by Mr Derek Webb, who also provides financial support to the Coalition to End Gambling Ads, of which Mr Prochaska is director? I should also say, although there is no financial interest at all, that I am the chair of the charity Action on Gambling and a trustee of it, as is Mr Prochaska.
Thank you very much to our witnesses for coming. What I want to raise with you is that, since our report back in 2020, there has been significant and growing concern about the illegal online gambling market—the black market, as some would call it. What is your assessment of the risks posed by that, compared with the licensed sector? Can you also explain to us what your view is of the effect if we were, for instance, to reduce advertising of the licensed gambling market, as you appear to be calling for? What effect would that have in displacing customers on to the black market?
Will Prochaska: This is a really important topic because, as you say, there has been a lot of noise, largely generated by the licensed gambling sector, about the threat of unlicensed illegal gambling in Britain. We saw similar tactics deployed by various harms industries, most notably tobacco. This may sound familiar to you, because the tobacco sector for a long time said: “Please don’t tax us. Please don’t regulate us, because everyone will go and buy their fags from France”, and we—the public health community—had to overcome those arguments. We see similar arguments deployed by the gambling sector now to try to resist regulation. That does not mean that they are not worthy of investigation. It is really important that we do investigate them and understand how the unlicensed sector is operating, because it is dangerous and a threat to public health in this country, and it is doing a significant amount of advertising, so I am certainly not dismissing it.
The best estimate we have of the size of the unlicensed market—it is difficult to quantify, because it is not as if they offer their revenue statistics to the Office for National Statistics—is that it is about 9% of the online market, which would make it about 4% of the total gambling market in Great Britain. This is not insignificant, but it is certainly not significant enough to dictate government policy on gambling. When you understand the dynamics of the market, though, things get a little more interesting. This is where the siren calls of the gambling sector start to fall away. Research published just a couple of weeks ago by Virve Marionneau and Heather Wardle, two leading academics in this space, found that over 50% of people who use unlicensed casinos in Britain are doing so to avoid self-exclusion.
You will remember that I mentioned Gamstop and the fact that there are, you know, approximately 700,000 people signed up to the self-exclusion register. What that means is that they are unable to gamble on licensed online casinos any more, because a licensed online casino has to check the register before accepting them as a customer. So they want to stop gambling. Of course, that then creates an opportunity for illegal, nefarious actors to try to lure them back in without the safeguards in place, so you see a lot of advertising showing up that explicitly says “Not on Gamstop”. That is the way that they approach people. So, they are clearly telling people who were once addicted to gambling or may still be addicted to gambling, “You can gamble with us without any of the protections that you might have from the licensed sector”. In this way, it is important to understand that the demand for unlicensed casinos has been driven by a licensed sector that has created people who have felt that they have to self-exclude from their products; they have been harmed to a degree that they have to ask them not to sell them to them any more.
It gets more interesting still. A report which I published today, which was reported by Bloomberg, found extensive links between the licensed supply sector and illegal casinos. So, what you have in the gambling market is front-face online gambling operators, which typically do not produce their own games that people become addicted to; they buy those in from games developers, and you have to have a specialist software licence in Britain to be a game developer. We are finding that the games of those licensed suppliers are appearing on the illegal casinos.
We found evidence of the names or games of 18 British licensed software suppliers appearing on two of the most notorious illegal websites. Two of them were licensed by the Gambling Commission after they appeared on those websites, which raised very serious questions as to whether the Gambling Commission is doing effective due diligence before it offers licences in Britain. But if you stand back from it, what you see is that the licensed sector has created the demand for illegal gambling by generating 700,000 people who have had to opt out of their own services, and it appears to be supplying the addictive content back to them through the illegal casinos, all the while crying foul and saying, “Do not overregulate us, otherwise you will push people to the unlicensed market”.
On your final question, Lord Foster, about whether a reduction in advertising would send people to the illegal sector, I reject it entirely. If we were to go all the way for a ban on gambling advertising entirely, we would know that any advert left was an illegal operator and it would help the regulator to spot them pretty quickly. A ban on social media advertising is a very popular suggestion as they, for example Meta’s Facebook, currently carry a lot of adverts for both legal and illegal casinos. But if we were to ban social media advertising, they would not be able to carry either because they would know they were not allowed to advertise gambling full stop. There really are a lot of restrictions that would stop the advertising of both licensed and unlicensed gambling.
Of course, if we were to restrict the amount of licensed gambling advertising, we would start to denormalise gambling in Britain, which is really where we need to get to. This public health crisis needs to be reined in by denormalising gambling. We should not be encouraging the whole population to gamble all the time.
James Grimes: I wholeheartedly agree with that. From a harm perspective, I think the fact that we have 700,000 people on Gamstop just shows how powerful this addiction is and how addictive gambling can be. It is obviously abhorrent that people are trying to get to those people who have made positive steps to stop. But we have had 20 years-plus of the regulated market convincing all of us, especially young people, to gamble, so is it any wonder that we have a generation of people who gamble and feel like they need to gamble by any means?
Going back to the question about international examples, I think this week the Government in the Netherlands have proposed a full ban on gambling advertising. They have implemented really strong restrictions already—stronger than what we have done, by the way—and found that they still were not enough to tackle the exposure to young people. I raise that now because they have said that they can tackle the unlicensed sector at the same time. So, it is possible to reduce gambling advertising while doing things to tackle that, which others might want to talk about because I am not an expert on enforcement.
Dr Raffaello Rossi: I would like to add one point on the evidence basis on the black market. I have to point out that the evidence basis is very strong on the licensed market, but the evidence basis on the black market is, let us say, a bit shady and sometimes a bit dodgy. I have been talking to colleagues in Europe who agree on that. The industry is pushing a lot of data around how many are participating in the black market, the size of it and the harm of it, but the evidence is not up to the standard that we have on the licensed market. Therefore, I would be wary of some of the industry reports out there as they are not very transparent or peer reviewed. It is a different level.
I have one final quick point on the differences with other European countries. As you have said, in many other European countries, gambling advertising is almost entirely banned. On top of that, we have the problem of having so many licensed operators in the UK, which makes us an outlier again. If you look at the public register from the Gambling Commission, there are 2,500 licences and around 800 remote licences. They operate in around 2,000 trade names and brand names. That means that you no longer know what is legal, especially in the online environment, because there is so much out there. It happens to me all the time that I will see an ad I think is clearly breaching the code and I have to look up whether it is regulated or not.
This is a serious problem because there are probably two groups that engage in the black market: the people on the Gamstop list and the people who, potentially, do not know. And how could they know, with the huge amount of advertising out there? I agree that one way to tackle this—potentially the only way, unless we want to drastically reduce the licenses—is to restrict gambling marketing so that the consumer learns very quickly that every gambling advertisement they see is by a black-market operator. That is an argument that has been made in other jurisdictions as well.
Lord Foster of Bath: Can I pick up on a couple of things from what has been said? I welcome the fact that you are all very clear that your concern about gambling advertising from the licensed market should not preclude us taking action against the illegal market. Of course, many of us have seen things like “Not on Gamstop” being advertised, deliberately targeting people who self-excluded. Coming back specifically to Mr Prochaska, from what you said about the evidence you received, you seem to be at least implying—if not stating—that some of those engaged in the licensed market are supplying things to the illegal market. If that is the case, surely their license for the licensed market should be revoked? Am I right?
Will Prochaska: You are right: that is exactly what I am saying. Actually, there was an industry warning notice released by the Gambling Commission in January 2025, stating that the Gambling Commission was aware that some of its licence holders’ games were appearing on illegal websites and stating that the Gambling Commission would be taking tough enforcement action against those suppliers. I am not aware of any enforcement action that has been taken against those suppliers, although I may just have missed it; certainly, the suppliers that we found in our investigation in May and June do not appear to have faced any enforcement action and it appears that their games are all over these two very notorious websites that have been linked to two gambling-related suicides since 2024. The issue could not be more serious, and I think there are very significant questions for the for the regulator to answer.
Lord Foster of Bath: Our next set of witnesses come from the representative body of the licensed industry, the Betting and Gaming Council. Are any of these in membership of the Betting and Gaming Council, which itself claims to be a standards body and so presumably should have investigated this itself?
Will Prochaska: We found the brand names of five members of the Betting and Gaming Council on these two websites, and I personally have played on three games which appear to be provided by those gambling game suppliers. So, there are some very serious questions there for the industry standards body. I think as well, the questions need to extend to the Minister and to the Department for Culture, Media and Sport, which has created an illegal gambling taskforce on which sits the Betting and Gaming Council, despite some of its members apparently having links with illegal gambling operators. Those questions need to be asked rapidly if the illegal gambling taskforce is going to command the confidence of the public.
I realise I did not offer an immediate solution to some of these problems. I think the long-term solution is to end gambling advertising, and we can talk about how that would be phased in and whether it is over three to five years to give sport a chance to adapt. We should start with an end to content marketing, because there is very strong evidence that it appeals most strongly to children.
We should move through to an end to direct marketing because there is very strong evidence that it is particularly harmful. You would then move to an end to gambling sponsorship and marketing of sport—including stopping gambling ads being visible anywhere around the stadium, again to protect children. You would then move to a complete end to all gambling advertising, because a partial solution is only going to be partially effective. As James has said, other countries such as Holland have found that to be the case and have moved to suggest banning gambling advertising altogether.
In the meantime, there are specific enforcement actions that we can take against illegal gambling operators to prevent them from advertising, such as enforcing “know your customer” checks on the advertising supply chain. This would be a piece of secondary legislation that the Treasury could pass. There are regulatory and legislative solutions to this that we could use quite quickly.
Q6 Lord Smith of Hindhead: I declare some interests. I am the chairman of an established society lottery. For this I am unremunerated, but it is worth mentioning because it is significant. I am also the chairman of the Association of Conservative Clubs, which is a very large UK-wide network of private members’ clubs where gaming machines are played. These are category B4 and category B3A—higher than a pub but not like a casino—and small lotteries and bingo are also played as entertainment.
I am very pleased that you mentioned Arthur Soames, Mr Grimes. His father, Jack, is a good friend of mine, so I can see some of the difficulties and the tragedies which are happening first-hand. A range of organisations regulate gambling advertising, including the Committee of Advertising Practice, the Advertising Standards Authority and the Gambling Commission. When I served on the Select Committee on the Social and Economic Impact of the Gambling Industry a while ago, this point was raised. I recall asking why, if we are concerned about young men gambling, they have someone such as Harry Redknapp in the advertising. I was informed that it was okay for Harry Redknapp to be there because he did not particularly appeal to young people. Apologies to Mr Redknapp, but that is what we were told at that time.
Recently, there has been a lot of advertising from Paddy Power with Danny Dyer. Do you think that Danny Dyer is exactly the type of leading “diamond geezer” who will appeal directly to the young men who are probably most at risk of gambling advertising? It seems to me that he would be, so that is a concern. If the different authorities involved in this are not looking at that and not taking those things into account, how effective has the arrangement been in protecting under-18s and young men from exposure to gambling advertising? I do not want to lead the witnesses, but I think the answer is “not at all”.
Who should be responsible for regulating gambling advertising if the current arrangement is not working? I suggest, without leading the witnesses, that it is not working at all. We would be very interested to know your views on whether the current arrangements are working and, if they are not, what should be in place to make them work.
The Chair: Could I ask witnesses not to repeat things that they have said in earlier answers, as we have another question after this?
Dr Raffaello Rossi: I must be quite direct. I have been engaging with the ASA, the CAP and partly the Gambling Commission a lot in the last six or seven years on my gambling marketing work. Being quite blunt, the system is not working at all, especially in protecting young and vulnerable people. I am especially concerned about the ASA’s ability to regulate gambling marketing, especially online. What I have been seeing over the past seven years has been appalling.
One example is content marketing. As of 2019, we have flagged it with the ASA 15 to 20 times. There has been substantial media reporting about the concerns. Lord Foster has raised it in the House of Lords a few times. The evidence is so clear that content marketing is appealing to children. However, the ASA has taken from 2019 until 2025 to put out their first ruling. Until this point, they have just been moving the goalposts, trying to brush it under the carpet, trying to play games. It has been incredibly disappointing. In that time, millions of children have been exposed to millions of strongly appealing gambling ads. This is a very clear fact. The ASA until last year resisted our calls. We were saying, “If you want to find out what appeals to children or young people, you need to talk to them”. They did not want to do that. They talk to adults who then try to judge.
I will give one other example of the failure of the ASA. There has been this incredible loophole. UK licensed operators would have an office registered abroad, in Malta, Gibraltar or whatever. That would mean that all their organic social media advertising, hundreds of thousands of adverts each year, would be completely outside the remit. This loophole was filled in September 2025, when we had been pointing that out since 2019—in meetings, through emails and through Lord Foster of Bath. The ASA has just ignored it. Millions of gambling acts were outside the remit simply because the ASA did not listen to us.
James Grimes: My main point, echoing everything that has been said, is that we should regulate gambling advertising as it exists today. The days of just focusing on TV advertising are gone. I agree that a lot of the people in those TV adverts do appeal to young people, but it is worse than that now. You have gambling companies making the content, making podcasts and working with influencers, YouTubers and celebrities on streamers. All that appeals to young people, so we need to act as it exists today, not as it was 20 years ago.
Lord Smith of Hindhead: The question was: who should be regulating it?
James Grimes: The Gambling Commission.
Will Prochaska: The Secretary of State has powers under the Gambling Act to take action on gambling advertising as he or she sees fit. We need Parliament to set the standards and a statutory regulator to enforce them. The ASA is not a statutory regulator. The Gambling Commission should do it.
Q7 Lord Butler of Brockwell: I have one question and a follow-up. I want to ask about voluntary measures. There are voluntary measures that the advertising industry has taken, such as whistle-to-whistle bans and the codes of conduct. Have these been helpful? Are they effective or are they simply PR measures?
James Grimes: I am going to answer very quickly, but Raffaello has more evidence. If we are measuring effectiveness in terms of reducing exposure, reducing behaviour and reducing harm, the consensus would be no, they have not been effective and voluntary measures and self-regulation have failed.
On the whistle-to-whistle ban, tonight England are playing on ITV. It will not make any difference tonight because it is after 9 pm. There will be gambling adverts before the broadcast, during the broadcast and after the broadcast. It has not reduced exposure. There has also been the football code of conduct, which I think was introduced to stave off government restrictions on gambling advertising. In its first year, 50% of Premier League clubs breached it. We have a situation where under-18s are wearing gambling-sponsored shirts as part of this supposed code of conduct. In short, the answer is no.
Dr Raffaello Rossi: We have been focusing on this through a variety of studies. Looking at the opening weekend of the Premier League, as of 2023 we analysed on each opening weekend all the live broadcast and social media advertising by gambling operators and so on. We also looked at how self-regulation was working. In 2023, we found that there were 11,000 gambling messages during this one weekend of the Premier League. Half a year later came the sponsorship code of conduct, which the Football Association and the Betting and Gaming Council put out to reduce the amount of gambling advertising during sports.
We did it again in 2024, when the code of conduct was in force. The amount of gambling advertising we saw in the opening weekend a year later had tripled to 29,000 gambling ads. You could say that a couple of months was not quite enough time for the industry to adjust. So we did it again last year, one and a half years after the introduction of this new code, for 27,000 gambling ads. If you look at the sponsorship code of conduct, one aim is to limit overall exposure; we found that it has tripled since it was introduced. It aims to restrict sponsorship to UK-licensed operators to avoid black market operators; we found that around 10% of advertising was from the black market.
We think the front of shirt ban coming into force as of September this year will reduce the amount of gambling advertising that we see by only around 9%, which is not really substantial. The whistle-to-whistle ban is an excellent example of how the industry spins regulation to make it sound really good. It says that gambling advertising must not occur from five minutes before the game up until five minutes after the game, but in the fine print it specifies that it is basically for commercials. Of course, there are no commercials during the games. We found 13,000 gambling messages on the hoardings, on the front of players’ shirts and everywhere in the stadium during this supposed whistle-to-whistle ban. One final point on the ASA, which I have made before, is that during a single weekend there have been 370 ads on social media that have all been completely outside its oversight because of this loophole I have pointed out.
After doing this for three years—everything is published completely openly—we have come to the conclusion that the self-regulatory framework is not working whatsoever. We need urgent legislative intervention.
Lord Butler of Brockwell: I just want to ask a question in defence of the industry. Once or twice, you have said that you do not understand why the Government have not acted. Is it not very obvious? Gambling is very popular, there is a vast number of people whom it does not harm and it is a source of employment and revenue. What would you say in answer to that?
Will Prochaska: I would say that the gambling sector is very unpopular. Poll after poll shows that the public demand greater restrictions on the sector. When you list it next to other sectors where the public would like greater action, it comes top of the list, across the political spectrum. Voters on the right and the left feel strongly that the gambling sector needs to be better regulated. The economic case simply does not stack up. If we reduced the amount of gambling in Britain, there would be an economic boon and that would result in greater receipts for the Treasury. Reducing gambling spend would be a boost for the economy, so the economic case does not stack up. From a public health position, it would have enormous benefits.
We are not talking about banning gambling; we are talking about stopping it being promoted—stopping something which is so harmful from being stimulated. With all the damage it is doing, society needs to ask whether this is something that we want to stimulate in our country. The answer is clearly no. There is a very strong case across the areas that you mention for much stronger government action.
Dr Raffaello Rossi: I will just add one tiny point. There is also a question of who owns the gambling legislation, which is DCMS. We know that the industries which profit most from gambling are media, due to massive marketing, sponsorship and advertising agreements, and sports, with these massive agreements on sponsorship. If DCMS restricts gambling, it might harm its other key areas, so there are a lot of questions in this field about whether DCMS is the right space to regulate this or whether it should be somebody like OHID.
James Grimes: Gambling is not what it was. We are not talking about the weekly bet on the horses or a family bookmaker, although some of those things still exist. What we have are really fast-paced and addictive online products, where most of the profit and most of the harm is happening. That is why we need to stop encouraging young people using that through advertising, marketing and sponsorship.
The Chair: Thank you all very much. That was very informative. We will move on to the next panel, but I should remind everybody that we are, in effect, on air during the changeover. Thank you very much for coming.
