British Horseracing Authority – Written evidence (GAM0065)



  1. The British Horseracing Authority (BHA) – the governing and regulatory body for thoroughbred horseracing in Great Britain – is delighted to respond to the House of Lords Select Committee Inquiry on the Social and Economic Impact of the Gambling industry. This response is being submitted by the BHA on behalf of the wider British racing industry incorporating our racecourses, licenced personnel (including trainers, jockeys and owners) and media rights holders.


  1. British racing is the UK’s second largest sport behind football in respect of attendances, employment and revenues generated annually. In 2018, 5.77 million people attended over 1,500 individual race meetings held across England, Scotland and WalesOur largest events are not only highlights in the increasingly competitive international racing calendar, but also the UK sporting and social calendar. British racing’s cultural significance is demonstrated by the fact that ours is the only sport which has two annual nationwide events – the Grand National and the Derby – which are included on the Group A list of full live coverage protected events for FTA broadcast.


  1. This translates into a significant economic benefit for the UK, with our industry generating £3.45 billion in direct, indirect and associated expenditure annually for the British economy. Much of this is focused in rural areas with over 20,000 people employed across our 59 licensed racecourses, hundreds of training yards and thousands of breeding operations – all of which play a key role in the life of the many hundreds of rural communities they operate in. British racing supports the Government’s wider trading and soft power agenda by encouraging multi-billion-pound investment into the UK, with the Minister for Arts, Tourism and Heritage Rebecca Pow MP recently commenting that:

We welcome the contribution British horseracing makes to the national economy and our quality of life. It is also a significant soft power asset to the UK and enhances the strong bilateral relationships we have with the Gulf States and many other countries around the world.”


British racing and the betting industry


  1. The British racing industry has limited involvement, beyond pool betting, in the operation of betting services in the UK. However, we are an industry which is heavily interlinked with the UK betting sector. Our Fixture List, race programme and many of our Rules are developed in order to provide a consistent, high-quality betting product on which people can gamble responsibly 362 days a year.


  1. British racing works hard via regulation from the BHA to ensure that the sport that takes place on a racecourse – and on which significant betting activity takes place every day in Licensed Betting Offices (LBO) and online – has the highest standards of integrity and fairness. This gives confidence for betting customers that the over 10,000 races which they are responsibly betting on 362 days per year are open and trustworthy gambling opportunities.


  1. Betting activity on horseracing in the UK is growing, showing its continued popularity as a culturally accepted betting product. The latest statistics from the Gambling Commission, for the 12 months prior to September 2018 (as represented in Figure 1), outline that over £14 billion was bet on horseraces in Great Britain at racecourses, in LBOs and online. Online betting now accounts for some 65.6% of turnover, and 50.4% of gross gambling yield on horseracing. This demonstrates that betting patterns now follow the general societal trend of business moving away from retail shops and onto digital platforms.


Figure 1- Turnover and Gross Gambling Yield on horseracing, October 2017 to September 2018

Two pie charts showing the turnover and gross gambling yield on horseracing

Figure 2 – William Hill betting shops where customers collected Cheltenham Festival winnings (William Hill H1 2019 Results)

 Map of the UK showing all the William Hill betting shops where customers collected Cheltenham Festival winnings



















  1. Betting on horseracing is also an intrinsic and social element of a day’s racing – either with on-course betting operators or pool betting services. In June, Ascot Racecourse’s Bet With Ascot pool betting service handled over 577,000 bets from the nearly 300,000 attendees over the five days of the Royal Ascot meeting. The average bet size during the meeting was £13.57 and means that the average amount wagered per attendee at the event was £26.75. From this the Government would have earned significant tax revenue, while the event provided an employment opportunity to 500 members of staff from Bet with Ascot and over 100 on course, independent bookmakers with their own staff. This demonstrates the economic opportunities and benefits which betting activity at a major event Royal Ascot provides.


  1. We are clear that British racing’s relationship with the betting industry is positive for the sport but believe it is also vital that it receives a fair return from betting activity. Our historic relationship with the betting industry has been recognised on numerous occasions by Parliament including through the introduction of the Horserace Betting Levy in the 1960s when betting away from racecourses was first legalised, and most recently in 2017 when it amended the Levy to ensure it captured a return from online betting activity on the sport.


  1. Racing’s symbiotic relationship with the UK betting industry also means that it can be greatly impacted by changes to the wider regulatory environment around gambling. We believe that it is critically important that policymakers are aware of the depth and complexity of these connections as they make future gambling policy. Figure 3 outlines the range of links between the betting industry and elements of the British racing sector.


Figure 3 – Key links between the Racing and Betting industries in the UK

Racing Industry Sector

Link to Bookmakers


Race sponsorship & prize money, for example Ladbrokes recently assuming sponsorship of the King George VI Chase at Kempton Park on Boxing Day; on-course bookmaker pitches; TOTE; course/bookmaker exclusive deals.


Individual sponsorship deals with bookmakers. All deals are registered with the BHA.

Horserace Betting Levy Board

Racing’s central funding body primarily funded by a 10% levy on bookmakers’ gross profits on horse racing. This income totalled £78m in 2018. It allows HBLB to invest money back into the sport through prize money, industry training and equine research. Money also funds the BHA’s raceday services and fixture incentive payments to racecourses for racing at certain times of day.


Working with bookmakers for anti-corruption purposes in the integrity department, mostly by data sharing of any suspicious betting trends. The BHA Intelligence Team then work to try and disrupt any potentially corrupt activity.

Media Companies (RMG, ATR, ITV, SIS)

Betting companies contribute significant sums of money in media rights deals to broadcast racing in their shops & also stream races online. Right holders also receive income from betting adverts during broadcasts.

Attendees and off course TV viewers

On and off course betting activity on racing – in Licensed Betting Offices and online.


  1. British racing is a sport with a strong social conscience. We are acutely aware of the social and economic damage that problem gambling can cause to individuals and communities. As a sport which generates a significant amount of revenues from betting, we keenly recognise our social responsibility and encourage all efforts to reduce problem gambling in the UK. It is important that we as a sport work towards the Government’s ambition for the betting sector of the “right balance between a sector that can grow and contribute to the economy, and one that is socially acceptable and doing all it should to protect consumers and communities.”


  1. We have responded to the questions within this consultation based on ensuring that the Committee has all the evidence it requires relating to aspects of gambling policy affecting British racing. Please note that not all questions are answered as we have only given responses to questions that we felt were relevant to horseracing.


Q1) Are the three primary aims of the Gambling Act 2005 (to prevent gambling from being a source of crime or disorder, to ensure that gambling is conducted in a fair and open way, and to protect children and other vulnerable persons from being harmed or exploited by gambling) being upheld?

  1. British racing is very keen to ensure that racecourse betting environments are places of integrity, and where fair and open gambling takes place. Every bookmaker that operates on a racecourse must act in accordance with the Gambling Commission’s rules, and British racecourses have a zero-tolerance policy on Under-18 betting activity on racecourses. We look forward to continuing to work with the Gambling Commission on ensuring that racecourses are safe environments at which people can gamble fairly and responsibly.


  1. The BHA’s world-leading intelligence department works closely with UK Gambling Commission licensed bookmakers in order to identify, prevent and disrupt any potential betting-related corruption in the sport, which could otherwise undermine people’s faith in British racing as a fair betting product. The BHA uses the ‘Racestraight’ website which provides an anonymous opportunity for anyone in the sport to report corruption.


  1. There is still more that can be done and in our role as a Member of the Sports Betting Group (SBG) which brings together representatives from across sport to provide leadership and share good practice to address the risks from sports betting corruptionwe would like to see further changes to Licence Condition 15.1.2 of the Gambling Commission’s Licence Conditions and Codes of Practice. This would further improve access to information for Sports Governing Bodies such as the BHA in the case of suspicious betting activity.


  1. The 2005 Act introduced regulations for different types of gambling (online sports betting, casino style games, fixed odds betting terminals) but did not differentiate between them. One of the appeals of horseracing is that betting on the sport can almost be considered as a skill and is enjoyed by many as an intellectual challenge, as well as, a leisure activity. Whether you’re a punter who has religiously scanned the form, or a once a year racegoer who picks on names, both have an opportunity to profit from fair and open gambling. The time gaps between races also allow punters to take a much more considered and responsible approach to their betting, reducing the potential for harm.


Q6) What are the social and economic benefits of gambling? How can they be measured and assessed?

  1. It is, in the view of British racing, very important that any assessment of the social and economic benefits of the gambling industry in the UK takes account of the considerable links between the racing and betting industries, and the contribution made by betting activity on the sport to its profile, popularity and £3.45 billion economic impact.


  1. The clearest example of the social and economic benefits of gambling, and how this feeds through to the racing industry, can be demonstrated by the Horserace Betting Levy. The Levy is charged at 10% of a betting operator’s gross profit on British racing. Receipts from the Levy are then distributed in line with three statutory purposes:


  1. The majority of Levy expenditure is reinvested by the Horserace Betting Levy Board (HBLB) for the improvement of horseracing, funding prize money which acts as the lifeblood of the industry – supporting participants, keeping more horses-in-training and improving the popularity of the sport as a socially responsible betting product.


  1. Levy expenditure also funds training, recruitment and retention including the industry’s accredited training centres – the British racing School in Newmarket and the National Horseracing College in Doncaster – and the Careers in Racing team at the BHA which provide pathways into the industry for young people. In 2019, the HBLB contributed £2m in grants towards veterinary research, disease surveillance and improving horse welfare both in and out of racing. More than £35 million has been invested through the Levy in veterinary science since 2000 and helped to make Britain a global beacon of equine veterinary science internationally. HBLB also played a vital role in containing the equine influenza outbreak earlier this year as they provided funding which paid for trainers to swab their horses.


  1. In the coming months, utilising the return from betting activity, British racing has significant plans to further bolster investment in: a range of areas including the mental and physical wellbeing of our participants; equine welfare initiatives including a predictive model to reduce fallers and injuries in Jump racing; and a landmark integrity education programme to provide participants and the public with information on the Rules of Racing and to help prevent participants from inadvertently acting in a manner which contravenes these. All this important investment comes through the Levy and betting activity on the sport. However, this requires stability in income from the Levy and other funding sources which are under increasing pressure as we outline below.


  1. We also work more broadly with betting operators outwith the Levy to generate social good in communities. In March 2019, William Hill and Scottish Racing (which represents Scotland’s five racecourses), announced a partnership with Alzheimer’s Scotland. As part of the year-long initiative, every racecourse in Scotland and 1,600 members of William Hill staff have been trained as ‘dementia friends’ while raising awareness and funds for Alzheimer’s Scotland.



Q10) Is enough being done to provide effective public education about gambling? If not, what more should be done?

  1. British racing is already taking action to try and prevent problem gambling from taking place both on-and-off course and is acutely aware of its responsibility to promote responsible gambling. The Racecourse Associationthe trade body for 59 British racecourses – is partnered with the Gambleaware campaign and aims to raise awareness of responsible gambling through advertising across racecards, on-course advertising and on bookmaker stands.


  1. During live racing broadcasts on ITV and our dedicated racing channelsRacing TV and Sky Sports Racing all gambling adverts will have a responsible gambling message at some point during the advert in order to try and dissuade people from betting beyond their means. Racing’s Free-To-Air (FTA) broadcaster, ITV, have previously partnered up with on the ‘BetRegret’ campaign which included TV spots discouraging ‘bored betting’ around this year’s Cheltenham Festival in March.


  1. We strongly welcome the recent news that five of the UK’s biggest operators (William Hill, Bet365, GVC, Flutter and Sky Betting & Gaming) making large increases to their ‘voluntary contributions’ to provide treatment and support to those suffering with gambling addictions; and support former Secretary of State for Digital, Culture, Media and Sport Jeremy Wright MP’s call for other firms to ‘engage in tacking problem gambling and look at what they can also do to step up’.  In the future, British racing would look to work more closely with betting operators that show serious commitment towards social responsibility and tackling the issue of problem gambling.


Q13) The Responsible Gambling Strategy Board has said that by not taking action to limit the exposure of young people to gambling advertising “we are in danger of inadvertently conducting an uncontrolled social experiment on today’s youth, the outcome of which is uncertain but could be significant.” Do you agree? How should we make decisions about the regulation of gambling advertising? What might be learned from international comparisons?

  1. British racing is in the fortunate position of being one of the major sports in this country that is still broadcast regularly on FTA television, with the current ITV deal running from 2017-2020. As part of the exclusive deal, there are 93 days of racing a year across ITV and ITV4, by far the most FTA coverage of any sport in the UK – allowing our sport to reach millions of households every year.


  1. Gambling advertising, targeted at adults, is a key aspect of the funding model for FTA broadcasting of sport on UK television, generating revenues for broadcasters to allow them to bid for sports rights and ITV Racing is no exception. It is wholly appropriate – provided that responsible gambling messaging is included and that the content and tone of the advert is suitable – for opportunities to bet responsibly on British racing to be advertised during broadcasts of the sport.


  1. Racing’s broadcasters are subject to a comprehensive and binding set of regulatory rules that apply to the content and scheduling of gambling advertising on TV whenever that advertising is broadcast.  In broad terms, these rules are set out in the BCAP Code which broadcasters are obliged to adhere to as an Ofcom license condition, with oversight and enforcement by the ASA and ultimately by Ofcom.  Adherence to these rules is mandatory and, ultimately, broadcasters can face very significant fines from Ofcom for serious or persistent breaches and could ultimately lose their licenses in the most serious circumstances.


  1. The Gambling Industry Code for Socially Responsible Advertising recognises British racing’s ‘inherent links with the gambling industry, which is not the case with other sports’ which means that it is exempt from the new ‘whistle to whistle’ advertising regulations which ban gambling advertisements during sporting events before the watershed. This recognises the historic interdependency between racing and betting, that is reflected in numerous ways including our funding legislation, our fixture list and rules, our appeal as a socially responsible betting product and the excellent broadcasting of the sport.


  1. Given these links, and the measures taken to promote responsible gambling, it is highly questionable whether any further restrictions on advertising of betting around horseracing broadcasts based on protecting under-18s from gambling-related harm would be justified or effective, particularly given the significant impact which this would also have on the finances of British racing.


  1. It is notable that there is international precedent for this position. Since March 2018, a ban on gambling advertisements during live sport in Australia has been in place, but this also includes an exemption around horseracing events. These regulations have been working well to date and demonstrate that the current approach being adopted by the IGRG code is proportionate in reducing the volume of gambling advertising on TV, while not adversely impacting the ability for horseracing to remain on an FTA broadcaster and be enjoyed by millions of people.



Q14) Gambling is becoming an integral part of a growing number of sports, with increasingly close relationships between operators and sports clubs, leagues and broadcasters. What are the risks attached to this?

  1. In its comprehensive 2017 State Aid clearance of reforms to the Horserace Betting Levy, the European Commission stated:

“In the UK, racing and betting have a unique interdependency that goes back over 200 years. A day at the races includes, for most participants, betting on horse races as well.”


  1. Whilst the ‘gamblification’ of other sports may therefore be a more modern trend, the relationship between Racing and Betting in the UK is far deeper rooted and symbiotic than any other sport. As outlined above in Figure 3, the intricacies of the relationship reach almost all elements of the racing and betting industries and has been recognised by successive UK Governments in gambling legislation, including the 2005 Gambling Act and the Horserace Betting Levy. As such, British racing works closely with betting operators across a range of areas to grow socially responsible betting activity on the sport.


  1. Fundamental to this relationship, however, is that there is a fair and sustainable return provided to the horseracing industry from betting activity generated on the sport – recognising the common interest between the racing and betting sectors in a sustainably funded racing industry. After unlocking a statutory return from all online betting operators as a result of The Horserace Betting Levy Regulations 2017, the Levy yielded a return of £94.7 million in 2017-18 (a 90% increase on the year prior). However, this yield reduced again by £16.7 million (18%) to £78 million in 2018-19 despite growing betting activity on the sport as outlined in Figure 1.

Figure 4 – Return from betting in horseracing in 2017 – International comparisons



Great Britain




Total betting activity

€ 15.6bn

€ 5.2bn

€ 9.1bn

$ 17.0bn

Basis of return to racing

10% of Gross Gambling Yield on British racing


Drawn from General Betting Duty – 2% of turnover on all sports

5.6% of turnover return on online betting

Pool betting monopoly in retail

Racefields legislation – Between 1% and 3% of turnover, with higher rate for premium races

Return from racing outwith jurisdiction?





Return to racing

£ 86.3m

€ 64m

€ 792.7m

€ 446.8m

% return to racing






  1. In our view, further reform to the Levy system is required which would deliver much more consistency in terms of the sports income and allow British racing to better plan critical expenditure for the future. Moreover, – in terms of prize money, key metrics, and the basis of the statutory return from betting to racing – we remain behind our major international rivals, which despite the prestige of our bloodstock and racing will put the sport at an increasing disadvantage internationally. The comparison of British racing against fellow international jurisdictions is demonstrated in Figure 4. This comes at a time when, contrary to many other jurisdictions, betting activity on horseracing in the UK is growing rather than declining.


  1. Nonetheless, there are critical projects which are funded in the British racing industry as a result of investment facilitated by a return from betting activity on horseracing. This is a key contribution which the betting industry makes to the funding of the country’s second largest sport, a major industry in the UK rural economy, and a key soft power asset for the UK internationally.



  1. It is our view that British racing has greatly benefitted, both socially and economically, from the liberalised, evidence-based approach towards gambling regulation in the UK since 2005.


  1. British racing is an increasingly popular, socially responsible and culturally accepted form of betting activity that provides enjoyment to millions of people, supports jobs and contributes significantly to rural economies and communities. This impact would not be what it is today without the relationship between racing and betting – which is secured through a sustainable return from betting activity.


  1. Nonetheless, we encourage all betting operators involved in our sport to make efforts to reduce problem gambling and as an industry we are keenly aware of our responsibilities towards promoting and supporting responsible gambling.


  1. As the committee considers the regulatory environment surrounding gambling as part of its Inquiry, we ask that the complexities and specificities of British racing’s relationship with gambling are appropriately considered, allowing British racing to continue to grow and lead the increasingly competitive international racing sector, while supporting rural communities across the country.


6 September 2019