Ipsos MORI, Professor Agnes Nairn and Josh Smith – Written evidence (GAM0069)


  1. This is a submission from Ipsos MORI, Professor Agnes Nairn (University of Bristol) and Josh Smith (Chief Technical Officer, Demos). Our responses to these questions are based on recent research we conducted for GambleAware on the impact of gambling advertising on children, young people and vulnerable adults, which can be found on the following links:
  2. For the purposes of our research children and young people were those aged 11 to 24, and vulnerable adults were defined as people living in constrained economic circumstances, people with limited capacity to understand information, people already experiencing problems with gambling, and people with experience of mental health problems.
  3. The results of the second part of the research will be published later this year, and will include a quantitative survey as well as an effort to indicate the impact of gambling advertising on children, young people and vulnerable adults.

The Gambling Act 2005


  1. 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? Our report shows that there are serious concerns related to gambling advertising, particularly on social media and for eSports bettingOn Twitter, 68% of traditional sports and 74% of eSports adverts were perceived by the researchers to violate at least one of the advertising regulations put in place to protect children and the vulnerable.  Thus, there is evidence that the aim of protecting children is not necessarily being upheld.
  2. Q2: What changes, if any, are required to bring the Act up to date with new technology and the latest knowledge about how gambling harm is distributed? In response to question 2: Ipsos MORI’s synthesis report on the impact of gambling advertising and the report by University of Bristol and Demos on Twitter advertising recommended that new technology could be utilised to minimise the risk of children and young people’s exposure to gambling advertising. Advertising technology exists that can target very specific online profiles with certain advertisements. For example, in our research using avatar[1] technology, both Gala Bingo and GamBan[2] used highly targeted strategies to reach young gambler profiles and those with gambling problems respectively. This same technology could therefore certainly be used to stop gambling adverts being shown to online profiles that appear to belong to children or the vulnerable. It is particularly likely that children, young people and vulnerable groups will be exposed to gambling advertising if they are sports fans. Many adverts were served to the avatars on sports sites and were related to sports/event betting. We recommend that blocking or screening technology should be assiduously applied in the context of sports or eSports.
  3. Q3: Is gambling well regulated, including the licensing regime for both on- and off-shore operations? How successfully do the Gambling Commission, local authorities and others enforce licensing conditions including age verification? What might be learned from comparisons with other regulators and jurisdictions? Our research aimed to examine how well gambling advertising operated as opposed to how well the licencing regime works.  However, as noted above, the advertising regulations are also relevant in this regard as they are designed to protect children and the vulnerable from exposure to enticements to gamble.  We identified many instances in which, in our view, the advertising regulations on gambling had been flouted. This was particularly the case for eSports adverts and on Twitter.  Indeed, 68% of traditional sports gambling adverts and 74% of eSports gambling adverts appeared to violate at least one of the advertising regulations put in place to protect children and the vulnerable. We suggested that the advertising regulators should investigate these instances of poor compliance and beyond this, investigate whether current regulations are fit for purpose. Regulatory breaches identified for attention included:

6.1.                      A core part of the current advertising regulations relates to whether or not particular advertising content has “particular appeal” to children. When this is deemed to be the case, the advert is not allowed. Examples of themes or features that may be deemed to have particular appeal include the use of cartoon characters or animated style, bright colours or depiction of young people (i.e. under the age of 25).  Our research found that children were attracted to a wide variety of themes and features within advertising, for example, humour and contemporary cultural references. These features may appeal to adults as much as to children, but of course does not diminish the appeal to children.  Given this we question whether it makes sense to base regulations on the premise of particular appeal”.

6.2.                      We also recommended that, as eSports is a growing industry, it is important that the Gambling Commission continues to rigorously pursue related betting organisations licensed in Great Britain. Our research estimated that 41,000 UK followers of gambling related accounts were likely to be under 16, and that children make up 17% of followers of accounts focused on eSports gambling.

6.3.                      We also found that there is a need to maintain careful oversight over unlicensed operators online, particularly in relation to eSports. The unlicensed remote eSports betting market requires close scrutiny to ensure that it is not contravening British law by allowing consumers in Great Britain to access its gambling facilities. This is particularly important as the research found evidence of children being exposed to, and interacting with, Twitter accounts advertising unlicensed eSports betting. The regulator should maintain a robust approach in deterring and combating unlawful gambling activities.


  1. Q8 How might we improve the quality and timeliness of research in the UK? What changes, if any, should be made to the current arrangements for funding, commissioning and evaluating research in the UK? What might be learned from international comparisons? The Gambling Commission Advisory Board for Safer Gambling has convened a meeting of academics in the UK on 13th November to address this issue.
  2. Q9 If, as the Responsible Gambling Strategy Board (RGSB)1 has suggested, there is limited evidence on which to base sound decisions about gambling by children and young people, what steps should be taken to rectify this situation? Our research identified a research gap in understanding the motivations and behaviours of 16-18 year olds and, in particular, 17 year olds as they move towards the legal age to gamble. To help address this gap, a longitudinal study would allow for a more robust assessment of the impact of gambling advertising on children and young people, and the impact of gambling more generally.  Disentangling cause and effect is extremely difficult in this type of research, but longitudinal research would increase the robustness of examining this.



  1. Q10 Is enough being done to provide effective public education about gambling? If not, what more should be done? Our research highlighted that more could be done to educate children, young people, their parents and teachers on the risks of gambling. Many participants reported exposure to gambling activity, often in informal settings at a young age, and being encouraged to take part by family and friends, as well as a feeling that gambling had become normalised. Moreover, participants reported mixed understanding of risk and felt more could be done to emphasise the risks of gambling over the sense of enjoyment and fun. Education initiatives therefore could include content for both parents and young people to promote a better understanding of gambling-related harms and risks, and of odds and financial offers stated in marketing.




  1. Q13 The RGSB 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.”2 Do you agree? How should we make decisions about the regulation of gambling advertising? What might be learned from international comparisons? Yes, this was the focus of our research. Our research so far into impact of gambling advertising on children, young people and vulnerable adults provided some evidence for:

10.1.                 It was too early for us to judge the measurable impact of exposure to gambling advertising and marketing on children, young people and vulnerable adults within our Interim Synthesis report. And, indeed, this is a complex measurement to make. However, the qualitative research does suggest that impact should be considered in terms of both short term and long term outcomes. Thus we should consider whether, on the one hand, a particular advert impels an individual to place a bet straight away and/or whether the sheer volume of gambling advertising and marketing normalises and legitimates gambling as an ongoing habit. Though our findings cannot be generalised to a wider population, our primary qualitative research certainly found evidence of individual ads prompting gambling behaviour that hadn’t already been intended or considered by participants. Yet it was also clear that advertising is more nuanced than this. Vakratas and Amber (1999), for example, set out a taxonomy of how advertising works, noting that sometimes (though not very often) the objective of an advert is to elicit direct or sometimes immediate purchase or action. Much more often the impact is indirect, with the advertising intentionally having an effect on beliefs and emotions, which may or may not in time lead to action by the consumer. It is important to consider this when thinking about the regulation of gambling advertising.

10.2.                 These findings will be assessed alongside findings from the forthcoming survey research that considers the role of other factors in influencing gambling attitudes and behaviours. These more complex relationships between advertising and emotions, as well as beliefs and attitudes towards gambling will be explored further in the Full Synthesis report. We are working to publish this report in early 2020, and it may be that the findings from this lead to further suggestions on how we should look to regulate gambling advertising.

10.3.                 It is also worth considering the complex nature of potential impact.


Gambling and sport

  1. 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? Sport is an important context in which exposure to gambling advertising is likely to occur. This was demonstrated in the media analysis section of research by: i) spikes in spend on gambling advertising within traditional media, and spikes in social media activity across key sporting events (such as Cheltenham Gold Cup and the World Cup), ii) by the compounded rate of exposure to sponsorship whilst watching certain live sporting events on TV, and iii) by the prevalence of sports/event betting as the most common form of online advertising within the online avatars’ research. However, we found that this association was not universal across all sports – for example, the sports sponsorship analysis found heavy gambling advertising in boxing and around football where the teams were already sponsored by betting companies, but very few references to gambling within live broadcasting of rugby and tennis sample matches, and no references within Formula 1.

11.1.                 The qualitative research found that gambling was also closely related to sports routines and interests. Awareness of, exposure to and participation in gambling activity increased around watching or attending matches. When watching sport on TV, particularly football, participants noticed the wide variety of types of marketing, including shirt and team sponsorship, pitch-side ads, and adverts during commercial breaks. Many participants felt gambling marketing was omnipresent in sport, particularly within football, including sponsorships of teams, in stadiums and surrounding the pitch. For some, gambling had become embedded within a social routine, and was a regular and important part of the sporting experience: for example, placing accumulator bets ahead of a weekend of fixtures, or betting online or at a match. Gambling within sport was also linked to a perceived sense of skill over luck. A number of sports fans, including those identified as problem gamblers, believed that it was possible to win if you had the relevant knowledge and expertise. Some young people felt there was a pressure to gamble from friends during big events, whilst others felt this was less intense than peer pressure to take part in other activities including consuming alcohol and smoking.

11.2.                 ESports represents the largest growth opportunity for sports gambling and presents a particular worry as its players and spectators are young. 15% of internet users are eSports fans, 38% of fans are aged 16-24 and 1 in 3 are aged 20 to 24.  23% of UK males aged 16-24 have watched eSports in the last month (this compares with 39% in China and 9% in Japan) [3].  Our research on Twitter gambling advertising showed that 74% of eSports gambling adverts were perceived by the researchers to contravene current advertising regulations. In particular, eSports professionals (such as 15 year old Fortnite champion Jaden Ashman) are under 25 and cannot, according to the regulations, appear in gambling adverts. However, this was repeatedly flouted.  ESports take place in fantasy worlds, which use animated styles that appeal to children. Again the regulation not to use content that appeals to children was repeatedly flouted.  Meanwhile, many tournaments take place in China and USA, which results in young people watching and being encouraged to bet late at night in the UK when cognitive defences are depleted.  

11.3.                 Our literature review highlighted young men as a group at particular risk from problem gambling.  This is the group who make up a significant part of the eSports spectator (and therefore potential gambling) market.  This requires particular attention from the regulators.


Gambling by young people and children

  1. Q15 How are new forms of technology, including social media, affecting children’s experiences of gambling? How are these experiences affecting gambling behaviour now, and how might they affect behaviour in the future? As discussed above and in our written reports[4][5], our research showed that children and young people are interacting with gambling online. There was clear evidence of children following and engaging with betting related accounts on Twitter. It was estimated that 41,000 UK followers of gambling related accounts are likely to be under 16, and that children make up 6% of followers of ‘traditional’ gambling related accounts - this rises to 17% of accounts focused on eSports gambling. 28% of those responding to eSports Tweets are children.  And although exposure to gambling advertising didn’t always translate into reported engagement in the qualitative research, there is likely to be wider impact in terms of raising awareness of and normalising gambling.


6 September 2019

[1]   Online avatars are created using Audience Panel Simulation’, which generates users that are referred to as avatars. Each of these avatars had a specific personality. These personalities were developed through normal browsing activity, akin to the behaviours of a real online user.

[2] N.B This is not a gambling company but is a tool designed to block gambling adverts online and in apps

[3] https://cdn2.hubspot.net/hubfs/304927/Downloads/ESports-report.pdf?t=1528372092399

[4] https://about.gambleaware.org/media/1965/17-067097-01-gambleaware_interim-synthesis-report_090719_final.pdf

[5] 067097-01-gambleaware_interim-synthesis-report_090719_final.pdf