Written evidence from UKRI Gambling Harms Research UK Evidence Centre (GAM0003)

We are delighted to present our submission to the House of Lords Liaison Committee on the regulation of gambling advertising, marketing and sponsorship. This submission has been prepared by the Gambling Harms Research UK Evidence Centre. The Evidence Centre is part of the UKRI Research Programme on Gambling, funded through the statutory gambling levy. The contributions below reflect the views of the academic experts within the Evidence Centre but do not necessarily represent the views of UKRI or the Gambling Levy Programme Board.

The Evidence Centre aims to catalyse a world‑leading, collaborative research ecosystem that delivers high‑impact evidence to understand and ultimately address gambling harms. The Evidence Centre is led by Professor Heather Wardle, and includes experts such as Professor Simon Dymond, Dr Daria Ukhova, Dr Virve Marionneau, Dr Ellen McGrane, Professor John Holmes, Professor Chris Bunn, Professor Gerda Reith, Professor Jo Neale and Centre Collaborators like Dr Ross Gordon. In preparing this submission, we have drawn on expertise across the Gambling Harm Research UK network. This network includes advisors with expertise in gambling harms and harm prevention policy research from across the social and behavioural sciences, including sociology, public health, psychology, and social marketing. Centre members also have an extensive track record in international comparative gambling policy research, including on gambling advertisement, marketing, and sponsorship.

Our submission is based on our own programme of research in these fields that has been funded by the ESRC, Wellcome Trust, and the Academic Forum for the Study of Gambling, as well as the extant body of research evidence. We address the questions relevant to our expertise below.

To contextualise our response, we begin by comparing gambling advertising regulation in Britain with that of other European countries.

Compared with other European countries, Great Britain maintains one of the most permissive regulatory regimes for advertising, as evidenced in a recent review comparing gambling advertising regulations across Europe (Marionneau et al., 2026) (N=30 jurisdictions). Based on a comparison of jurisdictions across eight different regulatory domains (advertising content, target audiences, channels/media, times, objects of advertising, sponsorship arrangements, online advertising, harm prevention measures), Great Britain was classified as having few overall restrictions on gambling advertising, particularly in comparison to other Western European countries (see Figure 1). The review focused on binding regulations and excluded industry self-regulatory documents. Comparatively, Great Britain had weaker binding regulations on the times and media of advertising, no binding regulations on sponsorship, and few regulations on bonuses or direct marketing. Great Britain was also one of only a few countries that did not mandate any harm prevention messaging on advertising (warning message, age limit, helpline information, or similar). Existing responsible gambling messages are based on industry codes rather than enforceable regulation.

Figure 1: Regulatory approaches to gambling advertising in Europe (based on Marionneau et al., 2026)

Similarly, a report by Ipsos MORI and the University of Bristol found that Britain has by far the largest evidence base on gambling marketing harms, more than Belgium, the Netherlands, Italy and Spain combined, yet the fewest restrictions of any comparator (Wilson et al., 2024). The authors noted that advertising and marketing reform had been enacted in countries like Spain, Italy, and the Netherlands via primary legislation on public health grounds and identified political will as the primary driver. In all cases, the presence or absence of direct causal evidence was not a decisive issue within the decision-making on this issue. The authors noted that meaningful change is unlikely to come from further evidence but from the political will to legislate.

Taken together, this evidence indicates that international trends are moving towards statutory, comprehensive frameworks for regulating gambling advertising, rather than the voluntary, industry-led self-regulation that predominates in Great Britain (see also Ukhova et al., 2025).

For the remainder of this submission, we list the questions provided by the House of Lords Select Committee and our response to them.

Written evidence questions for academics and public health experts

Research

1)    The 2020 special inquiry committee recommended that the Government “commission independent research to establish the links between gambling advertising and gambling related harm for both adults and children”.1 As of May 2026, how clear is the evidence of a causal link between gambling advertising by licensed operators (in all its forms) and: 

1.   increased gambling participation by adults; 

2. increased incidence of problem gambling amongst adults; and, 

3.   increased gambling participation by under-18s? 

Response: To our knowledge, little independent academic research has been commissioned directly by government on this issue. The second part of this question deals with issues around causal inference, which we discuss in detail below.

2)    In July 2025, the Government stated that “more high-quality research on the impacts of gambling advertising is needed and there are a range of evidence gaps that need to be addressed”.[1]

1. What evidence gaps are there and to what extent is this characterisation of the evidence base justified? 

Response: As stated above, Wilson et al (2024) found that Great Britain, out of five comparator countries, had the largest evidence base on gambling marketing harms.   On the central question, whether advertising exposure is associated with behaviour, the evidence is settled. Several reviews of the literature (Bouguettaya et al., 2020; McGrane et al., 2023; Mcgrane, Pryce, Moore, et al., 2025) have identified a substantial body of evidence demonstrating a consistent association between various forms of gambling advertising and increased gambling behaviour across a range of measures, particularly among individuals at greater risk of gambling-related harm. Findings from longitudinal, experimental or natural experimental designs support the positive association between gambling advertising and gambling behaviour observed in the wider literature (Roderique et al., 2020; Mcgrane et al., 2026; Rockloff et al., 2026).

There is also a wide-ranging evidence base demonstrating that increased gambling consumption is associated with increased risk of gambling harms (Hodgins et al., 2023; Kesaite, Wardle and Rossow, 2023; Rochester and Cunningham, 2023; Rossow et al., 2025).

The genuine evidence gaps are narrow and specific, rather than foundational, as summarised below:

1. There is a near absence of evaluations of gambling advertising policies after their implementation. The limited evidence base reflects a lack of available data to support policy evaluation rather than a methodological deficiency in the field. One notable exception is a study conducted in Spain (Aonso-diego et al., 2025), which examined the effects of a broader policy change that included restrictions on advertising and found a statistically significant decreases in the number of new accounts and total money bet on gambling. The restrictions had also reduced the total advertising budgets of gambling operators. The study illustrates the value of evaluating policy interventions using routinely collected population-level data.
2. The evidence base is geographically concentrated. For example, 16 of the 22 studies included in McGrane and colleagues’ 2025 review (Mcgrane, Pryce, Moore, et al., 2025) were conducted in Australia, though as noted by Wilson et al (2024), out of five European Countries, Great Britain is characterised as having a largest evidence base.
3. Comparatively little research has examined children and young adults, or inducements as distinct from general advertising exposure.
4. Much of the quantitative evidence remains correlational. The shortage of prospective longitudinal research is notable compared with cognate public-health fields. In tobacco and alcohol research, substantial bodies of cohort evidence have followed individuals over time and found that greater marketing exposure predicts subsequent initiation and consumption (Anderson et al., 2009; Gordon, Mackintosh and Moodie, 2010; Lovato, Watts and Lf, 2011). Gambling research has not yet developed a comparable longitudinal evidence base.

Related to point 1, an important route to strengthening the evidence base is piloting, trialling and evaluating different policy approaches, rather than postponing action until definitive evidence becomes available. This method is used in other cognate policy fields.

This could involve piloting policies prior to wider rollout or incorporating sunset clauses, whereby policies are implemented for a fixed period and subject to evaluation before requiring a positive parliamentary vote to remain in force. Modern evaluation approaches enable robust assessment of policy impacts even when experimental conditions are not feasible, drawing on methods developed for complex interventions and natural experiments (Skivington et al., 2021; Craig et al., 2025).

A useful example is the introduction of Minimum Unit Pricing (MUP) for alcohol in Scotland. Although the policy was supported by indirect evidence, it had not previously been implemented at a national level. The legislation therefore included both a five-year sunset clause and a statutory requirement for evaluation. The resulting evaluation programme was extensive, well-resourced, and methodologically rigorous (Public Health Scotland, 2023; Clay et al., 2025), providing the evidence required for the Scottish Parliament to make an informed decision on whether the policy should continue beyond the initial five-year period.

Similar approaches could strengthen the evidence base for gambling policy. Effective implementation of evidence-based evaluation would require continued investment in gambling data infrastructure to improve access to comprehensive, high-quality gambling data.

2. What methodological problems are associated with definitively establishing a causal link in the above areas?

Response: The scientific methods best suited to establishing causality pose deep challenges when applied to social sciences more widely and to gambling research specifically. Within sciences, causation is most securely tested through controlled, often laboratory-based experiments. However, no experiment can accurately or ethically reproduce the experience of being exposed to, and influenced by, gambling advertising across everyday life or of gambling in a real-world context.

Instead, social science disciplines tend to rely on a range of other metrics to understand and determine the likelihood of causal relationships. This includes multiple criteria such as observing strong statistical relationships that are consistent over space and time and which remain when other variables are taken into account; temporal evidence providing insight that experience of or exposure to one element is associated with the subsequent outcome; that increased experience or exposure leads to increased experience of subsequent outcomes (dose/response relationships). In addition, use of natural experiment data can also help understand casual relationships. In this context, establishing casual relationships is rarely definitive but through a series of synthesised research evidence can be examined for high likelihood or probability (Hill, 1965).

There are certain methodological advancements which would enhance our ability to examine causal relationships within gambling advertising studies. These include:

• Access to operator data, which are inherently longitudinal in nature, and routinely collect information on a) marketing offers sent and b) resulting consumption patterns. Unlike other countries (cf, The Netherlands, Switzerland (Ukhova et al., 2023)), researchers in the UK have no routine right of access to these important sources of data. We would strongly recommend the implementation of a statutory framework requiring licensed operators to provide suitably anonymised data for approved independent research, subject to clear safeguards for privacy, commercial confidentiality, and research independence, as is the case in several European countries, including the Netherlands and Switzerland
• Development of prospective longitudinal cohort studies to track real-world exposure against later behaviour over time.

Finally, exposure occurs across a wider marketing mix, including sponsorship, inducements, direct marketing and social-media content, making it difficult to isolate the effect of any single form of advertising. However, research in the alcohol field has shown that it is possible and useful to measure exposure across multiple marketing channels and examine its relationship with subsequent consumption (Gordon, Mackintosh and Moodie, 2010). Gambling research similarly needs to examine the cumulative and potentially reinforcing effects of the wider marketing mix rather than treating each channel (i.e., sponsorship) in isolation.

Despite these constraints, the application of increasingly robust research designs has continued to yield evidence consistent with the conclusion that gambling advertising is associated with increased gambling behaviour (Torrance et al., 2021; Mcgrane et al., 2026; Rockloff et al., 2026). The evidence gaps noted reflect methodological and data-access obstacles rather than any demonstrated absence of effect. Comparable evidence supporting the competing claim that gambling advertising is not harmful has not been produced. This asymmetry in evidentiary standards was highlighted in a letter co-authored by more than 50 gambling researchers (Newall et al., 2023).

3. Can further research, such as the use of different techniques or larger samples, overcome these barriers to provide policymakers with meaningful further insight?

Response: Yes, in part, though further research is better understood as refining what is already known rather than overcoming the barriers to establishing causation outright. Some barriers to research can be partially addressed. Ecological momentary assessment, already applied to gambling advertising in Australia (Russell et al., 2018; Browne et al., 2019; Rockloff et al., 2026), improves on the limited ecological validity of laboratory studies by capturing exposure and response as they occur in daily life. And while the individual-level longitudinal data needed for direct tracking remain largely inaccessible (see response to Q1b on how this could be addressed with reference to operator data), jurisdictions that introduce comprehensive bans generate population-level natural experiments, allowing harm indicators to be compared before and after a defined regulatory change, such as the study conducted in Spain (Aonso-Diego, García-pérez and Krotter, 2025). 

Evaluation evidence from other settings demonstrates that such evaluations can be conducted using large and detailed datasets when available. For example, restrictions on advertising products high in fat, salt and sugar (HFSS) across the Transport for London network were associated with a relative reduction in household purchases of HFSS products compared with a constructed control region, reflecting a slowing in the growth of HFSS purchases (Yau et al., 2022). A commitment to such evaluations, alongside access to larger and more granular data on gambling behaviour, may permit similar evaluations of gambling advertising policies in the future.

Larger samples improve precision but do not create an unexposed comparison group where one does not exist. In the absence of better data, the realistic contribution of further research will be to clarify which formats and populations are most affected and the pathways linking exposure to harm.

4. Is the Government justified in awaiting the outcome of further research before proceeding with policy action?

Response: Our opinion, based on known evidence to date and the stated benefits action could bring through enhanced evaluation opportunities, is that this is not justified.

The relationship between gambling marketing and gambling behaviour is already supported by a consistent body of evidence across systematic reviews, experimental studies, and emerging natural-experimental research. Drawing on Spanish operator data, García-Pérez and colleagues (Garcia-Perez, Krotter and Aonso-Diego, 2024) found that for every €1 operators spent on bonus inducements, players deposited €1.60, and for every €1 spent on sponsorship, players deposited €4, a dynamic unlikely to differ materially in Britain.

Policy action is also necessary to generate stronger evidence (see response to Q1a). Research should accordingly focus on evaluating the impact of changing advertising, which in turn, can be used to shape comprehensive action rather than to postpone it. The more useful question is not whether the Government should wait for every evidential uncertainty to be resolved, but how proportionate measures can be implemented now, independently evaluated and refined in light of emerging evidence.

International comparisons:

3)    In a Westminster Hall debate on 23 April 2026, the Government stated that the UK should be “guided by the lessons that [other] jurisdictions offer, and we should consider what has and has not worked.”[2]

1. How does the regulation of gambling advertising in Great Britain compare with the approach taken by comparable international jurisdictions in Europe and elsewhere?

Response: As previously noted, Great Britain has one of the most permissive gambling advertising regimes among comparable European jurisdictions (Marionneau et al., 2026). It has relatively few binding restrictions on advertising times and media, sponsorship, bonuses, direct marketing and mandatory harm-prevention messaging (Marionneau et al., 2026)

A key difference is that Great Britain continues to rely heavily on self-regulatory codes, often co-developed with the industry, whereas a number of other jurisdictions have introduced broader statutory restrictions on public-health grounds (Wilson et al., 2024; Ukhova et al., 2025). The main lesson from these comparisons is the need for a more comprehensive and legally enforceable framework.

Safer gambling messaging

4)    Would an increase in the proportion of gambling adverts containing safer gambling messaging, or improvements in the form of this messaging, contribute to a reduction in gambling-related harm?

Response: Yes, but only marginally, and not as a standalone solution. Research evidence suggests that the safer gambling messaging currently carried by British adverts may be ineffective at best and counterproductive at worst. For example Newall et al (2025) showed that industry safer gambling adverts can actually increase viewers' urges to gamble, because they carry operator branding and imagery that is indistinguishable from ordinary advertising. Similar results have been reported in other countries (Jääskeläinen and Marionneau, 2025).

Better-designed messaging is more promising. The DHSC has invited evidence to support independently designed safer gambling messages, and Newall, Torrance and colleagues (Newall, Torrance, et al., 2023; Newall, Weiss-cohen, Petrovskaya, et al., 2025; Newall et al., 2026; Spicer et al., 2026) have produced strong evidence for a range of such messages across different message types and audiences. Increasing the proportion of adverts carrying messaging and improving its form would offer advance the current position. However, the effect is likely to be small, as no message can compete with the roughly £2 billion spent each year on advertising by the industry (estimates provided by WARC, widely reported across industry and national press). Improved messaging should be treated as a modest complement to wider regulatory reform rather than a substitute for it.

Advertising in sport

5)    Have self-regulatory measures reduced exposure to gambling advertisements during live sports programmes?

Response: No, not meaningfully. Torrance et al (2023) quantified gambling marketing in English Premier League broadcasts. Across ten matches from the 2022/23 season, gambling-associated logos appeared on average 16 times every broadcast minute, roughly once every four seconds. Only 6.9% of these were front-of-shirt sponsorships, the single category the the Premier League's voluntary ban will capture once implemented from August 2026, while the remaining 93.1% appeared in other in-game locations such as pitch-side hoardings not subject to the ban. The voluntary Premier League ban on front-of-shirt sponsorships will apply to roughly 1 in 20 gambling logos visible during a match. Subsequent analyses by Rossi et al (2023) confirmed these findings and suggested that gambling marketing in and around UK live sports is increasing. On this evidence, it is unlikely that this self-regulatory measure will reduce exposure during live sport. Rather it will remove a small and conspicuous fraction while the bulk continues.

Additionally, the broadcast ‘whistle-to-whistle’ ban is a limited intervention aimed at reducing gambling advertising during live sports, but evidence suggests its impact may be confined to the restricted window (Mcgrane, Pryce, Wilson, et al., 2025). While the ‘whistle-to-whistle’ ban reduces the frequency of television advertising to an extent, it does not eliminate it overall, with potential displacement into pre-match and other adjacent programming (Mcgrane, Pryce, Field, et al., 2025; Mcgrane, Pryce, Wilson, et al., 2025).

Live sports programming is the only carve-out from the broader self-regulatory watershed restriction. As a result, adverts continue to appear before and after matches, as well as through other unrestricted exposure formats during live coverage, which are highly prevalent (see above). To our knowledge, there is no evidence to suggest that this period of pre and post-match programming is inherently lower risk than within match programming in terms of advertising impact, particularly given the continued presence of multiple forms of marketing exposure. Evidence from the 2022 FIFA World Cup indicates that the presence of television gambling advertising was associated with increased likelihood and frequency of football betting among a sample of male bettors, suggesting the restriction may be insufficient to mitigate behavioural impacts of television advertising around live sport in at least some higher-risk subgroups (Mcgrane et al., 2026). 

6)    In light of developments since 2020, what would be the advantages and disadvantages of:

1. Prohibiting gambling advertising on sports kits and in or near sports venues (with the exception of horseracing and greyhound racing), as recommended by the former committee;[3]

Response: The principal advantage would be a marked reduction in the gambling logos to which sports audiences are exposed, particularly the pitch-side and kit branding that dominates in-game marketing. Research by Roderique et al (2020) has shown that embedded gambling promotion in football elevates viewers' urges to gamble and normalises gambling among young and vulnerable audiences. Removing would could lower both effects, as before, evaluation of this change would be useful.

The principal disadvantage is that the efficacy of this policy depends on how comprehensively the ban is drawn. Evidence from Belgium (Constandt and De Jans, 2024) shows that a partial ban can shift advertising to channels that are still permitted. Furthermore, a prohibition confined to overt gambling logos risks circumvention through alibi branding. This was examined by Heath et al (2025) in Italy, where, despite a near-total ban, operators re-saturated the Serie A football league with alibi brands that retain the recognisable identity of operators such as LeoVegas and bet365 while adding an innocuous, non-gambling suffix (for example, LeoVegas.News). To be effective, a British ban would need to be drawn broadly enough to capture these surrogate forms. Similar regulations on alibi marketing already exist in the alcohol field (Murray et al., 2018; Purves et al., 2026).

2. Prohibiting ‘bet to view’ inducements, as recommended by the former committee;[4] and,

Response: To our knowledge, there is no direct evaluation of ‘bet to view’ models specifically. The principal benefit of prohibiting this model would be to prevent access to sports content from being made conditional on gambling, thereby removing a mechanism through which viewers may be steered from an interest in sport into a gambling environment.

Live streaming can significantly expand the role of betting operators as providers of sports content. Streaming allows betting platforms to offer access not only to major televised events, but also to international, lower-profile or late-night events that may otherwise be difficult to view (Parke and Parke, 2019). Even where access does not formally require placing a bet, the viewer is brought into an operator-controlled environment where betting markets, account prompts and inducements can be presented alongside the content.

The restriction would simply prevent gambling participation from becoming the price of access to viewing. However, to be effective, the prohibition would need to be drawn functionally, so that operators could not reproduce the same effect through registration-only streaming, bonus-linked access, account-credit requirements or other mechanisms that make sports viewing a pathway into gambling.

3. Introducing a mandatory element to the current voluntary restriction on broadcast adverts by gambling operators during live sports coverage?

Response: Evidence and policy recommendations from other research areas suggest that partial advertising restrictions may be less effective than comprehensive statutory approaches (Saffer and Chaloupka, 2000; World Health Organization, 2003, 2019; Harris et al., 2006). In Great Britain, current self-regulatory rules allow carve-outs in broadcast restrictions for live sports, making them the only daytime television programmes permitted to carry gambling advertisements. Research referenced above indicates that gambling advertising remains prevalent in and around these broadcasts. In addition, video-on-demand services face no equivalent scheduling restrictions, with current safeguards relying mainly on content and targeting rules to limit children’s exposure (Committee of Advertising Practice, 2012). This differs from the approach taken for “less healthy food and drink” advertising, which is subject to a 5:30 am to 9:00 pm watershed on linear and on-demand television, and a 24-hour ban on non-Ofcom-regulated platforms (Department of Health & Social Care, 2025). A similar mandatory, time-based framework for gambling advertising could provide a more consistent and effective regulatory approach for gambling advertising. The disadvantages of applying such rules in isolation are that they only apply to one type of advertising (linear or on-demand television). A mandatory restriction on broadcast advertising would likely need to sit within a broader statutory framework covering the full range of gambling marketing associated with sport.

Broadcast advertising

7)    Would further restrictions on broadcast advertising in the pre-9pm watershed period, and application of similar restrictions to online advertising, reduce exposure of under-18s?

Response: Yes, further restrictions on broadcast advertising in the pre-9pm watershed period, and the application of similar restrictions to online advertising, would be likely to reduce exposure of under-18s within the regulated channels and time periods. However, the effectiveness of such measures would depend on how comprehensive they are. Evidence suggests that watersheds or similar restrictions can reduce exposure to gambling advertising in the restricted period, but they can also lead to increases in advertising volumes at other times or in other media if introduced in isolation (Hörnle and Carran, 2018; Mcgrane, Pryce, Wilson, et al., 2025; van Montfoort, 2025).

For example, in Australia, advertising after the 8:30 p.m. watershed, introduced in 2018, led to an increase of gambling advertising past 8:30 p.m. by 131% (Thomas et al., 2023). In the Netherlands, advertising restrictions in traditional media have shifted advertising to online platforms (van Montfoort, 2025). This suggests that broadcast restrictions are more likely to reduce children’s exposure when they are coordinated with restrictions on online and on-demand advertising, rather than applied to broadcast media alone.

The effectiveness of watersheds, particularly if voluntary, depends heavily on the television and radio usage patterns of minors. Evidence compiled by OfCom in 2013 (cited in (Hörnle and Carran, 2018) demonstrated that 45.5% of gambling advertisements were broadcast between the hours of 06:00 and 20:59, with a further 13.1% of gambling adverts being shown between 21:00 and 22:59, and 32% being shown between 23.00 and 05.59. The same report estimated that 26.6% of 10-15-year-olds watched television past 21:00, with 8% watching television past 23:00 (Hörnle and Carran, 2018). This evidence indicates that partial watershed arrangements do not sufficiently align with children’s actual media use.

8)    What would be the benefits and risks of a ban on sponsorship by gambling operators of non-sport TV and radio programmes?

Response: The evidence base on gambling sponsorship is strongest in relation to sport, and there is less direct evidence on sponsorship of non-sport television and radio programmes specifically. However, the likely benefit of a ban would be to reduce repeated exposure to gambling brands in wider entertainment contexts.

There is substantial exposure to advertising through non-sports sponsorship of televisions programmes, with many high-profile non-sporting television programmes being sponsored by gambling companies. This includes programmes like I’m a Celebrity…Get Me Out of Here, sponsored by Tombola (Luke, 2023). This features substantial sponsorship during the programme and a wide range of fan activation activities. This programme has consolidated viewing figures of around 10 million people, demonstrating substantial reach across the British population (Itv.com, 2025b). The benefits of a ban would be a reduction in population exposure to advertising and marketing, especially of programmes like I’m a Celebrity, which have wide appeal to younger people. Data from 2025, compiled by ITV, showed that the show achieved an 83% share of 16 to 34-year-old viewers, with 1.5 million viewers in this demographic, up 9% year on year (Itv.com, 2025a).

Inducements

9)    To what extent do early indications of the impact of the ban on mixing of products within incentives and the limit to wagering requirements, introduced on 19 January 2026,[5] suggest that this policy is reducing gambling-related harm?

Response: Very little can yet be concluded directly, since the measures took effect only in January 2026 and systematic evaluation of these measures has not been commissioned (though recent appointment of a UKRI/DCMS Policy Fellow may contribute towards this, but is not due to report until 2027).

Relevant evidence is provided by Torrance et al (2026) which tested comprehension of the new “10x” wagering cap, where any wagering requirements attached to incentives (such as bonuses) must not exceed 10 times the incentive amount. The authors found that 92.4% of adult gamblers still underestimated the true cost of inducements incorporating the 10x wagering requirement. Participants described these inducements as manipulative and economically worthless, and concluded that they require further reform regardless of the 10x cap. This evidence indicates that while the cap is a reasonable first step, continuing comprehension issues may undermine its efficacy. Evidence from Spain suggests this may be compounded operators migrating towards non-wagering incentives such as free bets and odds boosts (Aonso-Diego, García-pérez and Krotter, 2025). On balance, the early indications suggest a useful but partial measure, and the evidence points towards the need for further reform, at least, on grounds of consumer transparency.

10)                        Would a more comprehensive ban on inducements to start or continue gambling, as recommended by the former committee,[6] be more effective in reducing harm?

Response: Inducements are the form of gambling marketing most directly linked to behaviour, and restrictions on them have produced the strongest behavioural evidence of any measure in the literature (Challet-Bouju et al., 2020; Balem et al., 2022). Qualitative evidence links inducements (bonuses, sign-up offers, cashback deals) with increased gambling behaviour; increased expenditure and time spent gambling; and reduced perceived risk (Jääskeläinen, P., Kivistö, M. & Marionneau, no date).

The case turns on who is targeted. Welcome and sign-up bonuses fall disproportionately on younger consumers (Gambling Commission, 2023) and may serve as a pathway from non-gambling to gambling. In both Australia and Spain, acquisition inducements have been prohibited (Department of Social Services, 2022). In Spain, this action was followed by a sustained fall in new account openings and in total amounts staked (Aonso-Diego, García-pérez and Krotter, 2025).

11)                        Does the current regulatory framework for gambling advertising sufficiently account for the different levels of risk associated with different products, and risks linked to cross-selling?

Response: No. The current regulatory framework does not systematically calibrate gambling advertising restrictions to the different levels of risk associated with different products, nor does it sufficiently address risks linked to cross-selling.

Some European countries have stricter rules on the marketing of the most harmful products – in most cases online and land-based EGMs and casino products. Finland and Norway prohibit the advertisement of both online and land-based casinos and EGMs. In addition, fast-paced online betting products cannot be advertised in Finland. In Germany, online casino gambling is subject to watershed restrictions, unlike sports betting advertising. In some other countries with strict gambling marketing regulations, lotteries are exempt (Estonia, Latvia, Bulgaria) (Marionneau et al., 2026).

These examples show that advertising regulation can be designed to reflect differences in product risk. Great Britain’s current framework does this only to a limited extent. It does not provide a systematic hierarchy of advertising restrictions based on the risk characteristics of products, such as speed of play, event frequency, structural intensity, accessibility, or association with higher levels of gambling harm.

Regulations on marketing of the most harmful gambling products can also limit cross-selling. Cross-selling increases gambling involvement among existing consumers by getting them to add gambling types to their gambling repertoire. Greater gambling involvement is associated with increased risk of gambling harms. For example, analysis of data from eight different jurisdictions showed that increasing the number of gambling activities someone undertakes per year beyond three or four different types is associated with an increased risk of gambling harms (Hodgins et al., 2023).

A regulatory framework could distinguish between product categories according to their risk characteristics, restrict marketing for higher-risk products more strongly, and limit practices that encourage consumers to move between products in ways that increase intensity and breadth of gambling involvement. However, most gambling operators maintain unified brand identities across multiple products spanning different levels of risk. As such, permitting an operator to promote a lower-risk product would need to be accompanied by strict safeguards preventing the targeting or cross-marketing of higher-risk products within the same portfolio, brand identity or operating group to those customers. Without such protections, differential regulation based on product risk may simply create indirect pathways that expose consumers to more harmful gambling options through the same operator ecosystem.

Direct marketing

12)                        In the first full year since its implementation in May 2025,[7] what evidence is there that the opt-in system for direct marketing on a per channel and per product basis has:

1. reduced the number of such direct marketing communications; and,
2. contributed to a reduction in gambling-related harm?

Response: At present, there is insufficient independent evidence to determine whether the opt-in system has reduced the overall number of direct marketing communications or contributed to a reduction in gambling-related harm. A reduction is plausible, since operators may now only send direct marketing through channels and for products to which customers have explicitly opted in. However, without mandatory reporting of direct marketing activity before and after implementation, and without suitably anonymised operator data for independent evaluation, it is not possible to assess whether communications have fallen, shifted between channels, become more concentrated among highly engaged customers, or reduced harm. This contrasts with other European jurisdictions where operators are required to provide regulators with more systematic information on advertising activities, either at the end of the year (Finland, Switzerland) or as a plan beforehand (Cyprus, Greece, France) (Marionneau et al., 2026). Similar reporting obligations in Great Britain would make it possible to evaluate the opt-in system rather than leaving its effects largely unknowable.

13)                        In light of current evidence, what would be the benefits and risks of:

1. Restricting direct marketing to those opted in to VIP/HVC schemes, as recommended by the special inquiry committee;[8] or,
2. A comprehensive ban on direct marketing?

Response: A comprehensive ban on direct marketing is strongly supported by current evidence, with the principal caveats concerning how it widely the ban is drawn (i.e., whether it also includes affiliates, other commercial partners etc) rather than whether it would work. Rockloff and colleagues' (Rockloff et al., 2026) randomised field experiment, the first of its kind, found that bettors who opted out of operator direct marketing placed 23% fewer bets, spent 39% less, and reported 67% fewer short-term harms, providing evidence that direct marketing increases betting and harm among existing customers. Evidence shows both advertising and direct marketing can motivate those experiencing gambling harms to continue to gamble (Wardle et al, 2023). The main risk is displacement, since operators may redirect effort to affiliates, sponsorship, or other channels, so the benefits depend on a ban that explicitly captures affiliate and third-party promotion while preserving essential account communication.

Regulatory framework

14)                        In your view, how effective is the current division of responsibilities between the ASA and the Gambling Commission in relation to the regulation of gambling advertising, and how might it be improved?

Response: The division is coherent in principle but arguably weak in practice. The ASA administers the CAP and BCAP content codes, written by the advertising industry, while the Gambling Commission acts as the statutory backstop, regulating operators through licence conditions with the power to fine or revoke. However, the ASA who has responsibility for setting and policing content standards has little enforcement weight of its own, since the ASA relies on adverse rulings, complaints and advert removal. The Gambling Commission, who have a wider range of regulatory responses available, tends only to becomes involved only on referral for serious or repeated breaches, a route rarely used. The result is a largely self-regulatory, complaints-led system with poor compliance. Furthermore, many organic social media gambling advertising breach the codes and whole categories of marketing fall between the different regulator, notably sponsorship, affiliates, and content marketing.

Improvement could be delivered by closing the gap between standards and enforcement, most cleanly by consolidating advertising rules within the Gambling Commission's enforceable licence conditions, an approach its recent incentive and opt-in rules show can work. This should be paired with a single point of accountability spanning the full marketing mix, a shift towards proactive independent monitoring, and the explicit inclusion of affiliates, sponsorship, and content marketing, alongside extending age protection beyond 18 to cover young adults.

Affiliate marketing and social media influencers

15)                        The 2020 special inquiry committee recommended that affiliates “be licensed by the Gambling Commission before they can enter into contracts with gambling operators”.[9]

1. Is the current regulatory model, by which the ASA regulates marketing by affiliates and the Gambling Commission holds licensed gambling operators responsible for the actions of their affiliates, operating effectively?

Response: Focus on affiliates and accountability for their practices is welcome. Data from Spain shows that total money spent by gambling operators on affiliate marketing was positively associated with increased deposits from consumers and with higher numbers of active accounts. After Spain introduced restrictions on advertising and marketing in 2020 – including regulations on content produced by affiliates - these associations were rendered non-significant (Garcia-Perez, Krotter and Aonso-Diego, 2024).

Whilst the Gambling Commission can hold licensed operators to account for the practices of their affiliates, the Commission can only reach an affiliate through the licensed operator that engaged it. This model has a structural weakness - it only works where there is a licensed operator which the Gambling Commission can hold to account.

This creates regulatory gaps. The clearest example is affiliated streamers sponsored by operators with no British licence. Most notable is sponsorship of gambling streamers, previously on platforms such as Twitch and now newer platforms like Kick. Kick was created by the owners of the crypto casino Stake, which is unlicensed in Great Britain. Using the Kick platform, Stake sponsored streamers (among others) reach British audiences, including young people (Hughes et al., 2026). Where there is no British licensing of these operators, the Commission has no operator to sanction, and the ASA can only take complaints-led action if the streams are considered marketing communications and thus subject to relevant codes. Direct licensing of affiliates, as the former committee recommended, would be a constructive first step.

2. What would be the benefits and risks of prohibiting gambling promotions by social media influencers and content creators?

Response: The benefits follow directly from the gap identified above. Prohibiting influencer and content-creator promotion would close the channel in which the current accountability model breaks down. The benefit targets a weak point within the present regulatory regime. The principal complication is difficulty of enforcement. Because much of this promotion sits on offshore platforms beyond direct British regulatory reach, a prohibition cannot be delivered by the regulator alone and depends, in part, on the platforms themselves to detect and remove the content. Our understanding is that The Illegal Gambling Taskforce is intending to lead on engagement with platforms on this priority issue, though the commercial arrangements of platforms like Kick suggest this engagement may be challenging.

Content marketing

16)                        How widespread is gambling ‘content marketing’, and what evidence is there for its impact on under-18s?

Response: Gambling content marketing is now a major part of the gambling marketing landscape, and a growing body of work from Rossi and colleagues has provided evidence on both its reach and its effect on children. This research estimates that content marketing accounts for roughly 40 to 50% of all gambling advertising on social media (Rossi et al., 2021). According to Rossi and colleagues, content marketing is harder to recognise as advertising than conventional gambling advertising, including for children, thus bypassing the scepticism overt advertising would trigger and breaches the requirement that marketing be obviously identifiable (Rossi and Nairn, 2025). In an experiment with children aged 13 to 17, content marketing proved both more emotionally arousing and less identifiable than standard advertising, with a school-based gambling education programme failing to reduce either effect (Rossi, Tozzi and Nairn, 2026). Taken together, this evidence describes a form of marketing that is widespread. Among children, it is emotionally engaging whilst being not recognisable as advertising, with both aspects being resistant to educational efforts to counter these effects.

17)                        To what extent does the ASA’s distinction between ‘advertising’ and ‘editorial content’ affect its ability to regulate content marketing?

Response: The ASA’s jurisdiction rests on a distinction between marketing communications, which fall within its codes, and editorial content, which does not. This boundary works reasonably well for conventional advertising, where promotional intent is clearly signalled. However, content marketing often operates in a space where this distinction becomes less clear-cut. By presenting promotional material in formats that resemble organic or editorial content, such material can be experienced as editorial while still serving advertising purposes.

This reflects a wider challenge in gambling regulation, where rules are sometimes framed around specific distinctions that can be difficult to apply consistently in practice. For instance, the ‘strong appeal’ threshold does not include the 18 to 24 age group, despite the Government recognising the heightened risk of harms among this age group (Department for Culture Media & Sport, 2023). Similarly, adjustments to features such as celebratory sounds for losses framed as wins have addressed formal requirements while raising questions about whether the broader intent of the rules is fully met (Myles, Bennett and Newall, 2026). Practices such as alibi branding also maintain brand visibility even when sponsorship is restricted (Heath et al., 2025).

Across these examples, there is a recurring tension between regulating formal characteristics and addressing the broader functions that marketing performs. Where regulation focuses primarily on form, there is a tendency for marketing practices to adapt accordingly. In this context, if the ASA’s remit continues to depend largely on whether content is classified as advertising rather than on its practical effects, certain forms of content marketing may remain difficult to address fully within existing frameworks.

18)                        Should gambling content marketing be permitted, and if so, how might it be regulated more effectively?

Response: Rossi, Nairn, and colleagues have made a clear set of recommendations on this question (Rossi and Nairn, 2021, 2022, 2024, 2025). Whilst they have subsequently recommended an outright ban on content marketing (Rossi and Nairn, 2025), should content marketing continue to be permitted, they recommend that it should include:

a)    mandatory and prominent labelling as commercial content, and

b)    via permitted only through opt-in model for gambling advertising on social media (Rossi and Nairn, 2021).

The EU Digital Fairness Act will introduce additional regulations on digital marketing by influencers operating within European internal market. One expected requirement is for influencers to clearly indicate when they are advertising a product. This restriction is expected to reduce the uncertainties involved in identifying content marketing.

Children and young people

19)                        Should social media companies do more to prevent the exposure of under-18s to gambling advertising, and how might this be achieved?

Response: Evidence suggests that under-18 exposure is concentrated on platforms that already possess age-gating, targeting, and detection tools that could help reduce exposure. However, systems that rely primarily on self-declared age and complaints may limit the effectiveness of these protections, with studies indicating that substantial numbers of minors continue to engage with gambling-related accounts on platforms such as Twitter (Rossi et al., 2021).

Potential improvements could include moving toward an opt-in model, where gambling advertising is shown only to users who actively choose to receive it and whose adult status has been verified. This could be complemented by stronger age-verification processes, more proactive detection and removal mechanisms, and the inclusion of influencer and content marketing within existing standards.

There is some evidence that platform-level interventions can have an impact. For example, Twitch’s removal of unlicensed gambling streams was associated with a notable reduction in such content on the platform (Han, Yang and Simonov, 2025). At the same time, the possibility that exposure may shift to other spaces suggests that platform measures may be most effective when combined with broader regulatory support and independent oversight.

International approaches also point to alternative models. In Spain, gambling advertising regulations introduced under Royal Decree 958/2020 extended to online and audiovisual media, including video‑sharing platforms such as YouTube, by restricting advertising to a 1am–5am watershed. This example demonstrates that online and social media environments can be incorporated into statutory advertising frameworks, rather than treated as entirely separate from more traditional broadcast regulation.

20)                        Should gambling advertisements in video games with a PEGI rating below 18 be permitted?

Response: The CAP Code (specifically Rule 16.3.12) specifies that gambling advertisements are strictly prohibited from being of "strong appeal" to children or young persons under 18, particularly by associating the content with youth culture, cartoon characters, or high-profile celebrities. Locating adverts within games designed to be appropriate to those under the age of 18, as specified by PEGI, would appear to be a violation of this code and should not be permitted.

Unlicensed operators

21)                        How significant are the gambling-related harms associated with the unlicensed sector in comparison with those linked to the licensed sector?

Response: Individuals engaging in unlicensed gambling have higher problem gambling severity scores and gamble more frequently than those gambling within the system (Gainsbury et al., 2018; Hagfors, Oksanen and Salonen, 2024). Unlicensed gambling is particularly prevalent among those who have self-excluded from licensed provision (Håkansson and Widinghoff, 2019; Wardle and Marionneau, 2026). Harms associated with unlicensed gambling are mainly driven by a) high levels of engagement in unlicensed gambling by those who have already been harmed by gambling (e.g., the self-excluded), b) higher overall engagement with gambling, c) a lack of protections and exploitative business practices within the unlicensed market.

In a recent study conducted in Great Britain (Wardle and Marionneau, 2026), 5.7 % of regular gamblers reported any unlicensed gambling. Unlicensed gambling was associated with higher overall gambling involvement. The odds of engaging in unlicensed gambling were significantly higher among those who regularly gambled at land-based casinos or on gambling machines. Cryptocurrency gambling was the most common reason for unlicensed gambling use (54.7 %), followed by self-exclusion (50.7 %). The results show that people gamble with unlicensed websites for many reasons. The authors concluded that in many cases, harms and gambling involvement generated within the regulated market can create demand for unlicensed gambling.

22)                        To what extent is there a risk that further restrictions on the visibility of advertising by licensed operators will increase the relative prominence of the illegal market and contribute to increased gambling harm?

Response: There is currently little evidence that restricting advertising by licensed operators would materially increase use of the unlicensed market. The claim that advertising restrictions will drive consumers towards unlicensed operators is frequently made by the licensed industry, but it is not strongly supported by the available evidence.

The available evidence points to a different set of drivers of unlicensed gambling (Gambling Commission, 2025). Recent research in Great Britain found that 5.7% of regular gamblers reported some unlicensed gambling, and that unlicensed gambling was associated with higher overall gambling involvement (Wardle and Marionneau, 2026). The odds of engaging in unlicensed gambling were significantly higher among people who regularly gambled at land-based casinos or on gambling machines. Cryptocurrency gambling and self-exclusion were also important reasons for unlicensed gambling use (Wardle and Marionneau, 2026). This suggests that demand for unlicensed gambling is shaped by factors such as intensive prior gambling involvement, the search for products or payment methods unavailable in the regulated market, and attempts to circumvent consumer-protection tools such as self-exclusion. The Gambling Commission work did identify a group they called “accidental tourists”, that is those who stumbled unwittingly onto unlicensed websites. Evidence shows that licensed gambling operators state that sponsorship and advertising are vital ways for consumers to distinguish between the legal and unlicensed market (Wardle et al, 2021). However, a clear, mandatory, stamp mark showing that each operator is legitimately licensed could perform the same function. Thus, for most unlicensed users, few people are retained or recovered by the visibility of licensed advertising.

Furthermore, interviews by Newall, Whybrow and Torrance (2026) with representatives of state monopoly operators across European jurisdictions consistently suggested that advertising restrictions did not lead to consumer migration towards illegal operators.

23)                        Is the Gambling Commission adequately resourced to tackle illegal advertising by unlicensed operators, and does it have sufficient powers in relation to the dissemination of such advertising by social media companies?

Response: Data collected across Europe for the Global Gambling Control Scorecard allows us to compare regulatory resourcing by examining declared regulatory budgets as a percentage of Gross Gambling Yield for each nation (Ukhova et al., 2025). Drawing on data collected in 2024/5, this provides an indication of which regulators have greater or lesser budgetary resource relative to the size of their markets (see Figure 2). Based on this metric, Norway has the highest level of relative budgetary resource with Great Britain being towards the lower end of the scale. Whilst relative budgetary resource does not necessarily translate fully into efficacy, it provides a useful comparator.

The Commission’s resourcing has improved. The government has allocated an additional £26 million over three years, enabling the appointment of a dedicated Head of Illegal Markets and the establishment of the Illegal Gambling Taskforce in January 2026, with tackling online advertising by illegal operators as one of its three core priorities.

There are several challenges facing this taskforce, including gaining engagement from social media operators and platforms to implement solutions to major issues. This includes unlicensed companies deliberating advertising themselves as “not on GamStop”, which explicitly targets people who have self-excluded through Britain's national scheme. Tim Miller, Executive Director for Policy Development at the Gambling Commission has highlighted this, noting that such adverts can be surfaced in seconds through Meta's own searchable ad library while platforms continue to act only once notified (Gambling Commission, 2026). This exposes a core issue, which is that the Commission cannot compel platforms to detect and remove illegal gambling advertising proactively and must instead rely on voluntary cooperation. That the forthcoming Crime and Policing Bill is expected to grant it stronger powers to take down illegal domains is itself an acknowledgement that current powers fall short.

Economic impacts

24)                        What would be the economic disbenefits of further restrictions on gambling advertising by licensed operators, and could these be effectively mitigated?

Response: This question, in part, relates to understanding the wider economic impact of implementing greater regulatory protections. Several studies have examined this, modelling the direct impacts of reducing gambling consumption (often measured by Gross Gambling Yield) upon the macro economy. A recent study by Morris et al (2026) found that reduced gambling spending generates net positive effects across six economic outcomes, including tax receipts, employment, net earnings, output and Gross Value Added. The authors concluded that the potential negative macroeconomic impacts of reducing spending on gambling could be more than mitigated when consumers reallocate money spent on these products to other consumption.

Simpson et al (2026) focused specifically on the question of reallocation of money to other areas and examined the likely impact of reduced gambling spend among those gamble regularly. They conducted empirical research with regular gamblers to examine consumption preferences and model the likely direct economic impacts of reduced gambling expenditure, using projected reductions in Gross Gambling Yield (GGY) under the Government’s White Paper as a case study.

Models showed that of the projected £812 million reduction in GGY anticipated from enhanced regulatory measures, the majority is likely to be retained within the wider economy, with only £134 million (approximately 16 per cent of the total reduction in GGY) expected to translate into a net negative impact on UK GDP. If money was consistently reallocated to the unlicensed market, then around 23% of the total reduction was anticipated to translated into a net negative impact on GDP. Only 8% of regular gamblers said they would consistently reallocate their spending to the unlicensed market if there were greater restrictions to licensed operators. Simpson et al (2026) concluded that gambling reform delivers a substantial reduction in gambling expenditure with only a limited net economic cost. The majority of consumer spending is redirected into the legitimate economy, meaning the macroeconomic impact is significantly smaller than any headline reduction in gross gambling yield suggests. 

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June 2026