Written evidence submitted by The Gambling Related Harm All Party Parliamentary Group (GRH APPG) (OSB0151)


This is not an official publication of the House of Commons or the House of Lords. It has not been approved by either the House or its committees. All Party Parliamentary Groups are informal groups of Members of both Houses with a common interest in particular issues. The views expressed in this report are those of the Group. The research for the report was undertaken by the members of the Group. The report was drafted by Interel, the Group Secretariat - the Secretariat is funded by Derek Webb.



  1. The Gambling Related Harm All Party Parliamentary Group (GRH APPG) is pleased to have the opportunity to respond to the call for evidence on the Draft Online Safety Bill.


  1. The GRH APPG was established to address the issues associated with gambling related harm. We hold regular evidence sessions and contribute to policy making and raising issues with government. We recently held an evidence session on new forms of gambling online and welcome the opportunity to share some of the highlights from this for the joint committee’s consideration.


Evidence session: new forms of online gambling


  1. In July 2021 the GRH APPG held an evidence session to explore the issue of new forms of gambling activity online. We heard from from Dr. Heather Wardle (University of Glasgow), Dr. David Zendle (University of York) and an expert by experience, Danny Cheetham. During the session they explained the convergence between online gaming and gambling. In particular, we heard about slot streaming, social casinos, esports betting and loot boxes.


  1. The GRH APPG’s work this year has focused on the government’s current Gambling Act review. Classification of an activity or service is an issue for gambling regulation and law. However, the evidence we have heard suggests that new activities online, and social media platforms, provide a means for potentially vulnerable people to experience gambling, or gambling like activity.


  1. We recently wrote to John Whittingdale MP, Minister for Media and Data, to raise some of these issues. Our letter, written jointly with Peers for Gambling Reform, summarised some of the evidence we received:


  1. Two of the most significant activities are not classified as gambling but have the hallmarks of activity which could lead to gambling harm. Social casinos (casino like apps, where players pay for additional spins but cannot take home any winnings) are some of the most popular apps worldwide, with an estimated 3-4% of UK adults playing them (David Zendle). Slot streaming, which is live streaming of gambling activity on video sharing platforms, is growing exponentially. This is without safeguards for viewers, which may include children. We heard that 35.2m hours of slots were watched on Twitch last month (Danny Cheetham).


  1. In addition, we understand that some operators are offering betting and gambling via WhatsApp. Because this is not classified in the same manner as online platforms, vulnerable customers using the service are not protected by exclusion schemes. This is a great concern. We ask the government to address this loophole as soon as possible.



Response to draft bill


  1. The online safety legislation focuses on user-to-user content sharing through online platforms, which is not a ‘traditional’ place for gambling activity. However, the evidence we have heard demonstrates that is also now a location where young and vulnerable people can encounter gambling activity, or it can be promoted. Often there are few protections.


  1. In addition to this, we are asking the government to take action to research, identify and classify new forms of gambling where there is evidence that they are causing harm, or have the potential to.


  1. Most relevant to the bill is live streaming of gambling online through video sharing platforms. This activity is known as ‘slot streaming.’ Users can live stream videos of themselves playing games and gambling. This can include promotional messages or links to other content and sites. Watching this can introduce vulnerable audiences, particularly children, to gambling without restrictions and safety measures.


  1. We understand that some video sharing platforms have introduced measures to address these issues however, this is not universal.



  1. With this in mind we have some simple recommendations:


  1. First, that platforms and other businesses in the scope of regulations are required to assess for the risk of children being exposed to gambling harms through streaming content.


  1. Second, that these businesses are required to introduce measures to stop children being exposed to this content and provide appropriate protection measures.


28 September 2021