Wilna van Wyk

Last week, the House of Commons debated the amendments to the Gambling Act 2005 and the Draft Gambling Levy Regulations.

The Impact of New Stake Limits on Online Slot Games

Under the new amendments, online slot games will be subject to a statutory maximum stake limit of £5 per spin for players aged 25 and over and £2 per spin for those aged 18 and 24. 

Introducing discussion around the new regulation, Labour MP Stephanie Peacock, Parliamentary Under-Secretary of State for Culture, Media and Sport, stated, “Online slots are the highest risk gambling product. They have the highest rate of binge play and the highest average losses of any online product.” 

She continued to note that the UK’s online gambling sector generates £6.9 billion annually, with online slots alone comprising 52.2% (£3.6 billion) of the market, an increase of 61% over the past five years. 

Sir Iain Duncan Smith, Conservative MP for Chingford and Woodford Green, stayed true to his long-running anti-industry stance, welcoming limits but arguing £5 was too high. The Chair of the APPG for Gambling Reform said, “We have a problem here because we have physical shops on the high street where stakes will be limited to £2, yet we have a £5 limit for online. The online side will grow rapidly, and it has the greatest attraction for those who get hooked on gambling.” 

He continued, “Online slots are available anytime, can be marketed to every current and potential account holder, and offer unrestricted access to high-speed and addictive products.” 

Cameron Thomas, the Liberal Democrat MP for Tewkesbury, supported the changes and called for restrictions on gambling advertising and the regulation of loot boxes in video games. 

In his address, he commented, “We urgently need action to tackle pervasive gambling advertising and sponsorship. We also need action on black market gambling, and we need gaming products such as loot boxes to be regulated as gambling products to protect children from gambling harms.” 

Statutory Gambling Levy Sparks Mixed Response

The Draft Gambling Levy Regulations 2025 will impose an annual levy on all licensed gambling operators to provide consistent funding for research, prevention, and treatment of gambling addiction. 

Peacock described the levy as a “watershed moment,” adding, “The levy provides us with an opportunity and the resources to put the right projects and services in place, with clear objectives and robust governance. We want a world-leading funding and commissioning system to reduce gambling-related harm.” 

The pro-gambling lobby responded with a frosty tone. Louie French, the Conservative MP for Old Bexley and Sidcup, argued that the expanded levy would disproportionately affect smaller operators and high-street bookmakers. 

“It is remarkable that in almost every conversation that the shadow DCMS team has with people across the sector, we are being told consistently that the Government is not even engaging, let alone listening,” he commented. 

Duncan Smith shunned his fellow Conservative’s concerns, commenting, “The gambling industry had years to get the voluntary levy right. The good ones contributed; the bad ones did not, or when they did, it was peanuts. The statutory levy was required; otherwise, the money would not go to many of those community groups and charities that disburse the money and work to get this done.” 

There were also comments from Jim Allister (Northern Ireland), who highlighted the lack of regulatory oversight for online gambling in Northern Ireland. Further, concerns were expressed over potential unintended consequences of stake limits, such as black market activity.

Peacock responded to French’s call for a review mechanism to monitor the pivot to the black market by assuring the government that it would review the stake limits within five years of implementation.

Written By

Wilna van Wyk

Wilna van Wyk is an online casino enthusiast with over a decade of experience working with some of the world’s biggest gambling affiliates, including Thunderstruck Media and OneTwenty Group. She specializes in gambling sites and games and provides expert knowledge on the online casino industry’s essential fundamentals.

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The report supported the proposal in principle but called for checks to be as frictionless as possible. There were also calls for changes to the approach to deposit limits, with it stating that they should be set by default and require customers to opt out rather than opt in.

Nonetheless, the parliamentary committee underlined that industry reforms shouldn’t solely be reactive, arguing instead for gambling activity to be safer by design. It highlighted that some elements of gambling can cause continued play and lead to harmful player traits. 

The report pinpointed slots when it comes to this type of behavior – key elements of slots that lead to this are speed of play, near misses, losses disguised as wins and game visuals. Most notable, according to the report, is speed of play, with MPs citing that faster play causes a reduction in a player’s ability to withhold from gambling. 

In terms of action, the group revealed ambitions for the introduction of a safety testing regime, which increases the safeguards around exposure to gambling products that are deemed more harmful for players. 

As well as this, the Committee urged the Government to investigate the case for banning children’s access to social casino games, which are often playable on smartphones and simulate gambling activities and products.

The report also highlighted that similar regulations introduced in 2021 slowing the pace of online slots, calling for the adoption for other online products with five second minimum game speed as well as removal of characteristics which dissociate from awareness of play. 

A consultation period is currently being embarked upon in terms of actions when it comes to the framework around safer gambling. 

The report was also critical of the UK government’s approach to betting advertising in sports and the delays around the implementation of a new sports sponsorships code of conduct. 

Outlining the Committee’s view, Chair Dame Caroline Dinenage MP, said: “While gambling regulation should not overly impinge on the freedom to enjoy what is a problem-free pastime for the majority, more should be done to shield both children and people who have experienced problem gambling from what often seems like a bombardment of advertising branding at football and other sporting events. 

“The Government needs to go further than the proposals in the White Paper and work with sports governing bodies on cutting the sheer volume of betting adverts people are being exposed to.”

The Betting and Gaming Council also responded by taking aim at sporting bodies who they describe as having been ‘dragging their feet’ on formulation and finalisation of the code.

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The gambling harm charity witnessed £430.9m in donations throughout the financial year, including £31.7m in RET donations as well as £113.7m in non-RET funding, from unclaimed winnings or inactive player accounts. 

Neither Entain, Flutter Entertainment, bet365 or William Hill were present in the list of donors covering April-June 2023, however the omission of the ‘Big Four’ was expected due to the companies’ large donations in previous quarters that are typically made annually. 

Significant donations in the opening quarter of 2023/24 saw Betfred donate £50,000, solely-online sportsbook Betway pledge £25,000 and Star Racing, Virgin Bet and the Postcode Lottery donate £28,916, £22,836 and £18,708, respectively. 

Although the UK is currently awaiting consultations on RET funding changes proposed in the Gambling Act white paper, the nation currently uses a system of voluntary donations from the gambling industry for RET and charitable funding. 

While all companies with revenue above £250,000 pledge to donate 0.1 per cent of gross gambling yield, and those below the threshold donating at least £250, the aforementioned ‘Big Four’ have indicated that they will increase their contributions from 0.1 per cent to one per cent by 2024. 

Due to this pledge, Entain, Flutter, William Hill and bet365 have dominated GambleAware’s donor lists in recent years, having contributed a combined total of £42.9m for the full financial year 2022/23, representing 92 per cent of total donations (£46.5m). 

As these operators were missing on GambleAware’s latest report, the organisation pointed out that larger operators do tend to donate later on in the year after assessing their GGY. Despite this, GambleAware’s Q1 2023/24 RET donations witnessed a nine per cent drop from the same period last year. 

With white paper consultations set to make their impact on the industry, the UK’s gambling treatment funding system could soon find significant changes as a statutory levy for RET was a key proposal laid out in the review. 

This levy is something GambleAware has encouraged for some time, hoping for greater ‘disparity’ between smaller and larger operators regarding their RET funding in the form of a mandatory funding commitment. 

The charity stated: “GambleAware welcomes plans for a statutory levy as outlined in the government’s gambling white paper and looks forward to its swift implementation.”

Earlier this week, the UK government announced the first set of consultations to address the proposals of the Gambling Act review, with the RET levy to be addressed in the second round of consultations further down the line.

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Following over two years of development, the UK Government has finally published its white paper for the 2005 Gambling Act review with proposals covering stake limits and affordability checks. 

On the latter point, the white paper proposed a ‘targeted system of financial risk checks’ that includes a monthly net loss threshold of £125 and a yearly net loss threshold of £500 as the benchmark for initial affordability checks. 

Additionally, a higher threshold of £1,000 in losses for one day or £2,000 within 90 days was also proposed. 

The white paper also suggested age-restricted maximum stake limits for online slot machines, with either £2 or £4 proposed for 18-24 year olds or, alternatively, ‘an approach based on individual risk’. 

The DCMS published the white paper on Thursday morning, covering other issues such as a Code of Conduct for advertising in the industry, a reorganisation of the UKGC and balancing consumer freedom with player protection. 

4

Spelinspektionen has issued a SEK 4m fine (£310,000) and a warning to Betfair International for offering betting on U21 Allsvenskan Swedish football, which is not allowed.

In a statement, Sweden’s gambling inspectorate stated that it “considers the infringement to be serious and has occurred systematically”.

Spelinspektionen added that the assessment had not been affected by the “fact that the bets have been made for low remuneration for Betfair”.

According to the country’s regulations, betting on football may only be offered on the four highest league levels in the Swedish league system.

306.4

Kindred Group has declared “encouraging improvements in both revenue and profitability” in the first quarter of 2023, thanks to its core markets performing well to begin the year.

Publishing its Q1 results, Kindred reported an overall revenue from B2C and B2B operations of £306.4m, up 24.2 per cent year-over-year (Q1 2022: £246.7m). 

However, while the group is focused on cost optimisation, in tangent with its result, the board of directors announced a review of ‘strategic alternatives’ to maximise shareholder value and the overall value of its assets.

In a statement, the group noted that it will “consider all potential alternatives that can deliver value for the company’s shareholders” including a merger or sale of the company, but no timetable has been set for the completion of its review.

429.6

Evolution CEO Martin Carlesund cited a “strong start to the year” as the B2B provider’s operating revenues increased by 31.5 per cent in the first quarter to €429.6m. 

Publishing its Q1 interim results, Evolution revealed that 83.8 per cent of revenues derived from live casino games with the remainder made up by RNG-based games, attributing a “strong demand” from customers to the robust performance. 

Live casino revenue came out at €360.1m, an uptick of 36.1 per cent compared to last year, while RNG revenues stood at €69.5m. 

Carlesund stated: “A strong start of the year at Evolution. Revenues increased by 31.5 per cent to €429.6m in the first quarter, with 83.8 per cent of revenues deriving from live casino games and the rest from RNG. 

“The underlying growth drivers for online casino are solid and I am happy with the start of 2023.”

964

Boyd Gaming has instilled confidence in achieving its full-year corporate objectives following an “excellent start to 2023”.

Publishing its Q1 financial update, Boyd Gaming declared revenues of $964m, up 12 per cent year-over-year (Q1 2022: $860.7m) with net income growing to $199.7m (2022: $162.9m).

Per segment, gaming revenues declined slightly YoY to $664.3m (2022: $668m), whilst food & beverage revenue rose to $71.6m (2022: $63.7m), and room revenue increased to $50m (2022: $42.4m).

However, online revenue – which includes the company’s sports betting partnership with FanDuel, online market access agreements, and online casino Boyd Interactive – had the largest growth YoY, rising by 123 per cent to $122.9m (2022: $55.1m).

Boyd Gaming attributed the online growth to the launch of “sports-betting operations in Ohio and Kansas, continued growth in existing markets, and contributions from Boyd Interactive”.

100

NorthStar Gaming has announced the acquisition of Slapshot Media, purchasing 100 per cent of the Canadian igaming marketing and managed services firm. 

Slapshot Media specialises in providing managed services to Spreads.ca, an online casino site operated by the Abenaki Council of Wolinak, as NorthStar looks to open up the Canadian market to its brand outside of Ontario.

Through the move, NorthStar is set to acquire 100 per cent of Slapshot’s issued and outstanding shares for C$1.8m, payable in 3,272,727 common shares deemed at a value equal to $0.55 per share, subject to customary post-closing adjustments for working capital. 

“The acquisition of Slapshot expands our ability to enter new markets faster as we look to introduce NorthStar Bets to consumers across the country,” commented Michael Moskowitz, CEO and Founding Partner at NorthStar. 

“We are hyper focused on growing the reach of NorthStar and this strategic acquisition and partnership further positions NorthStar for rapid growth into new markets within Canada.”

3

Hard Rock International Chairman Jim Allen speculated that the introduction of three New York casinos could have a major impact on land-based casino properties in New Jersey, and particularly Atlantic City. 

Speaking to the Associated Press, Allen highlighted the percentage of visitors it receives from people that live in downstate New York and how the new proposed casino openings in the Empire State will impact business in the Garden State.

“Atlantic City receives 20, 30-plus per cent of its revenue from upstate New Jersey and downstate New York, and there’s no doubt it is going to have an impact on this particular market,” Allen said.

“So you have three or four that are very strong and then I think there’s a question as to what happens in that next level down. I think it’s a concern that if these other casinos don’t perform, then inevitably from a business standpoint, is there vulnerability? I don’t think that changes unless there’s enhancement to the perception of Atlantic City.”

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Three of the UK’s most prominent RET organisations issued statements in response to the legislative proposals, outlining their views on what steps should be taken by the government and industry stakeholders. 

GamCare

Treatment organisation GamCare, which operates the National Gambling Helpline, has been an enforcer of charity organisations calling for reform in the UK Gambling sector. 

GamCare focused on the research, education and treatment funding area of the white paper, which saw the government propose an RET levy for the industry to provide mandatory contributions. 

Anna Hemmings, GamCare CEO, commented: “We are pleased to see that the gambling white paper is now published. The measures the Government are proposing are an important recognition of the changes needed to make sure that legislation around gambling is fit for the digital age. 

“At GamCare, our priority is making sure that people who need help receive it as quickly as possible. We therefore welcome the clarity the Government has provided on how research, education and treatment will be funded.” 

On the topic of RET, Hemmings outlined that 85 per cent of GamCare’s audience agreed that bookmakers need to ‘meet the costs’ of supporting people affected by problem gambling.

Welcoming the inclusion of ‘financial risk checks’ for online betting, GamCare’s Chief Executive cited that 75 per cent of the charity’s users stated they have struggled with long-term debt.

Additionally, one of the last defining recommendations of the white paper is the creation of an industry ombudsman to handle customer complaints and redress. 

Hennings praised this proposal as a step towards ‘fair, transparent and quick resolution of complaints’, while calling for GamCare service users ‘to be at the heart of the design of the new system’.

Hennings added: “We will now take time to carefully review all the proposals and respond to the details of the white paper and any related consultations. We receive over 40,000 calls to our National Gambling Helpline every year and we will be looking for those people to share their thoughts on the proposals. 

“As the leading gambling support charity in the sector, we look forward to working with the Government and our partners in the National Gambling Support Network, so we can move forward in shaping the future of gambling support.”

EPIC Risk Management

Gambling harm minimisation consultancy EPIC Risk Management responded to the long-awaited review with ‘cautious optimism’.

CEO Paul Buck stated: “We welcome the release of the Gambling Act Review white paper because whilst it is far from the end of the process due to another likely two or three years of discussions, this now informs where we’re heading to create a safer gambling industry within the UK. 

“We welcome any legislation that looks to prevent gambling-related harm sensibly, but we’re acutely aware that today’s white paper still has plenty of work to do to iron out the details on key areas.”

Sections of the white paper with particular significance for EPIC include a £2 stake limit for online slot machines – for players aged 18 to 25 – as well as the proposed introduction of the RET levy. 

Despite this ‘cautious optimism’, Buck expressed some areas of concern that still remain due to the fact that the white paper is still subject to further consultations, meaning its proposals are less than concrete. 

Buck also questioned the ins and outs of the RET levy, voicing concerns over the percentage of industry revenue to be used, which has not yet been made clear.  

“If you’re looking at the three main areas, the first is a statutory levy,” Buck added. “That means the operators must give a certain percentage of profits to a research, education, and treatment levy. In principle, this could work, despite worries from public health experts globally. 

“However, the consultation must clarify exactly who will independently commission this and ensure the funds are directed to the most effective organisations that can create the most impact. The effective commissioning of funding will be crucial and will take step-change progress.

“The other concern is that there is much talk of treatment (NHS) and research. Whilst these are crucial, we also believe that prevention is crucial, and it is a false economy that encourages harm if prevention is not front and centre of the conversation.”

GAMSTOP

GAMSTOP, the organisation behind UK Gambling’s most prominent self-exclusion scheme, was also left feeling that evidence and reasoning behind some of the white paper decisions is still required, while company CEO Fiona Palmer did agree with the need to bring UK regulations into the ‘smartphone age’. 

Palmer said: “Online gambling has changed out of all recognition since the 2005 Gambling Act, and we welcome any changes that protect vulnerable individuals, especially younger consumers who make up a significant percentage of our consumer base.”

Player protection is at the height of GAMSTOP’s concerns after March saw the company’s self-exclusion scheme record its ‘highest ever’ number of monthly registrations. 

As it stands, 365,000 people have registered with GAMSTOP since its 2019 inception, with a record 84,000 signing up in 2022 and 8,504 last month.

In her statement, Palmer also expressed a similar concern to that of the Betting and Gaming Council, looking into the impact of illicit sites on problem gambling and how that can be curved. 

“We are particularly concerned about the targeting of vulnerable individuals by illegal sites not registered with GAMSTOP,” Palmer added.

“More than 365,000 people have excluded themselves from online gambling and it is worrying that they are being deliberately targeted when they are at their most vulnerable.

“We are pleased that the Gambling Commission is to be given greater powers to deal with this issue, which we highlighted in our evidence to the DCMS. 

“We are encouraged that legislation will be introduced, allowing the Gambling Commission to apply for a court order as a last resort, requiring ISPs, payment providers and other service providers to implement measures aimed at disrupting the business of an illegal gambling operator. This will provide greater protection for GAMSTOP’s users.”

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Shortly after DCMS Secretary Lucy Frazer announced the reforms to parliament, and the white paper was published to the DCMS website, the BGC issued two separate statements to address the legislative changes. 

Michael Dugher, BGC CEO, highlighted that the association has worked ‘extremely hard and closely’ with the government over the 28 months of the Gambling Act review. 

Dugher reinforced that the BGC was established to examine reforms, while representing the industry and the 110,000 jobs within it when formed in July 2019, just 18 months before the review began in December 2020. 

“On behalf of our many members, the 110,000 people whose jobs rely on the regulated betting and gaming industry, and the 22.5 million people who enjoy a bet each month, we welcome the much-delayed publication of the Gambling White Paper,” explained Dugher. 

“We need time to consider the full detail and impacts of these proposals, but it is important to recognise the BGC has worked closely with the government to deliver a wide-ranging package of balanced, proportionate and effective reforms.

“Our members generate £7.1bn for the economy and raise £4.2bn in tax every year, and the measures announced today should protect jobs and sustain that vital contribution, while also building on our own work to drive world-leading standards in safer gambling.”

Reflecting on the legislative proposals, some of the BGC’s desired outcomes have been achieved as the DCMS proposed to create a new ombudsman to handle customer complaints and redress. 

Additionally, Dugher welcomed the introduction of stake limits on slots – varying depending on the age of customers – and ‘overdue plans to modernise the regulation of the casino sector’.

Regarding the research, education and treatment levy that was also proposed, Dugher maintained that the BGC has long-called for ‘enhanced contributions’ of its members in the industry to be made mandatory, noting that voluntary industry donations between 2019 and 2024 have amounted to £110m. 

Dugher added: “We welcome the decision to reject proposals from anti-gambling prohibitionists for blanket, low level and intrusive affordability checks, as well as their calls for bans on advertising, sports sponsorship and consumer promotions, which would harm our best-loved sports like horse racing and football, threaten jobs and drive customers to the growing unsafe, unregulated gambling black market online.

“These proposed measures will mean significant change but hopefully much needed regulatory stability to ensure our members can focus entirely on delivering for customers.”

Remaining hopeful that Ministers will ultimately reject proposals made from ‘anti-gambling prohibitionists’, the BGC CEO explained that the council retains its long-held view that gambling is ultimately a case of ‘freedom of choice’. 

Despite all of this, it remained apparent that many of the review’s proposals were not concrete decisions, with many waiting on further stakeholder consultation, such as with the UK Gambling Commission and the NHS. 

While the government prepares to move ahead with the proposals, Dugher remained adamant that the BGC’s members will continue to focus on finding a balance between player protection and retaining the enjoyment of those that aren’t vulnerable to problem gambling.

The BGC Chief Executive concluded: “This White Paper is a once in a generation moment for change and its publication must draw a line under the lengthy and often polarised debates on gambling. 

“Betting and gaming is popular, contrary to misconceptions, the numbers of people betting are stable and not increasing, problem gambling rates are stable and low, and our members are a genuine British business success story, ploughing billions into the economy. 

“The focus should now be on continuing to drive higher standards, whilst investing in jobs and businesses in the UK’s world leading regulated industry.”

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Having reviewed the White Paper recommendations, Rank, the UK’s largest casino operator, welcomed reforms that will ensure “there is an equitable approach to the regulation of the online and the land-based industries”.

“We welcome those commitments in the White Paper that directly address this objective and which respond to how the gambling landscape has changed since 2005”, the LSE gambling group stated. 

Of strategic importance, Rank is pleased that the government will allow an increase in the number of gaming machines allowed in 1968 Act casinos

The government’s pledge to introduce a sliding scale for gaming machine numbers, based on the size of the venue, is anticipated to benefit most of the Group’s 50 UK casino venues. Upcoming changes will enable customers to experience a broader variety of gaming machines designed to cater to their preferences.

Rank’s leadership is committed to engaging with the Government and the Gambling Commission regarding proposals to help modernize the sector, support the best interests of customers, and emphasize robust safer gambling measures.

Its proposals include expanding the range of table gaming products on electronic terminals and extending betting opportunities for the main stage game of bingo.

The Group also recognises the importance of considering the different associations between gambling sectors and their respective fixed costs, particularly concerning the consultation on the statutory levy.

In light of White Paper’s recommendations, Rank anticipates that its policy changes will have a net positive effect on its operations, with the benefits to land-based venues outweighing the negative impacts of lower maximum stakes for online slots and the additional cost of the statutory levy.

Concluding Ranks response, CEO John O’Reilly emphasised the importance of timely implementation, stating, “Swift implementation of these much-needed reforms is vital for the land-based sector as we look to meet the needs of today’s consumers while continuing to uphold our commitment to safer gambling.”

“The public policy changes set out by Government are a constructive set of measures for the future of our industry and provide a firmer foundation for us to invest in our business. Whilst our UK digital business will be impacted by a tightening of regulation, our land-based operations will benefit from the proposed regulatory changes and, in net terms, the Group will benefit.”

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According to the Racing Post, the MP for Pudsey, Horsforth and Aireborough in West Yorkshire will be confirmed by the government as the ministerial steward overseeing the Gambling Review and the imminent publishing of its white paper of recommendations. 

Andrew has worked as Parliamentary Under-Secretary of State for Sport, Tourism, Heritage and Civil Society at the DCMS since September last year under current Prime Minister Rishi Sunak, the third UK Prime Minster since the Gambling Act review began in December 2020.

While Andrew hasn’t vocalised many opinions on gambling previously, he was criticised for accepting hospitality from Paddy Power worth £1,961 for England’s UEFA Euro 2020 game against Germany in 2021.

The review has been overseen by five other ministers over the past two years – Parliamentary-Under Secretaries Nigel Huddleston, John Whittingdale, Chris Philp, Damian Collins and Paul Scully.

Alongside four DCMS Secretaries – Oliver Dowden, Nadine Dorries, Michelle Donelan and Lucy Frazer – a total of 10 ministers have had oversight of the review.

An MP since 2010, Andrew has previously served as the Parliamentary Under-Secretary of State for Wales as well as the Parliamentary Under-Secretary of State for Defence Procurement under former Prime Minister Theresa May.

He also held four positions while Boris Johnson was Prime Minister – Vice-Chamberlain of the Household, Minister of State for Housing, Government Deputy Chief Whip Treasurer of the Household and Minister of State for Prisons and Probation.

After Frazer recently assumed DCMS leadership, the Gambling Act review can now resume again, with many officials hoping for the white paper to be published before the end of March.

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Addressing gambling related harm has become a key focus of the betting and gaming industry as we’re seeing more markets open up, and more mature markets undergo a regulatory review. This is particularly apparent in the UK which is awaiting the findings of the 2005 Gambling Act Review.

Technology has an increasingly important role to play in upholding safer gambling standards, and according to Crucial Compliance CEO Paul Foster, this can bring numerous benefits for betting operators – particularly in areas such as affordability modelling. 

For large-scale operators, technology can be essential in identifying the first signs of gambling harm. This, however, must be followed by a human-led interaction. 

“I think they both have a place,” he explained. “Within every market, you have to look at what publicly available information you can get and then what you have to do is model that in relation to player protection – use it at the core of an algorithm or as a model for actually spotting it. In that way, it can be used very successfully.

“The issue we’ve got is that there’s an expectation that this is going to be the silver bullet and, unfortunately, there’s very few countries in the world where you can get the level of financial data that will give you an accurate affordability figure.”

As with any developments in the betting and gaming industry, particularly with regards to player protection, there are challenges and hurdles. 

Notably, Foster maintained that companies cannot completely disregard the ‘human touch’ when it comes to creating an effective harm minimisation strategy, adding that technology should complement the human decision making process.

He explained: “Technology has to be tuned into your business and once that has happened, it has to flag high risk cases which need human intervention. This is because the only way to effectively look at reducing gambling-related harm is to track it in the form of behavioural change. 

“Identification is only the first element. Whilst the system and AI will notice behavioural change, it can’t interpret what that information might mean. For example, it cannot comprehend why you might deposit three times as much on a Tuesday night – whereas the human eye might notice a casino win the day before which has just been deposited, or that the player has just reached payday and is making a long-term deposit.

“Safer gambling is always going to need human intervention to review on a case by case basis, especially in relation to high risk and very high risk cases. You initially need technology to identify behavioural change but you cannot rely on technology all the way through.”

Discussions soon moved towards the introduction of more stringent affordability checks. Many across the industry have voiced concerns over whether enhanced checks could “have negative impacts on the customer”.

Although Foster also noted that the same could be said of an over-reliance on technology should a “sledgehammer approach” be adopted. 

This, he asserted, was the case when affordability checks were first implemented as the industry was and is still learning. He added that this remains an issue with technological development on player protection. 

He continued: “The problem with any change in regulation and any new technology is that until we really understand it we will over rely on the initial solution to keep compliant, which impacts operator effectiveness and the customer. 

“What we are doing often is implementing change to match regulation with the technology available and without understanding. This means a lot of these changes initially can have negative impacts on the customer rather than positively impacting them until we manage to train the technology.”

It is particularly important for betting firms to review the technology they have available as it is a ‘constant battle to keep it up to date’, especially methods such as Artificial Intelligence (AI).

With AI being the ‘big word’ in player protection, Foster focused heavily on the importance of understanding how technology needs to be interpreted and trained so that it can be used effectively. 

“AI models are ultimately only as good as the person writing them,” he advised. “And the major problem facing the gambling industry right now with regards to their adoption is that AI is still in its infancy.

“As we look forward and we increase the level of high quality investment in this area then what we will see is better and better AI intervention. But it is very difficult to take an AI model used elsewhere in the gambling industry or outside and convert it into a player protection tool.”

He added: “All I would say is don’t buy something that is shiny or new when what you need is old fashioned advanced algorithms.”

Providing industry stakeholders with a snapshot of what to expect from the review, the UK’s Gambling Minister Chris Philp has repeatedly stated that he would like to see greater use of technology and data as tools for counteracting and minimising gambling-related harm. 

Foster agreed that this approach could not be more important for both operators and the UK Gambling Commission, as he noted that the UK’s approach to data has lagged behind many of its European counterparts – although “nobody has yet got it right”.

“Some are a lot better at getting data. If you look at ARM in Italy, it tracks all the data you need, so you can put a player protection system in via a regulator,” he commented.

“In Spain and France, their regulatory returns highlight data where you could set the data across the market for player protection – as is the case in the Netherlands and even Sweden. What they have is a framework that they haven’t yet extrapolated to player protection, but they can. 

“In the UK, we have the opposite. We have poor data collection, we have a poor single view of customers across the industry. It is a mess and as a result, the UK is going to struggle to catch up to the rest of Europe when it comes to data, not when it comes to regulation.”

With regards to the actions of the gambling companies themselves, the CEO argued that firms should put their primary focus on data before making any decisions with regards to technological implementation. 

“Operators need to look at their data first, and build a technology solution based on that available data,” he stated. “Every operator has different data, every operator stores it in a different way, and therefore the operator has to understand what their data is before they can even consider a technological solution.

“It is only data that can drive a true customer protection strategy, and it’s how you manipulate and use that data which makes the difference. Gambling companies have been brilliant for years at using that data for customer acquisition, retention, bonuses and promotions. But it is that same data that can be used to help player protection.”

In order to effectively leverage this data and develop a strong technological basis for player protection, operators must also deploy a strong recruitment strategy in this area, both internally and externally.

“When it comes to hiring, what’s really important is that you pick the people either within your business or outside who are interested in player protection, who want to learn about it, who have passion for it, and are willing to adapt their skills and their qualifications to player protection data analysis rather than just general data analysis.”

Ultimately, however, there is ‘no silver bullet’ to player protection and problem gambling, and further investment is needed – in time, money and people – for greater development in this area. 

“Compliance isn’t a profit centre but it is a cost centre,” Foster concluded. “If you look at the financial services industry, the insurance industry, pharmaceutical industry, they invest heavily in compliance for this reason, compared to gaming companies. The industry must invest now if we are to manage effective change.”

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Speaking at GambleAware’s ‘Taking action to tackling gambling harms as a public health issue’ conference, Scully noted that the review will use “targeted, proportionate and effective reform”, while stressing that gambling harms “cannot be tackled in isolation”. 

As a part of Rishi Sunak’s government, Scully was appointed Minister for Tech and the Digital Economy, taking on the challenge of completing the Gambling Act review that has been delayed several times, most recently due to the country’s political debacle. 

Scully addressed the governmental merry-go-round in the GambleAware speech, stating that he is “aware that you’ve seen a few different faces in the role of gambling minister in the last six months.”

Scully mentioned that the government is keen to publish its long-awaited review and white paper “in the coming weeks” to establish an updated regulatory framework for the UK, but explained that “causes of gambling related harm are complex to unpick and address.”

He stated: “Individual circumstances, environmental and other health factors play a role, but our approach also needs to look at the products and the practices.

“We also need to make sure anyone who is experiencing gambling-related harm can access the right support whenever and wherever they might need it.

“As you all know, we’ve been carrying out the most thorough review of gambling law since the 2005 Act. We want to publish it as soon as we can, but also we need to make sure we get it right.”

Commenting on the recent influx of financial penalties in the industry for regulatory misbehaviour, Scully said: “In the past year alone we’ve seen a number of operators pay out over £45m because of regulatory failures – two of the largest operators alone have paid £26m.

“By comparison, in the whole of the 2016/17 financial year, the Commission took action against three operators who paid £1.7m due to regulatory failures.

“The review is an opportunity to build on these changes, and do more to make sure we have the right protections for the digital age.”

To conclude his speech, Scully pointed out the need to publish the review. He stated: “The Gambling Act review is an opportunity to put the right framework in place to meet the challenges and seize the opportunities which have come with the changes since the 2005 Gambling Act was passed.”

“We’re determined to make sure that the review gets the right protections in place. We are committed to the review and I am aware that delays to the white paper have been difficult.

“I am pleased to confirm that we are keen to publish it in the coming weeks. But, I want to make clear that the white paper is not the end of our discussions on these matters.”

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