“As a regulator, we are committed to collaboration wherever possible”, he stated after kicking off his speech by lauding the growth of the relationship between the financial sector and the gambling industry, emphasising that the sector hadn’t previously been as engaged with the topic of gambling harm.”

Collaboration could be vital in various forms, according to Miller, who pinpointed working with operators and other regulators in order to ensure the industry is “fairer, safer and crime free”.

Miller added: “As we continue to move from a voluntary funded treatment and towards a statutory levy, a commitment to working together will remain of vital importance and that should include working with the widest range of voices and that should include all those with the knowledge, insights, skills and experience needed to make the future industry a success.

“I think the national strategy was a success in shifting the landscape from what was a quite disparate and sometimes unhealthily competitive environment, towards one that has more willingness to engage with a variety of voices.

“It was for example, during the life of the national strategy, that we saw, for the first time, the voice of lived experience being embedded in many organisations in the space. However, as we started to get closer to the statutory levy becoming a reality, it has felt like attempts to exclude certain voices have grown.”

The “exclusion of voices” is something that Miller warned against as he drew upon experience from the national strategy, where he underpinned the importance of acknowledging that each experience is very different.

“We have also got to ensure that we hear the voice of all consumers, including those that are gambling without harm. If the future system wants to genuinely take a preventative approach then understanding why some people don’t experience harm is an equally important part of understanding what will prevent harm.

“We also have to hear from voices of those that are working in existing services. I have also regularly heard from people who have been greatly helped by existing services or who currently rely on these services.

“Whatever future structures and systems may look like, being able to draw upon many of those whose work is already making a difference is key to whatever comes next.

“Finally, we should hear relevant voices from within the industry, don’t misinterpret what I’m saying here – the industry should not be able to make decisions about treatment and support services are designed – equally, research under the levy, should be demonstrably independent in how it is commissioned and operated – people have to be confident that the levy system works in a way that is not influenced by commercial decisions, but that does not mean the industry has nothing of value to add.”

He reminded that transparency, openness and including the broadest range of voices, shouldn’t impact the independence of the system, but can boost everyone when it comes to pulling in the same direction.

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In a latest blog update of the regulator’s website, Miller issued an update on the progress made in the interim, as well as outlining “another milestone” that is fast approaching.

Regarding the former, completion of a first deliverable was initially touched upon, which saw the UKGC “reinforce our expectations” on white label arrangements.

Following publication of this guidance, a first tranche of consultations will be launched through the current month, which will be undertaken across a 12 month period. Closing dates are expected to fall in October.

A first batch of consultations related to the Gambling Act review will include age verification in premises; remote games design – building on earlier work on online slots; direct marketing and cross-selling and financial risk and vulnerability checks for remote operators.

Furthermore, these will be accompanied by a pair of discussions unrelated to the review, which concern rules around personal management licences and procedures for regulatory panels.

“Implementing the Gambling Act review is a key part of our work to make gambling safer”

“We’re also progressing in the important work around improving the evidence and data for gambling in Great Britain,” Miller wrote.

“The implementation of our groundbreaking new participation and prevalence research methodology and building the evidence base are both Gambling Act review commitments. 

“We have made further progress towards these aims with the publication of updates on our work to improve our participation and prevalence statistics and the publication of our three-year evidence gaps and priorities review.”

Later in the year, Miller noted that a second round of consultations will be opened up that will look into socially responsible inducements and gambling management tools, with stakeholder engagement set to commence in the coming weeks.

In addition, the UKGC also reflected on the “vital work” in advising the government on amending aspects of the legislation and on implementation of these changes.

This will lead to the creation of a statutory levy, which will see the UKGC collect and distribute funds in line with government direction regarding the destination of the capital.

“whilst the work on implementation picks up momentum, rest assured we won’t be slowing down on protecting consumers”

However, once this system is created, the Commission has said that “it is likely” that the LCCP RET list will “no longer be relevant or needed”.

Furthermore, Miller also issued a reminder that the regulator will continue working alongside relevant parties “to monitor the progress of industry to deliver on their voluntary commitments”, such as an ombudsman and single customer view.

“Full implementation of the review will be a job of several years, especially when you include evaluating the impact of any changes,” he concluded.

“But that doesn’t mean we don’t want to progress things as quickly as possible. We are determined to make progress at speed.

“Implementing the Gambling Act review is a key part of our work to make gambling safer, fairer and crime free over the next few years. 

“But so is our day-to-day work of ensuring compliance with our rules. So whilst the work on implementation picks up momentum, rest assured we won’t be slowing down on protecting consumers across Great Britain either.”

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Speaking at the ICE World Regulatory Briefing, Miller cited investment into R&D, ongoing innovations and the embrace of digital, multinational operations in noting that the industry reflects that of global tech.

“This looks and feels more like an international ‘big tech’ than where gambling companies were only 20 years ago,” he said.

And that clearly has implications not just for how they operate but how they impact on consumers and how we as regulators need to do our jobs as well.

“When combined with the highly competitive market that gambling companies find themselves in across many jurisdictions, this has led to a number of trends that the Commission wants to flag.”

This first placed the pace of M&A under the microscope, with top three operators in Great Britain having increased market share from a third to half in just five years.

Furthermore, it was also noted that the top 10 operators now represent 77 per cent of total B2C GGY in Great Britain, with the top three accounting for over 50 per cent. 

“Of course these deals continue to get more complex,” he said. “More multi-layered. And so more expensive to investigate from our perspective as the regulator.”

Furthermore, in addition to suggestions that the lines “are becoming increasingly blurred” when it comes to novel products, such as NFTs and cryptocurrency, the issue of illegal online gambling was also looked into.

“This is of course a concern for all regulators and the Gambling Commission is no different. We are particularly focused upon those so called ‘not on gamstop’ sites and we have directed more resource to it over the last year,” Miller explained.

“This is especially insidious as these sites and their affiliates target people who have sought to self-exclude from gambling. Even well known publications like Readers Digest have been promoting such sites in their paid content and have ignored requests from us to remove it.

“As a result our efforts will increasingly be further upstream to seek to disrupt these illegal sites as much as possible and to work with regulators around the world, including placing pressure upon those jurisdictions that host and even licence many of these illegal sites. 

“But we will never accept the argument that because an illegal online option exists, this should mean that the regulated gambling sector should have lower, less fair or less safe standards.

“Britain is, and must continue to be, a world leader in providing consumers with a fair and safe gambling market.”

This saw the importance of international collaboration between regulators delved into, with the need to ensure that each aforementioned issues become more manageable, with less confusion and better all around results.

“So let’s take illegal online gambling then. What might be illegal in one jurisdiction might not be in another,” he continued. 

“Similarly, some jurisdictions don’t yet regulate online gambling at all and most regulators are largely focussed on what operators are doing in their own jurisdictions. Let’s also remember that legitimate, licensed operators from one jurisdiction can actually be the illegal or black market in another.

“No one gambling regulator can be the world police, taking gambling companies to task for everything they do in any part of the world. We aren’t resourced to work like that, we don’t have the powers to do that and it’s not what we’re set up to do.

“But that doesn’t mean we should ignore what an operator who is licensed or based in our jurisdiction is doing elsewhere, especially if that calls into question their suitability to hold a licence. 

“Where strong relationships already exist between regulators we are increasingly seeing the bad practice and bad behaviour of some operators being shared and discussed. And that helps us look at those operators’ practices and operations in our own jurisdictions.

“To be clear: No operator should want to be in this position. No operator should want to be the subject of discussion between regulators in different parts of the world.”

However, no address by the UKGC Executive Director would be complete without glace being taken to the ongoing Gambling Act review and white paper publication, with Miller reiterating that, despite these ongoing efforts “we have not stopped making gambling safer, fairer and more crime free”.

He concluded: “But clearly there is more we want to do with our partners and fellow regulators as well. So we will continue to share best practice, engage with our fellow regulators to share our experience and to learn from theirs. 

“We will look for areas where we can work together to call out concerning practice or products – speaking with one voice, across regulators. And we will build on what we are already doing to appropriately share intelligence and proven bad practice by operators with regulators who are willing to do the same.

“Whatever a given jurisdiction’s model of regulation – from prohibition to liberalised – gambling is global. So if gambling regulators are to keep on making gambling safer, fairer and crime free, we need to go global too. 

“We need to keep looking for ways to work together, to drive standards up and to give consumers a high quality and safe gambling experience.”

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These comments came from Tim Miller, UKGC Executive Director, at the recent CMS Conference, in which it was also said the above move could be a way to be more transparent in how such sanctions are calculated.

It was added that consideration will also be given to expanding the personal management licence regime in a bid to increase accountability.

This comes after Miller noted that the regulator remains “concerned by the potential that gambling has to cause harm. Harm that sadly still becomes a reality for hundreds of thousands of people in Great Britain today. 

“We are also still, too often, having to take action to enforce our other licensing objectives where operators are failing to keep crime out of gambling or to keep it fair and open.”

Furthermore, it was also revealed that, after undertaking stakeholder discussions in which a number of concerns were raised, the UKGC is also looking to change how it seeks such views and carries out consultations.

“Two messages came out clearly, firstly, people feel that we sometimes take a scattergun approach to consultations,” Miller commented.

“We find an issue and we push out a consultation, regardless of what else is going on or what else we have asked operators to do or provide views on at that time. 

“This makes it hard for stakeholders to plan the time needed to respond and, where necessary, to implement changes. 

“Secondly, people have also questioned whether consultation responses really make a difference to the outcome. A concern that sometimes the question is so narrow or the minute details seem so locked in that stakeholder views won’t change anything.”

This would see the introduction of what are called ‘consultation windows,’ which would aim to produce a more predictable pattern for all those concerned.

“We are aiming to set out two periods a year where any consultations will be published, meaning a more predictable pattern for operators, lawyers and other stakeholders to plan when they need to be ready to submit evidence,” Miller continued.

“It will also mean that updates to LCCP and guidance in turn become more predictable, helping industry keep on top of their obligations. 

“I can’t promise we won’t ever be forced to issue a consultation outside these periods but that should be the exception rather than the rule and we would clearly explain why we needed to depart from the usual ‘window’.”

In addition to voicing concerns of “gamblification,” Miller also briefly address a post-pandemic world where “the growing and competitive global market means the pace of mergers and acquisitions has continued to accelerate.

“The four biggest operator groups in Great Britain all have significant international footprints. They also, for the first time, will make up more than half of the British market by gross gambling yield when you exclude the National Lottery,” he said. “And we expect this trend to continue in the near future”.

Elsewhere, the UKGC exec moved on to detail the importance of cross-border partnerships in tackling ongoing challenges being encountered, noting that “our collaborative approach doesn’t end at the White Cliffs of Dover”.

“It is clear that there is a growing appetite for regulators across Europe, and indeed more widely, to work much more closely together,” Miller closed. 

“The risks that can come from the so called ‘black market’ is just one of those issues that really lends itself to cross-jurisdictional cooperation. 

“In particular, where an operator that is licensed in one jurisdiction is operating illegally in another regulated jurisdiction there seems to be considerable scope for those two regulators to take more coordinated regulatory action – for illegal activity in one regulated jurisdiction to have regulatory consequences in another. 

“It is my hope and expectation that you will see more and more examples of regulators working in lock step across international borders.”

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Commissioned by the Department of Health and Social Care, the PHE review acknowledged that overall participation in online gambling for at-risk gamblers (23.4 per cent) was more than double that of the general population of gamblers not under the “at-risk” banner (9.4 per cent).

It estimated that 0.5 per cent of the adult population have a problem with gambling, with 3.8 per cent at risk of problem gambling, while seven per cent are negatively affected by other people’s gambling. 

Harmful gambling is said to have a different “activity profile” to general gambling, with PHE noting that online wagering – including slots, casino and bingo games, electronic gambling machines in bookmakers, sports and other event betting – has a high participation rate among harmful gambling. The National Lottery, however, is said to have a low rate of participation. 

“There is so much more at stake from gambling than just losing money – from the toll on mental health to the impact on those around the gambler,” explained Rosanna O’Connor, director of Alcohol, Drugs, Tobacco and Justice at PHE.

“The evidence is clear – harmful gambling is a public health issue and needs addressing on many fronts, with an emphasis on preventing these harms from occurring as well as with help readily accessible for those directly and indirectly affected by the wide ranging and long lasting negative impacts of gambling.”

The government’s investigation into evidence on gambling harm, which it states is “the most comprehensive estimate of the economic burden of gambling on society to date”, revealed that the harms associated with gambling cost “at least” £1.27bn in 2019 to 2020 in England.

As part of the PHE assessment of the social and economic burden of gambling, six studies were undertaken to provide feedback on stakeholders’ views of gambling related harms recorded across England. 

The analysis includes the first estimate of the economic cost of suicide – £619.2m – and provides an updated cost of homelessness associated with harmful gambling, which the report states is £62.8m.

The review showed that people at risk of gambling harms are concentrated in areas of “higher deprivation”, such as the North of England, with the North East having the highest prevalence of at-risk gamblers, currently 4.9 per cent, closely followed by the North West at 4.4 per cent. The South East recorded the lowest prevalence at three per cent. 

The report noted that “due to small numbers, it was not possible to determine the levels of problem gambling for each region in England with any statistical significance”.

Jim McManus, vice president of the association of directors of Public Health, stated: “This evidence review from PHE paints a stark picture of the avoidable harms from gambling to the economy, society and the individual. 

“Again, we see that existing regional inequalities are exacerbated by these harms with those from poorer areas at higher risk from the negative impacts.

“A public health approach, with cross-government support, properly funded, is essential to reducing harmful gambling and all the negative consequences highlighted by this research in relation to debt, relationships and jobs.”

The impact of gambling among children and young people was also reviewed, with the report stating that participation in any form of gambling in “the last seven days” has reduced from 23 per cent in 2011 to 11 per cent in 2019. Participation in gambling activity within the last 12 months also fell from 39 per cent in 2018 to 36 per cent in 2019. 

The latest figures in the review highlighted that the extent of gambling among children and young people is lower than drinking alcohol, yet higher than using either electronic or tobacco cigarettes and illegal drug use. 

The review found that there “may also be a relationship between these other harmful activities and gambling”, but provided no evidence nor statistics to support the claim. 

“Harmful gambling is a major public health issue which seriously impacts on health in a number of ways,” added Faculty of Public Health president, professor Maggie Rae. “As well as suicide and severe mental health problems, this report highlights harms caused by gambling including financial, employment, relationships, physical health, and criminal activity.

“Gambling organisations are preying on people’s addictions, and we see that the burden of gambling harms is borne by those already facing disadvantage, serving to widen existing health inequalities. This report is welcome as it highlights the wide range of harms caused by gambling, and calls for concerted action to tackle this major public health problem. 

“This urgent call is especially timely as we have seen these problems exacerbated by the COVID-19 pandemic.”

On the impact of the global pandemic, PHE’s rapid review noted an overall reduction in gambling following the first lockdown, and either no change or reduction in frequency of betting activity. 

Though there was an increase in online gambling, it was reported as “small”, rising from 1.5 per cent to 2.3 per cent. Four per cent of participants in the study claimed to gamble more during lockdown with 20 per cent of problem gamblers admitted to further gambling activities within the same period. 

A further two studies, conducted in Europe by using data on online gambling participation, also found reductions in online betting between March and April 2020, with the studies using data from gambling providers. 

PHE disclosed that the studies were conducted “during the early stages” of the pandemic, with further understanding needed on the long term effects on gambling participation during COVID. 

Tim Miller, executive director at the Gambling Commission, responded to the review: “We are pleased to welcome this important independent report from Public Health England.

“Protecting people from gambling harms is a priority for the Gambling Commission, and we take a public health approach to do so. Public Health England’s work will help to support the continuing collaboration of a wide range of bodies under the National Strategy to Reduce Gambling Harms.”

The conclusion from the PHE’s 2005 Gambling review stated that “evidence suggests that harmful gambling should be considered a public health issue because it is associated with harms to individuals, families, close associates and wider society” with an approach that “focuses on prevention, early intervention and treatment.”

The fresh approach will see the new Office for Health Improvement and Disparities work “closely with other departments”, including the DCMS and key stakeholders, to develop a workplan to address knowledge gaps, improve data collection and deliver an effective response to gambling-related harm. 

Responding to the review, gambling minister Chris Philip, added: “We are gathering all the necessary evidence to reset the balance between giving adults the freedom to choose how they gamble safely, with the right protections for those at risk of harm.

“We are determined to protect vulnerable people from exploitation by aggressive advertising or unfair practices that entrench problem gambling.”

To read the full review, click here.

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The three-year programme will focus on education and prevention, and provide access to support and treatment for individuals and their families experiencing problem gambling.

Led by Public Health directors, and delivered as part of the National Strategy to Reduce Gambling Harms, Yorkshire and the Humber will deliver a coordinated and comprehensive approach to gambling harm across the region. 

Greg Fell, chair of the Yorkshire and Humber harmful gambling working group, said: “We aim to deliver a gold standard programme that can be replicated across the UK.  

“We are in the unique position of having a diverse population across city, town, rural and coastal environments, which offers the potential for an effective activity blueprint that could be used by other regions.

“We know high deprivation areas and low income workers are disproportionately negatively affected by gambling, so this will be our focus.”

The programme aims to improve identification of problem gambling through training in workplaces, direct gamblers to self-management and support, protect high risk and vulnerable groups from gambling-related harm, and will work with individuals and communities to raise awareness and reduce stigma.  

Tim Miller, executive director at the UKGC, noted: “We welcome this ambitious project across Yorkshire and Humber. A cohesive public health approach to tackling gambling harms is exactly what the National Strategy to Reduce Gambling Harms aims to stimulate. We are pleased to be able to approve the funding, which was agreed through a regulatory settlement.”

Adding: “Gambling is a problem when it impacts, disrupts or damages an individual, their family or interferes with daily life. It is vital we do all we can to protect the most vulnerable in society, given the pace at which the gambling industry is growing and developing.”

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Ahead of a package of changes being implemented in a bid to make online games safer, Miller examines key areas of focus for the regulator and a planned next consultation, as well as issuing a note of caution to operators regarding data provided through the regulatory returns process.

“We are not just working in this way to make gambling fairer and safer. We also adopt the same approach to keeping crime out of gambling,” Miller continues when addressing the impending changes to online slots.

This will bring a ban on features that speed up play or give the illusion of control over the outcome; spin speeds faster than 2.5 seconds; auto-play; and sounds or imagery which suggest a win when the return is equal to, or below, a stake; from October 31.

“One example that illustrates the point is our work around illegal online gambling. The Gambling Commission is alive to this danger and regularly takes action to cut off or shut down these sites,” he says. 

“But the solution to tackling that black market is not to cease taking action to make regulated gambling safer”

“With rapid changes in technology we know we need to be increasingly fleet of foot and may need a broader range of tools to tackle emerging risks. We are pleased that the review of the Gambling Act includes a focus on the powers and resources of the Commission. 

“Industry and others are right to flag the risks that can come from the black market. But the solution to tackling that black market is not to cease taking action to make regulated gambling safer. 

“We won’t legitimise poor practice at home through fear of what might be happening elsewhere. Making gambling safer and keeping crime out of gambling are not mutually exclusive and we will continue to pursue both of those objectives rigorously.”

Before looking at customer interaction, and warning that the industry must do more: “We continue to see example after example of operators who have allowed people to gamble amounts that clearly place customers at risk of harm with very limited or no customer interaction until a very late stage,” Miller continues.

“Just to be clear, we are not talking about grey areas here. We are talking about significant binge gambling or clearly unaffordable levels of gambling without action being taken. 

“Can anyone in this room seriously justify allowing a new customer to lose £10,000 within minutes without any checks or interaction? It is issues such as these that we are seeking to address in our customer interaction proposals. 

“Going back to our licencing objectives, the Gambling Commission has a duty ‘to aim to permit gambling’ as long as it is in line with the licencing objectives. But we will not permit operators to continue to place their commercial objectives ahead of customer protection.”

Following on from a recent consultation that focuses upon customer interaction, and which brought approximately 13,000 responses, Miller adds that the UKGC’s next step will be on thresholds for identifying key financial risks: when it comes to significant losses in a very short time, significant losses over time and financial vulnerability.

“…the quality and timeliness of data from industry is the single biggest limiting factor”

“We are mindful of the fact that there is an ongoing review of the Gambling Act and do not plan to consult on issues that are rightly for that review,” he adds.

Of the review, Miller welcomes the structiny which will hold the Commission “to account for how we deliver our role to support the licensing objectives”.

Adding that it could ultimately provide “a helpful opportunity to look at our powers and resources so that we can ensure that the Gambling Commission is fit for the challenges that we will see over the coming years and that our performance is as strong as it can be”.

Moving on, and citing National Audit Office scrutiny of the way the regulator uses data as a regulatory tool, Miller asserts that “all the investment in the world will not deliver a more effective Gambling Commission if the data we receive from operators is lacking”.

Concluding: “Historically, we have needed to carry out huge amounts of quality assurance on the data provided through the regulatory returns process. Returns have been late, or sometimes not delivered at all, with many returns being full of errors. 

“Despite this being an LCCP requirement, some operators have thought it acceptable to, in effect, outsource the quality assurance of their data to the regulator. This is not something that can continue.

“Industry and others should rightly hold our feet to the fire to ensure that our work is grounded in evidence. But the quality and timeliness of data from industry is the single biggest limiting factor.

“In next year’s business plan we will set out a programme of target compliance and, if necessary, enforcement action around the quality and timeliness of the regulatory returns we receive. 

“So I would strongly encourage operators to use the remainder of this business year to ensure your data quality processes are robust and fit for purpose.”

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In the new partnership, GREO will work alongside the UKGC to launch a new activity programme tailored towards supporting the National Strategy’s key focus areas: treatment and education, treatment and support. 

Tim Miller, executive director at the Gambling Commission said: “The new role for GREO to support the National Strategy is a perfect example of the collaboration we called for in the strategy.

“GREO is a well-respected independent research organisation with a wealth of experience in gambling research and dissemination. Ultimately, their expertise, networks and insight will help us and our partners to accelerate progress over the next three years.”

GREO will work towards research and policy implications for the gambling regulator, while also analysing potential international collaborations for the UKGC.  

Trudy Smit Quosai from Gambling Research Exchange said: “We are thrilled to announced our work as part of the National Strategy to Reduce Gambling Harms. It means we will be working with the best thinkers around the world to help tackle the issue and provide independent, evidence-based research to support the strategy’s priorities.”

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