The Gambling Commission Is About to Vote Itself More Power. What Could Possibly Go Wrong? 🎰💀

Posted by Geoff Banks | geoffbanks.bet

Somewhere in a Birmingham office, a group of unelected bureaucrats are preparing to vote on whether to impose Financial Risk Assessments on British punters. No parliamentary mandate. No independent scrutiny. No published final pilot report. Just a Board nodding through what they spent six years lobbying for. 🙄

I know. Shocking.

Let’s set the scene. The Gambling Commission’s previous CEO, Andrew Rhodes, departed on 30 April 2026. His replacement as Acting CEO? Step forward Sarah Gardner. The same Sarah Gardner who once told a Danish regulator that she simply cannot accept the argument that driving customers off the regulated market and into illegal alternatives should slow down the Commission’s regulatory ambitions. Cannot accept it. Just won’t have it. 🚫

So the person who has declared black market growth an irrelevance is now running the organisation about to greenlight the policy most likely to cause it. Wonderful. Truly wonderful.

The Math That Isn’t Adding Up 🔢

The Commission’s Director of Major Policy Projects, Helen Rhodes, published a blog in April 2026 reassuring us that only “less than 3% of active customer accounts” would trigger any steps under the FRA proposals, and that 97% of those assessments would be completely frictionless.

Let us pause here and appreciate the artistry.

Three percent of accounts sounds tiny. A rounding error. A statistical footnote. Except the UK has roughly 22 million active betting accounts. Three percent of that is 660,000 people. 660,000 people who will, in the GC’s own framing, have their credit file silently interrogated by a third party data provider without their knowledge or consent, with no appeal mechanism, and with the operator obliged to act on whatever the algorithm spits out.

“Frictionless” for whom, exactly? 🤔

And remember: these are accounts, not people. Many regular punters hold accounts with multiple operators. The same individual triggers the check five times over. The 3% figure is not a measure of consumer impact. It is a number designed to sound reassuring in a press release.

The People Being Targeted Are Not the Problem 🏇💷

Here is the part the Commission really does not want you to think about too carefully. Because when you do, the entire FRA architecture collapses.

The 3% of accounts facing the heaviest scrutiny under FRAs are, by definition, the highest staking customers in the regulated market. These are not, in the main, problem gamblers. They are the economic engine of British horse racing and of the licensed betting industry as a whole.

Dan Waugh of Regulus Partners put it plainly: the problem gambling rate for people who bet on sport online is, in his words, “microscopic” unless those customers are also engaged in online casino products. Horse racing specifically has a lower problem gambling rate within sports betting than almost any other category. 📉

So who does suffer gambling harm at meaningful rates? The evidence consistently points not to the high rolling racing punter sitting in the Members at Goodwood, but to lower income individuals engaged in high margin, high frequency products. Online slots. Fixed odds terminals. Products with house edges of 4%, 10%, 40%. Products where consistent, predictable losses grind down people with less financial resilience. The GSGB data shows that problem gambling prevalence is modestly higher in lower income groups. The open banking studies the Commission itself commissioned showed that, interestingly, the most financially concerning gamblers had income levels around 21% above the average. Higher stakers tend to be higher earners. That is not a surprise. It is arithmetic. 💡

Yet the FRA architecture is calibrated to trigger on spend volume, not on product type, not on income ratio, not on any actual indicator of distress. And spend volume is exactly where the racing punter lives.

SharpBetting’s modelling of different customer types under the EFRC regime tells the story with brutal precision. A roulette player placing hundreds of small bets per day at a 2.7% house edge loses around £5,000 a year. They are almost never triggered for a check. After five years, only 2% of simulated roulette accounts faced an EFRC. An acca punter betting £20 a day on long shot multiples loses £2,690 a year on average. Never triggered once. Not a single check.

Meanwhile a Racing Enthusiast placing £25 bets on two selections a day at 8/1 loses around £1,800 a year. That is less than either the roulette player or the acca punter. Yet 76% of Racing Enthusiast accounts are triggered for a check by year three. A Form Student placing a single careful £500 bet every fortnight on a studied selection loses around £250 a year. 97% of Form Student accounts face a check by year three. She loses the least. She gets checked the most. 🤦

This is not a consumer protection regime. This is a system that identifies and interrogates the customers who bet intelligently on horse racing while waving through the customers who lose more money on online casino games. It is as if the policy were specifically designed to cause maximum disruption to the sport and product with the lowest harm profile in the entire regulated market. 🎯

And the economic consequences of targeting precisely this cohort are devastating. Horse racing receives the Horserace Betting Levy, which last year generated £108 million. That sounds significant. But it is only a fraction of the total. When media rights, sponsorship, marketing and promotional activity funded by betting operators is included, higher staking customers contribute close to six times the value of the Levy back into the sport. We are talking about an economic relationship worth hundreds of millions of pounds to an industry employing tens of thousands of people, sustaining racecourses from Carlisle to Cheltenham, and underpinning the livelihoods of stable staff, trainers, jockeys, vets, bloodstock agents and everyone else in the ecosystem. 🏟️

The Racing Post’s Big Punting Survey found that among those regularly staking £500 or more, more than 50% had already been subjected to affordability checks. Not 3%. More than half. These are the customers on whom racing’s financial survival depends. One in five of those betting at £100 a time has already used a black market bookmaker in the last twelve months. More than one in three of those betting at £1,000 or more per bet has done so. They are not leaving the market because they cannot afford to bet. They are leaving because they are being treated like suspects while the regulator focuses its ideological firepower on the wrong product, the wrong customer, and the wrong type of harm entirely. 🚨

The Commission wants you to believe FRAs are about protecting the vulnerable. The evidence says they are systematically harassing the financially robust while doing next to nothing for the genuinely at risk. It is the regulatory equivalent of conducting drug searches at the golf club while waving through the inner city. And the sport that pays the price is the one that had the lowest harm rate to begin with.

The Commission vs The Commission 🥊

Here is where it gets genuinely funny. If you enjoy regulatory self-contradiction as entertainment, which you absolutely should.

The GC’s Compliance and Enforcement Report for 2019 to 2020 stated, in black and white, that customers wishing to spend more than the national average should be asked to provide payslips, P60s, tax returns or bank statements. Operators were told this was what compliance looked like. Fines followed for those who failed to implement it.

Fast forward to April 2026. Tim Miller, the Commission’s Executive Director, told the Ethical Gambling Forum that in 2026 it cannot be right that regulatory compliance still leads to some operators asking consumers to share financial documentation.

So operators were fined for not asking for documents. And now the Commission is appalled that operators are asking for documents.

The Commission spent four years training bookmakers to demand your payslips, and is now standing in front of a camera looking baffled that bookmakers are demanding your payslips. It is the regulatory equivalent of arson followed by a vigorous public statement condemning fire. 🔥🔥🔥

The Pilot Nobody Reviewed 🕵️

The entire justification for the Board vote rests on the FRA pilot. A pilot that concluded in summer 2025. A pilot for which no final, published, independent evaluation has been made available to the public, to Parliament, or to the industry.

Helen Rhodes’ April 2026 blog was described as an “update on post pilot analysis.” It was a Commission blog post. Written by a Commission employee. Reviewed by the Commission. Published on the Commission website to inform a Commission Board decision.

Dan Waugh of Regulus Partners put it well: the Commission cannot be allowed to mark its own homework, particularly when the dog has a habit of chewing inconvenient facts out of any assessment it undertakes.

No independent review. No OSR sign off. No parliamentary debate. No published data. Just a blog.

This is the evidence base on which they are voting. Take that in. 🤦

408 People Who Know More Than You Do 📢

Over 400 of the most senior figures in British horse racing, including trainers, owners, racecourse executives, and industry veterans, signed an open letter to Culture Secretary Lisa Nandy warning of the catastrophic consequences of FRA implementation. The BHA chief executive warned publicly that the government was sleepwalking into disaster. The Racing Post ran weeks of frontpage coverage detailing consumer harm, black market growth, and the chill on racecourse betting rings.

The Commission’s response? “Much of it has been ill informed or inaccurate.”

Yes. John Gosden: ill informed. The BHA board: inaccurate. 408 signatories representing billions in economic activity: not quite up to speed.

Meanwhile the Commission, whose leadership has no professional background in racing or betting, and which derives much of its ideological scaffolding from public health academics funded by a California based anti gambling billionaire, is, apparently, the voice of reason in this debate. 🎓💰

The Black Market Elephant 🐘

The Racing Post has reported that black market betting now accounts for an estimated 20% of UK racing turnover. William Hill owner Evoke has cited black market penetration as a factor in its UK revenue decline. Multiple senior racing figures have publicly admitted to betting on unregulated sites because they cannot get a bet on in the licensed market.

Sarah Gardner, the new Acting CEO, cannot accept this argument.

The unlicensed operators she cannot be bothered to worry about do not verify age. They do not contribute to the Horserace Betting Levy. They do not fund GamStop. They have no safer gambling obligations whatsoever. They take from the sport and give nothing back. And they are growing precisely because the regulated market is being made progressively more hostile to anyone who wants to have a proper bet.

But sure. Let’s vote to make the regulated market even less accessible. That will definitely fix the problem. 🤡

What Happens Next 📅

The Board votes. FRAs go through. Operators implement. The 3% that becomes 660,000 accounts gets their credit files silently checked. A meaningful proportion of those have insufficient credit data, or flags from financial difficulties unrelated to gambling, or simply do not match the threshold. Their operators are obliged to interact with them. Some will comply with whatever is asked. Many will not. They will close their accounts and open new ones on unlicensed sites based in Curaçao or Gibraltar or nowhere at all.

The Racing Post will write about it. The Commission will say the coverage is ill informed.

The Levy will fall. Racecourses will struggle. Small yards will close. Rural jobs will go.

The Commission will convene a working group to study the issue. They will publish an update blog. It will be written by a Commission employee, reviewed by the Commission, and published on the Commission website.

And somewhere, a Curacao sportsbook will be counting its new British customers and wondering what all the fuss is about. 💻🌴

The Gambling Commission is not a public health body. It is not a Treasury department. It is a licensing authority with a statutory duty under s.22 of the Gambling Act 2005 to aim to permit gambling. That duty has not been repealed. It is simply being ignored.

Vote against it. Write to your MP. Tell the BHA. Tell the BGC. Make some noise.

Because the Commission is about to make a decision it cannot be held accountable for, using evidence it will not publish, on behalf of consumers it does not represent, with consequences it refuses to acknowledge.

And nobody is stopping them. 🚨

Geoff Banks is a licensed remote betting operator. Views expressed are his own.

GamScore Wants to Save You From Yourself. By Reading Your Bank Statement. Three Times a Day. 🏦👀

🎰 Gambling Reform  |  Consumer Rights

A new app promises there is “no negative for anyone” in handing over real-time access to your entire financial life. British punters will forgive a degree of scepticism.

geoffbanks.bet  ·  May 2026

There is a sentence in the GamScore press release that deserves to be read slowly, preferably while sitting down with a strong cup of tea. ☕

“There’s no negative for the regulator, the operator and the consumer. It’s a massive tick for all of them.”

No negative for anyone. Not one. A massive tick all round. I have not encountered language this comprehensively reassuring since the last time a bookmaker wrote to inform me that my account remained technically open but my maximum stake on British horse racing had been adjusted downward for operational reasons. No negative whatsoever. Massive tick. 👍

GamScore is a new consumer ‘wellbeing’ app launching in October 2026. It will use open banking to read your bank account three times a day. It will feed everything it finds into an algorithm that generates a personal risk score. (out of ten??) Your bookmaker will have access to that score. It will flag activity consistent with offshore or unlicensed betting and report aggregated intelligence about that activity to regulators. And it will do all of this, the company cheerfully announces, for free. 🆓

For free! Splendid. That settles it then.

“When someone in the gambling industry tells you there is no negative for the consumer, check your pockets. There is always a negative for punters. And I am a Bookie.”

🔍 What Open Banking Actually Means

Here is the thing about open banking that GamScore’s marketing materials glide past with considerable elegance. When you grant open banking access to a third party, they do not see only your gambling transactions. 🎯 They see your entire current account. Every debit. Every credit. The mortgage. The salary. The Tesco shop. The school fees. The Pornhub subscriptions. The VPN subscriptions (ties into Pornhub ecosystem) The private medical invoice. All of it. Labelled, dated, and now sitting on someone else’s servers. Somewhere.

GamScore says it is looking at your gambling behaviour. What it is actually receiving is a continuously updated picture of your entire financial life, refreshed three times a day. The gambling transactions are perhaps five lines out of five hundred on a typical monthly statement. GamScore gets all five hundred. 📊

That data, incidentally, is commercially extraordinary. Income verification. Spending patterns at merchant level. Debt signals. Payday correlations. The kind of information financial services firms spend serious money trying to infer. GamScore receives it directly, at no cost to itself, because you blithely handed it over in exchange for a dashboard, a score, and, let’s face it, a sporting Yankee. Lovely dashboard though, presumably. 💻

🕵️ The Privacy Policy That Forgot the Product

At this point you may be wondering what GamScore’s published privacy policy says about all of this data? Or maybe you just don’t care? 🤔

The privacy policy, published 1st May 2026 and generated using a free online tool called CookieYes, lists the personal information it collects. There are three items. Your name. Your email. Your mobile number.

That is it. 🫠

The open banking data does not appear. The transaction history is absent. The AI risk score is absent. The black market activity flags are absent. It is, as one commentator elegantly put it (and I am stealing it), the data protection equivalent of a surgeon’s consent form that mentions car parking but omits the surgery.

The policy does note that it may be revised “at any time without any prior notice,” with new terms taking effect 180 days after posting, and that your continued use of the app constitutes acceptance. So the rules governing what GamScore does with your bank account can change, unilaterally, without telling you, and your silence counts as agreement. British punters are, of course, broadly familiar with arrangements in which the rules change without warning and silence is treated as consent. We encounter it every time we try to place a bet at a reasonable stake. 🙃

🏴‍☠️ The Black Market Monitoring Twist

Here is the detail that deserves more attention than it has received. GamScore will not merely monitor your activity at licensed operators. It will identify “behavioural patterns consistent with unregulated betting” and provide “regulators with aggregated insights into market trends.”

Consider the population of British bettors currently using offshore operators. Many of them are there because they were driven there by document demands, account restrictions, and stake limits from licensed bookmakers. Having escaped one surveillance regime, they are now being offered a consumer ‘ ‘wellbeing’ app (bless them) that will identify their offshore activity and report it upstream to the same regulatory infrastructure that created the problem in the first place. 🔄

The app that promises to fix affordability checks will, as a design feature, flag the people who left because of affordability checks. There is a circularity here that should give everyone nightmares. 🤯

😍 A Regulator’s Wet Dream

Let us pause and consider who benefits most elegantly from this arrangement, because it is not the punter. 🎯

The Gambling Commission has spent years trying to build a comprehensive surveillance architecture around British bettors. It has faced parliamentary opposition, judicial review threats, accusations of acting ultra vires, a public petition signed by tens of thousands, and sustained pressure from the racing industry. Every step toward a mandated financial monitoring regime has come with a political and legal cost. GamScore solves all of that in one move. 🪄

Think about what the Commission gets here. It gets a single customer view of British bettors’ financial lives, updated continuously, without having to amend the LCCP. It gets black market intelligence it has never been able to gather systematically, fed to it as aggregated regulatory insight, without having to build the infrastructure itself. It gets a compliance lever over operator customer management without having to fight another consultation. And crucially, it gets all of this while maintaining perfect plausible deniability. The Commission did not mandate GamScore. Consumers chose it freely. The regulator merely expressed enthusiasm (exploded all over themselves) for innovative solutions and the market responded. 🙄

This is the dream of every regulator that has ever been frustrated by democratic accountability. Outsource the surveillance to a private company. Let consumers opt in voluntarily. Call it empowerment. Receive the data. The Gambling Commission has been trying to get a real-time view (peer up your crevice with a davy lamp) of bettor financial behaviour since at least 2020. GamScore proposes to hand it over, funded by consumers themselves, wrapped in a wellness dashboard and a personalised score. If the Commission endorses this, and the press release strongly implies it will, it will have achieved through a Swindon startup what six years of formal consultation could not deliver. The punter pays for his own monitoring. Everybody wins. Except, err, the punter. 🏇

💰 The “Free” Question Nobody Is Answering

GamScore Phase 1: consumer wellbeing app. Free. October 2026.

GamScore Phase 2: operator compliance tool. Sold to bookmakers. Early 2027. 💼

Within roughly three months of consumers downloading the free ‘wellbeing’ app and granting access to their bank accounts, GamScore monetises that infrastructure as a compliance product sold to the bookmakers those same consumers bet with. The consumer is not the customer. The consumer is the dataset. 📦

This is not a conspiracy theory. It is the stated business model, laid out in the press release in plain English. Phase 1 acquires the data. Phase 2 sells it. The only question is why nobody has asked about it more directly. Well, at least until contrarians like me came along

“The friction, it turns out, was the form-filling. The surveillance was always fine.”

🤝 The BHA’s Interesting Position

The BHA, which has spent several years vocally opposing affordability checks on the grounds that they are intrusive and treat ordinary bettors as suspected criminals, has described GamScore as “an interesting intervention.” Ok, thanks for playing. 🧐

🎮 How Operators Will Actually Use This

GamScore describes its Phase 2 product as a “single customer view.” That phrase deserves unpacking because it sounds fluffy and warm, and is neither. 🔬

British punters already know what operators do with information about their betting behaviour. They restrict your stakes. They close your account. They limit your markets. They do all of this unilaterally, without explanation, without appeal, and without any obligation to tell you what triggered the decision. The legal framework gives operators near total discretion over who they serve and on what terms. That has not changed. What GamScore changes is the quality and granularity of the information feeding those decisions. 📉

Currently an operator sees what you do on their platform. With GamScore’s single customer view, they see what you do everywhere. Your profit and loss across multiple accounts. Your betting frequency patterns across competitors. Your financial trajectory from your bank statement. Your chasing behaviour identified by an AI that updates three times daily. All of it processed, scored, and served up to the operator in a conveniently actionable format before you have even placed your morning bet. ☀️

And then what? The press release is silent on consequences, which is the most important silence. Because the BGC Code Handbook already requires operators to take action when indicators of harm are identified. GamScore, feeding into that framework as a Phase 2 compliance product, becomes the trigger mechanism for those actions. Your score drops because you had three consecutive losing days, or perhaps you just paid your wife’s Amex. The algorithm flags it. The operator’s compliance system receives the signal. Your account is restricted before you have spoken to anyone, appealed anything, or been given any opportunity to explain that you are a professional punter having a bad week. ❌

The operator does not have to justify this to you. They never have. They will not start now. What changes is that the decision will no longer even feel like a human one. It will arrive as an automated consequence of a number generated by an algorithm you did not design, running on data you provided under a wellness framing, governed by terms that can change without notice. The bookmaker who previously closed your account because you were winning will now close it because a score said so. Accountability has not improved. It has simply been outsourced to mathematics, which is considerably harder to argue with. 🤖

GamScore calls this empowerment. You own your score. It is on your dashboard. Your name is on the front. Which is rather like being told you own the rope they tied you with. 🪢

⚖️ The Verdict

geoffbanks.bet — Bottom Line

Let us be completely clear about what GamScore is, because the press release has worked hard to ensure you are not. 🎯

It is not a consumer protection product. A consumer protection product protects consumers from external threats. GamScore protects the industry from consumers, by building a continuously updated intelligence file on every bettor who signs up and distributing that file, in scored and processed form, to the operators those bettors use. The consumer is not the beneficiary. The consumer is the subject. 📋

It is not a privacy-respecting alternative to affordability checks. Its privacy policy was generated by a free online cookie tool, covers three data fields, omits the entire commercial foundation of the product, and reserves the right to change its terms without telling you. A product proposing to hold real-time access to millions of British bank accounts has less published data governance than a local dentist’s appointment booking system. 🦷

It is not free. Nothing that costs this much to build and operate is free. What is free is the consumer acquisition. The monetisation is the Phase 2 operator compliance product, sold to bookmakers using the data consumers handed over for nothing in Phase 1. 📦

It is not independent. It has positioned itself explicitly as the answer to a Gambling Commission call for innovative solutions, which means it is angling for regulatory endorsement from day one. An entity that needs the regulator’s blessing to succeed is not going to challenge the regulator’s priorities. It is going to serve them. 🫡

And it will not reduce the black market. Bettors driven offshore by intrusive checks and unilateral account restrictions will not return to a licensed market that now monitors their bank accounts three times a day, scores their behaviour algorithmically, flags their offshore activity to regulators, and feeds all of it to the operators who already restricted their stakes. They will stay offshore. They will tell their friends. The black market does not shrink when the licensed market is put under a commercial microscope. It grows. 📈

The Gambling Commission spent six years and considerable political capital trying to build a financial monitoring regime for British bettors. GamScore proposes to hand them something far more powerful, funded by the bettors themselves, with a wellness logo on the front. If the Commission endorses it, they will have confirmed what critics have argued for years. That this was never about harm reduction. It was always about control. 🔒

There is no negative for anyone, Josh Apiafi tells us. The punter begs to differ. The punter, as usual, wasn’t really part of the conversation. 🏇

THE RIGHT TO BET

HOW THE GAMBLING COMMISSION IS FAILING PUNTERS AND RACING





Betting & Regulation

The Right to Bet:
How the Gambling Commission Is Failing Punters, Racing and the Law

Affordability checks are being imposed on millions of ordinary bettors on the basis of flawed evidence, without legal authority, and with consequences the regulator either cannot see or chooses to ignore. It is time to say so plainly.

Gambling is legal in Great Britain. It has been freely permitted, and indeed actively liberalised, since the Gambling Act 2005 created one of the most open betting markets in the world. The legislation that established this framework also created the Gambling Commission, and it imposed on that body a clear statutory duty: not merely to pursue the licensing objectives of protecting the vulnerable and preventing crime, but to permit gambling, in so far as the Commission thinks it reasonably consistent with those objectives.

That duty is not decorative. It is not a footnote. It sits in section 22 of the Act alongside the harm-prevention objectives, carrying equal legal weight. The Commission was never intended to be a body that restricts gambling whenever it can find a rationale — it was intended to be a regulator that allows a lawful activity to flourish while managing genuine risks. By any honest assessment, it has drifted very far from that mandate.

The “Choice” That Is No Choice at All

In a recent smartbetting podcast interview, Gambling Commission chief executive Andrew Rhodes was confronted with a direct and reasonable question. Punters are currently being told by bookmakers — among them bet365, one of the largest operators in the world — that if they wish to continue betting at certain levels, they must enrol in an open banking service called Bet Budget and grant access to their financial records. In some cases, we are told, this means sharing five years of complete bank account history across all accounts held.

The interviewer put this squarely to Rhodes: is this really a choice? Rhodes replied that it is a consumer choice — they decide whether or not to use open banking. The Commission is not doing this. The operator is doing this. And if you don’t like it, you can choose not to.

This answer deserves to be examined carefully, because it is not an honest account of what is happening.

The exchange — verbatim

“Their choice is adhere to this or you can’t bet with us — so it’s not really a choice, is it?”

— Interviewer, Smart Betting Club Podcast

“It’s a choice as in you can bet or you can’t.”

— Andrew Rhodes, Gambling Commission CEO

That response — “you can bet or you can’t” — is, in effect, an endorsement of coercion dressed up as consumer autonomy. The logic, applied consistently, would justify almost any operator imposition. A bookmaker could demand you provide your passport, your payslips, your mortgage documents and a letter from your employer, and the regulator’s position would be: that’s the operator’s commercial decision, and you are free not to use them. This is not consumer protection. It is the abandonment of it.

What makes it worse is that the Commission has spent years applying regulatory pressure — through enforcement reports, compliance activity, and implied threat of licence sanction — that has driven operators toward exactly this behaviour. The checks that Rhodes presents as “operator choices” are, in very large part, a direct consequence of Commission pressure applied through channels that were never subjected to formal rule-making or parliamentary scrutiny. Operators did not suddenly decide, of their own commercial volition, that demanding five years of bank records from punters was good for business. They did it because they were afraid of what would happen if they didn’t.

The Legal Duty Being Ignored

Section 22 of the Gambling Act requires the Commission to aim to permit gambling. This is not a vague aspiration. It is a positive obligation, and one that has meaningful content. The “reasonably consistent” qualifier that follows it requires the Commission to balance the duty to permit against the licensing objectives — it does not allow harm prevention to operate as an absolute trump card that extinguishes all other considerations.

Consider what proportionality requires in this context. The enforcement cases that provided the Commission’s original justification for pushing operators toward affordability checks involved genuinely extreme conduct: people losing hundreds of thousands of pounds without any check whatsoever, operators treating clearly distressed customers as VIPs. Nobody defends that. Nobody should.

But the regulatory response has not been calibrated to address those extreme cases. It has been applied at a level so far below them that it now routinely catches ordinary recreational punters — people losing a few hundred pounds a month on horse racing, betting within their means, causing harm to nobody — and subjects them to intrusive interrogation about their personal finances. The Commission’s own proposed thresholds would trigger checks at net losses as low as £150 in a month. At one point in the debate, the figure of £1.37 a day was cited as the effective threshold for frictionless financial vulnerability checks. The Commission did not dispute this arithmetic.

It is very difficult to argue that a policy causing documented, serious collateral harm — to a lawful industry, to hundreds of thousands of ordinary consumers, to the financial ecosystem of British horse racing — while failing to demonstrate any measurable reduction in problem gambling rates, satisfies the proportionality test that section 22 implicitly requires.

The “3%” That Tells a Misleading Story

Throughout this debate, the Commission and government have repeatedly invoked the figure that only 3% of accounts will be affected by enhanced financial risk checks. This has been treated as a reassurance — a signal that the vast majority of punters have nothing to worry about.

It is not an honest reassurance. It is a number that has been selected, presented and sustained in its most politically convenient form.

The 3.2% figure comes from a survey of 5.86 million active accounts covering May 2020 to April 2021. It represents the proportion of accounts losing £2,000 in a rolling 90-day period in a single year, at 2020 price levels. From that baseline, the problems compound quickly.

The thresholds were never inflation-adjusted before implementation. By summer 2024, when the policy was due to begin, £2,000 at 2020 prices had risen to approximately £2,528 in real terms. The figures simply weren’t updated. On inflation-adjusted terms, around 4.1% of accounts would breach the 90-day threshold, and 2.5% would hit the 24-hour £1,000 threshold. Because accounts can qualify for both, the true affected proportion is higher still — the Commission’s own analysis confirmed that between a fifth and a quarter of individuals identified by one threshold did not exceed the other, meaning the number of unique individuals affected is notably higher than either figure alone suggests.

More importantly, 3% in year one is not 3% in year three. The process is not stationary. Accounts that avoid checks in year one can breach a threshold in subsequent years as results accumulate. Independent simulation modelling of typical racing punter profiles makes this vivid:

That last figure deserves emphasis. The threshold design is structurally biased. A punter placing modest daily accumulator bets at a high operator margin — losing nearly £2,700 a year — will never trigger a check, because steady daily losses don’t produce the variance spikes that trip the thresholds. Meanwhile a knowledgeable racing punter placing a single £500 fortnightly wager will almost certainly face checks within three years, even if they are profitable overall.

The policy, in short, disproportionately targets the most engaged, most informed, most economically valuable customers of horse racing — while largely ignoring the steady, high-frequency, low-unit gamblers that arguably represent a greater harm risk. This is not a technicality. It is a fundamental design failure that the Commission has never adequately addressed.

Horse Racing: Not Collateral Damage. A Foreseeable Catastrophe.

When the podcast interviewer asked whether the knock-on effect on sports like horse racing was “just collateral damage”, Rhodes demurred. He acknowledged racing’s unique dependency on gambling — 70% of its gross gambling yield comes from just 1% of accounts, five times the concentration of other sports. He acknowledged a declining consumer base. He then suggested that racing has structural problems independent of affordability checks and that it’s “not really for the Gambling Commission to comment on the economics of horse racing.”

This position is not sustainable. The Commission’s regulatory decisions are a direct, proximate, and now quantified cause of racing’s financial deterioration. The claim that this is somehow outside the Commission’s remit is precisely the kind of institutional detachment from consequences that makes this situation so frustrating.

“The Gambling Commission increasingly appears to be unaccountable and out of control. Moreover, they continue to be unable to demonstrate any evidence as to the impact that the current affordability measures are having on problem gambling rates.”— Martin Cruddace, CEO, Arena Racing Company

The numbers are not in dispute. Online racing turnover fell to £8.37 billion in the year to March 2024, compared to around £10 billion two years previously. Had it grown in line with inflation, it would be close to £11.5 billion — a real-terms decline of more than 25%, or a gap of some £3 billion. The BHA’s own data shows turnover year-to-date at end of August 2024 was down a further 9.5%, suggesting the decline is accelerating rather than stabilising.

The levy that funds racing’s prize money, its safety infrastructure, its veterinary research — all of it flows from betting turnover. British racing already receives less than 3% of betting revenue, compared to 7.7% in France and 8.4% in Ireland. It cannot absorb a 25% revenue shock. The mathematics are not complex.

Independent economic modelling by Regulus Partners, commissioned by the BHA, estimated that up to 1,000 stable staff jobs — one in seven — could be lost if the current proposals are implemented in full. These are not executive positions. They are the people who care for 14,000 thoroughbreds in training, who work in rural economies across Britain, who are not rich and who have no obvious alternative employment in the areas where racing yards operate.

“Racing cannot take any more financial setbacks. Racing and betting have come together on this issue like never before, because they know that they face the greatest ever threat to their existence.”— MP Philip Davies, Westminster Hall debate, February 2024

British racing contributes £4.1 billion to the British economy. It employs 80,000 people directly and 100,000 indirectly. It supports 8,000 small and medium enterprises. It touches 60 marginal parliamentary constituencies. It is not a fringe activity of the wealthy. It is a rural industry, deeply embedded in British cultural and economic life, and it is being hollowed out by a regulator that cannot demonstrate that what it is doing is working.

The Black Market: The Risk the Commission Keeps Minimising

Perhaps the most concerning aspect of the Commission’s posture throughout this period has been its persistent tendency to underweight the black market risk. At a Culture, Media and Sport select committee hearing, Rhodes said that every time he had heard someone say people were going to the black market, he had asked them where, and had never received an answer he could act on. This was presented as scepticism about the phenomenon’s scale.

Since then, Yield Sec data has shown a substantial increase in black market gambling, with visits to unregulated sites from UK users tripling during the 2022 World Cup, with peaks during Cheltenham and Royal Ascot — precisely the events most associated with the racing audience being disrupted by affordability checks. Rhodes contested the methodology. He may have points. But the direction of travel is not seriously in dispute, and his earlier scepticism now looks like something he has had to quietly retreat from.

What no one in the Commission’s leadership has grappled with honestly is the fundamental policy logic problem. If affordability checks in the regulated market drive even a fraction of consumers to the unregulated black market, the harm-prevention case for those checks collapses. Black market operators have no safer gambling tools, no self-exclusion obligations, no consumer protections whatsoever. They don’t want winning punters, and they are notorious for not paying out. A policy that displaces people from a regulated environment into that landscape has made those consumers worse off by every measure the Commission claims to care about.

The Commission appears to operate on an implicit assumption that bets which regulated operators are unable to take simply will not be placed. That assumption is not credible. It never was.

What Honest Accountability Looks Like

None of this is to argue that gambling requires no regulation, or that every punter is responsible and every operator trustworthy. The cases that prompted government action — people losing hundreds of thousands without any interaction from the operator — were genuinely indefensible. The regulatory impulse behind affordability checks is not unreasonable in origin.

But reasonable in origin does not mean appropriate in execution. And the Commission has failed, repeatedly and seriously, on execution:

It applied regulatory pressure through enforcement reports and informal guidance without formal rule-making, creating binding practical obligations that were never subjected to legal scrutiny or parliamentary oversight. It allowed years of chaotic, inconsistent, operator-by-operator affordability checking to cause real harm to real consumers before attempting to standardise anything. It cited a “3% of accounts” figure that was stale, not inflation-adjusted, accounts-not-people, and systematically selected to understate real-world exposure. It pushed a pilot scheme to test whether frictionless checks work — after those checks had already been de facto implemented and had already caused the damage the pilot was supposedly designed to prevent. It has been unable, after years of this regime, to point to any evidence that problem gambling rates have fallen as a result. And it has watched a 25% real-terms collapse in horse racing turnover — a lawful industry it is legally obliged to permit — and described it as something it cannot properly comment on.

That is not the record of a regulator carrying out its statutory duty. It is the record of a body that has allowed one interpretation of one part of its mandate to crowd out everything else, without accountability and without evidence that the approach is working.

What Needs to Happen

The government should require the Gambling Commission to publish, before any formal implementation of enhanced financial risk checks, a full impact assessment that quantifies: the reduction in problem gambling rates attributable to current affordability measures; the proportion of consumers displaced to the unregulated market as a result; and the economic damage to horse racing and the wider rural economy. If such an assessment cannot be produced — because the evidence does not exist — then the policy cannot be justified.

The Commission should acknowledge formally, and in its regulatory guidance, that it has a statutory duty to permit gambling, and that this duty imposes a proportionality requirement on everything it does. The harm-prevention licensing objective does not override that duty. It must be balanced against it.

The open banking situation — where consumers are told by regulated operators that they must surrender five years of complete financial data or be refused service — must be directly addressed. Rhodes’ characterisation of this as a “consumer choice” is not acceptable from a regulator that is supposed to ensure gambling is fair and open. It is not open to say to a consumer: hand over your most sensitive personal financial information, or we won’t take your bet. That is not consumer autonomy. It is coercion, and the Commission should say so.

And the racing industry — which operates under a unique statutory funding relationship with the gambling sector through the levy — deserves specific recognition of the disproportionate impact that demand-side restrictions on betting turnover have on its finances. The Gambling Commission’s mandate to permit gambling is especially acute here: if it is permitting the regulated industry to collapse the consumer base for the very betting activity that funds an entire sport, it is not fulfilling its obligations under the Act.

Over 400 leading figures in racing — trainers, owners, jockeys, MPs of all parties — have signed an open letter to the Secretary of State calling for affordability checks to be scrapped. The BHA has warned that the Commission appears to be considering the pilot results without adequate government scrutiny of the consequences. Racing’s turnover is still falling.

The Gambling Commission was created to balance protection with permission. Right now, it is failing at both: it cannot demonstrate the protection is working, and it is presiding over the systematic destruction of a legal, economically vital industry it was legally obliged to protect. That is a regulatory failure of the first order, and it requires a direct political response — not more pilots, not more consultations, not more expressions of good intent.

British punters have a right to bet without being subjected to financial interrogation. British racing has a right to the regulatory environment the law promised it. Neither right is currently being honoured.

This analysis draws on the Gambling Act 2005, the Gambling Commission’s consultation responses and enforcement reports, parliamentary debate records (Hansard, February 2024), independent economic modelling by Regulus Partners, research published by the British Horseracing Authority, the Smart Betting Club podcast interview with Andrew Rhodes, legal commentary by Child & Child, and impact assessments published by gamblingreform.co.uk. All statistics are sourced from publicly available official data or named independent research.

Geoff Banks

CEO Geoff Banks Online

https://geoffbanks.bet

April 2026

‘Axe The Tax’

If one was to pen a business plan for racing, it would have one action plan

  1. When things go wrong in racing’s ship – put the prices up on the bookmakers

Racing, and racetracks don’t seriously consider actually improving the product. They don’t look at days like Super Saturday and decide it needs trimming for effectiveness. They will schedule a race to go off ten minutes after the Grand National, and cut to it by contract stipulation. They put on extra days on racing festivals and fill them with handicaps. Or split championship events like the Cheltenham Gold Cup and the Champion Hurdle. The regulator is ruled by the will of the tracks for wall to wall racing, and cheap black type, and shows no appetite for real change

As a career bookmaker, I’ve always known, whilst not accepting, that racing as a product is disproportionately expensive. I require a much higher margin to absorb exorbitant streaming charges, levy, duty and marketing of the same. Racing does represent a far higher share of my customers interest. That won’t be true of the likes of 365 however, where racing might attract just ten percent of the giants product turnover.

Is it any wonder, therefore, when racetracks like Arena hike their streaming charges up by circa 20 percent, that the likes of Flutter simply say no. Arena was already expensive, for a product that several days a week might have little or no product to display. Bookmakers need content, and they need it to be compete favourably with Man Utd vs Man City. Arena, however, isn’t profitable. To that end I understand the money quest- but you can’t just put the prices up to make yourself look more attractive on the market.

In similar vein racing ‘expects’ a greater levy share. Levy is simply another ‘tax’ bookmakers pay. Racing wants more levy to fund its offerings at a time when the amount of betting on sports in 2024 declined by 9 billion pounds! Exacerbated by highly restrictive business practices such as ‘affordability checks’ which have seen many high end players simply depart the UK market

Let us be clear- affordability checks aren’t the fault of racing. It is policy which emanated from an over zealous gambling commission, embarked on a ‘public health’ mission, rather than acting as the gambling regulator. Racing and racetracks have fought these checks almost isolated. Few bookmakers have publicly said anything. Certainly not the major bookmakers, and their marketing arm, the ‘Betting And Gaming Council.’ Who have publicly supported affordability, rather than challenge deeply unpopular policy. To be fair the BGC has a outstanding record in fail.

Leading the fight, in a leadership vacuum only Racing can create (no CEO for 2 years?) has been Martin Crudace. A smart cookie who heads Arena Racetracks. He’s been an immovable object in the path of gambling reformers. His powerful, persuasive, argument is simple. Affordability checks haven’t reduced the (already world wide low) level of problem gambling by one person. They don’t work. A stance the gambling commission now accepts, but won’t admit (their involvement)

Opposing gambling in pretty much all of its forms is Derek Webb. Webb invented the casino game ‘3 card poker’ – a voracious product so profitable to casinos it often fronts the house. Gambling made him a very wealthy boy, and he sees no irony that he is now using all the money he earned from a highly lucrative casino game into anti activism. Chucking out millions to impose his new morals on the industry. For example funding the opposing candidate to Philip Davies at the last election. Paying for loaded ‘survation’ surveys and other research specifically designed to portray gambling as somehow dirty. He doesn’t accept people’s right to choose. To bet at whatever level they prefer, and under their own controls. Nor their right to the privacy of their data, with demands for affordability and ‘single customer view’ access to people’s finances.

Yet he now appears to have untangled racing from sports betting and by all accounts the SMF (which Webb funds) is working with racing

Also at the altar of sponsored opinions are activists against gambling- like James Noyes. He is a left wing academic, funded by Las Vegas philanthropist Derek Webb. In 2020 Noyes argued passionately, without a shred of evidence, that affordability should be implemented at levels as low as £23 of customer deposits a month. It was an absurd and irrational argument, especially given the clear opposition to such plans from punters. In the last year alone, sports betting has declined by some 9 billion pounds, and hasn’t saved a single individual from harm. Noyes now describes affordability as a ‘fiasco’ yet he drove the policy irresponsibly. He now wants Racing to commit to his new plan- to split horseracing out from all other betting products. Notably sports.

However, he has now managed the conjuring trick of convincing Crudace in the new ‘Axe The Tax’ campaign that racing should speak only for itself. It is a smart move, one would have thought noone would countenance. Noyes, and his benefactor Webb, appreciate that with Crudace and Racing out the way, they can advance their cause to establish gambling, and notably sports betting as a health emergency (The words of Noyes). The removal of horse racing objections representing a major step in SMF ambitions to raise gambling taxes to prohibitive levels, and the acceptance of sports betting as a harmful product. We have even hear Zarb-Cousin argue on the Luck show that horse racing represents less of a welfare issue than greyhounds. Who is he kidding?

The SMF appear to be running the show. They will both, of course, claim that they are not anti gambling, but when you advocate restrictions on gamblers and their activities, sponsorship of gambling, huge tax rises, advocation of affordability checks at absurdly low levels, and prohibitive practices which you absolutely know can only send consumers to the black market? You’re a prohibitionist, you just don’t like being called one.

What is the issue with ‘splitting out’ racing? Well it is exactly like advocating in a supermarket, that the milk, tea and eggs be treated as ‘favourable products.’ The argument is racing to be afforded a low duty rate, and the decrease in duty made up by a commensurate increase in levy! In exchange, racing will ‘stand aside’ from any involvement in the rest of the sports betting package bookmakers sell. This ‘splitting out’ of racing, notably excludes greyhound racing from any tax break. An astonishing position! Thrown to the dogs, as they say?

Aveek Bhattacharya, the Social Market Foundation man at the treasury, was formerly funded by Webb at the SMF, has somehow managed to have himself installed as the head of excise at the treasury. A policy position of incredible influence. The fact that Webb funds the Labour party of late to the tune of 1.5 million raises the more than reasonable speculation of cash for favours. You’re allowed to donate to political parties, but you’re not supposed to expect ‘treats.’ We all accept that to be nonsense. But the relationship with Bhattacharya, the SMF and Webb is undisputed. Webb is playing his orchestra with far more skill than those representing racing and betting, and Noyes believes he can smooch everyone onside, with a campaign of reasonable appeasement.

Bhattacharya, advocates that betting duties be ‘harmonised.’ In said regard his views are aligned with several student politic standard position papers opposing anything humans like to enjoy he has penned in the past. Like smoking, drinking, and of course gambling. He is no friend of anything humans consider enjoyable pastime. The suggestion is sports betting be raised to 21% – the current rate of remote gaming. Racing wants its own level set at 10%. And the difference made up by an appropriate increase in levy. I hope you’re following this?

Well, if this treasury official gets his way, sports betting will be hiked by 40%. Racing thinks it will be exempt, and there’s a more than fair chance that’s precisely what will happen. Since it is a heritage sport all would want to survive. The callous advocation by racing, and the tracks, a form of cognative dissonance, that it should all be about them, leaves bookmakers shouldering a huge duty increase. And potentially levy too.

The trouble with this is how bookmakers operate. A shop, or online firm, that offers racing, offers that product as an element of various sports. Without football for example, no betting shop would be viable. Nor any online business for that matter!

So why such a naïve stance?

Well it is difficult to understand such folly. Racing must believe the unsupportable tax hike in sports betting will simply be absorbed by the 4 largest companies. They calculate the loss of the independent market as a ‘price worth paying.’ No independent can withstand such a rise in tax. And to pass the duty cost on by delivering higher margin, or by removal of offers, like best odds guarantees, robs bookmakers of any competitive advantage against the black market- who pay a zero rate of tax and levy!

It follows the racing alliance believes big corporations, like the 35 billion pound Flutter should ‘just pay.’ Because it can afford to. Racing has deep history with such views. Even if racing is a loss leader to the gaming companies.

It is a bold plan. One born of the beer mat and the incredibly smart Derek Webb, who has managed to split the immovable racing out. Flutter, for example are already saying no to hikes in streaming and levy. Quite why racing thinks it can ‘bully’ such companies into ‘just paying?’ Well that goes back to rule number 1. Which I repeat

  1. Bookmakers should just pay.

The future

If racing gets its way, it must believe the ‘split out’ can last ad infinitum. In reality those who oppose gambling on moral grounds, and horse racing on welfare, will be unrelenting in their opposition to racing being treated as a special case- when it causes so much (imagined) harm. Racing will end up ‘harmonised.’ The independent bookmaker market (that’s companies like Geoff Banks Online, Star Sports, Fitzdares etc) will disappear offshore. Acceptable collateral I believe that’s called. Finally racing thinks government will be able to bully Flutter, Entain, Evoke and 365 into a new world of 40 percent uplifts in tax and levy. Play stupid games- win stupid prizes

If I was the CEO of Flutter, or Entain, and racing wins the round in securing for itself more levy, whilst turning its back on its association with sports? Well I would find I have two products ‘harmonised’ for tax at the same high rate. There’s no tax advantage now to offer racing. One is my gaming with minimal cost attaching – the other is the racing, which is enormously expensive in charges to offer. Which part of my business would I be shoving down my customer’s throat? Inevitably it would be Racing that would suffer. And I wouldn’t lose a moments sleep about a sport that abandoned its defence of the other products which effectively offer punters a ‘one stop’ solution for their betting. Racing, having given the treasury the nod for huge tax increases in sport, has committed the biggest single act of immolation in its history.

Good luck to all those of you who think you can manage such a trick on companies domiciled in Gibraltar and Malta, I have said it before, but I will repeat. Racing has to look to itself and modernise. Punters? Well your future lies offshore. And as offshore entities like Stake prove they can pay winners – they will dominate the market. That’s if Flutter, 365, Evoke and Entain don’t set their shop up in Malta for good, and put two fingers up to racing, and this government.

Who could blame them?

Luqa, Malta – June 23, 2016: Air Malta Airbus A320

UK actions inspire hope and despair

the Player Protection Hub newsletter, your biweekly roundup of news, features, interviews, conversation, and new research; plus a guide to upcoming digital and real life events related to player protection and ESG in the gambling industry

UK actions inspire hope and despair
While the Gambling Commission’s action that has resulted in Stake leaving the UK market will delight regulated operators concerned about crypto competition, the UK government’s appointment of the Office for Health Improvement & Disparities (OHID) to administer £30m of public funds will please almost nobody.


Stake announced its withdrawal from operating white-label websites after the Gambling Commission investigated claims that Stake’s branding was found on a social video from porn star Bonnie Blue imploring “barely legal” Nottingham Trent University to have sex with her.The Commission will be congratulated for coming down hard on such irresponsible advertising and also finally tackling a crypto-first operator using a UK white-label site for the purpose of gaining a sponsorship deal with a Premier League football club (in Stake’s case, Everton).
After its action on Evolution Gaming’s presence on unlicensed operators, it will be seen as another sign of the Commission getting serious about the black market.
The Commission says it will write to Everton as well as two other clubs with unlicensed sponsors warning of their dangers.


Swings and Roundabouts:
However, the industry will be horrified by the appointment of OHID as prevention commission for £30m of RET funds, which, according to the government, could include measures such as national public health campaigns.
“They will see harm prevention and gambling prevention as the same thing,” Regulus Partners’ Dan Waugh told us today. OHID has a strong relationship with anti-gambling campaigners Gambling With Lives going back several years, which has resulted in people being deterred from using GambleAware’s National Gambling Helpline, among other things.OHID has also released research advocating for:
– Annual tax increases on the industry above the rate of inflation
– A universal advertising ban
– A ban on the sale of beer and wine in casinos, and possibly on racecourses
– Plain packaging for gambling products with no colours or logos or images.Lived experience concerns: Charity organisations such as Deal Me Out have expressed their concerns about OHID discriminating against organisations due to their funding models. This is an appointment that will please nobody except the prohibitionists at Gambling With Lives.

Court case threatens UK research, education and treatment agenda

The UK government’s decision to appoint the Office for Health Improvement & Disparities (OHID) as the Commissioner of a £30m industry levy to prevent gambling harms is coming under increasing scrutiny with the possibility the government ends up in court.

Concern has grown among Research, Education and Treatment (RET) providers that discriminatory practices at OHID have stopped them from providing their services under the current model and there is concern that it will just get worse when OHID becomes the sole commissioner.

Player Protection Hub has learned that lawyers are advising on the possibility of a judicial review to halt the appointment.

A public health approach:

The Prevention Commissioner’s role is to develop a “comprehensive strategy” to reduce gambling harms. In the recent past, OHID has signposted its intentions by convening a panel of non-industry experts to thrash out “a comprehensive public health approach” to gambling.

Its recommendations included:

Tax rises on operators above the rate of inflation

A maximum limit on customers gambling on an operator’s website at onceBanning in-play betting on sports events

A universal ban on all gambling marketing, advertising, and promotions

Banning the sale and consumption of alcohol at land-based gambling venues

Banning the broadcast or streaming of all live gambling competitions

Banning jackpot prizes after a set time or amount gambled on a specific product

All gambling products to have plain packaging!

It does not take an expert to point out that some of these recommendations would put companies out of business.

The big picture:

Non UK-readers will need to excuse us for dwelling on what seems to be a parochial affair of British politics but there are wider issues at play that are relevant to any regulated gambling market. Other issues with OHID include: The Gambling Commission has raised concerns about the organisation manufacturing statistics.

OHID’s ties with anti-gambling campaigners Gambling With Lives run so deep that a freedom of information request asking for emails between the two was rejected because of a clause that allows the government to turn down the request if it is too time-consuming. FOI requests have been granted for 400 pages-worth of documents.

“One good thing is that OHID is a public body and subject to public scrutiny,” says Regulus Partners’ Dan Waugh. “They should be easier to hold to account. The issue is that the industry has not been very good at holding public bodies to account, preferring to keep a low profile.”

reproduced from the Player Protection Hub. An excellent source of accurate analysis of gambling related issues

it’s ok to lie- in a good cause!

Last year, the Gambling Commission wrote to the Betting and Gaming Council (‘BGC’) to ask it to stop referring to Health Survey statistics. It now transpires that it did so on behalf of the activist organisation, Gambling with Lives (‘GwL’)

Great Britain: Politics – is something rotten in the state of the West Midlands?
A novel solution to addressing ‘problem gambling’ was briefly glimpsed in parliamentary debate last week – the imposition of strict gambling controls on people in the West Midlands; leaving those living elsewhere in England to flutter as they see fit. 

During Wednesday’s Westminster Hall Debate on Gambling Harms, Sarah Coombes MP (Lab, West Bromwich) claimed that there were “168,000 people in the west midlands who say that problem gambling is devastatingly affecting their lives” and the lives of family members. Seconds earlier, Ms Coombes’s colleague, Jim Dickson MP (Lab, Dartmouth) had told the chamber, with the authority of the now defunct Public Health England (‘PHE’), that an identical number of people in the whole of England were experiencing ‘problem gambling’. Taken together, these statements appear to indicate that gambling may only be a problem for people living in the environs of Wolverhampton, West Bromwich, Walsall, Coventry and Birmingham (home of Britain’s Gambling Commission).

No sooner did this regional lockdown ‘public health approach to problem gambling’ hove into view, than it started to dissolve under the weight of wider MP interventions. Dawn Butler MP (Lab, Brent) argued that there are around 20,000 ‘problem gamblers’ in her constituency alone; and Cameron Thomas MP (LibDem, Tewkesbury) claimed (incorrectly) that PHE had put the national figure at 246,000. Other MPs insisted that there were in fact 1.3 million or more ‘problem gamblers’ in Great Britain – claims that rely on the misuse of official statistics, as defined by the Gambling Commission. 

In general, the debate was a poor advertisement for parliamentary discourse. One Liberal Democrat MP suggested that supporters of Liverpool FC would find themselves “unable to talk to their friends and family about the losses and their addiction” as a direct result of Ladbrokes becoming the club’s official betting partner; while Butler of Brent claimed, without providing a shred of evidence, that gambling was “more addictive than heroin”. According to National Health Survey (‘NHS’) estimates, the rate of DSM-IV gambling disorder lies between 0.1% and 0.2% of the adult population, compared with 3.1% of people showing signs of drug dependency and a similar proportion with mild or severe alcohol dependency). As flies to wanton boys are statistics to MPs; they use them for their sport.

Only one participant – Labour’s Jake Richards, Member for Rother Valley – appeared to notice what was going on, observing that, “we have heard a lot of statistics in this debate, but they vary because we just do not know what we are dealing with”. Mr Richards was half-correct in his diagnosis. The real reason for the confusion is that prevalence rates are based on responses to self-report surveys – and estimates vary significantly depending on how these are conducted. NHS Health Surveys have historically been conducted in-person, an approach considered to be the “gold standard” in terms of yielding accurate results (Sturgis & Kuha, 2022). The Gambling Commission’s Gambling Survey for Great Britain (‘GSGB’) is conducted online and is less likely to be reliable due to low response rates and topic salience bias (ibid.). GambleAware’s Annual Treatment Survey uses self-selected online panels (surveys of people who actively choose to spend their time filling out questionnaires) and, while these panels may have their uses, providing reliable population-level figures is not one of them.

The chief executive of the Gambling Commission, Andrew Rhodes recently lamented that arguments over which survey is more accurate distract from what really matters. He is correct – but this is a situation of the Commission’s own making. Repeated attempts by the regulator to undermine public confidence in Health Surveys in order to shore up the defences of the GSGB reflect poorly on those involved and have prompted activists to describe the use of NHS statistics as “a con”. If it is a con, then it appears that both HM Government and HM Opposition are in on it. In last week’s debate the shadow gambling minister, Louie French (Cons, Old Bexley and Sidcup), and the DCMS minister, Stephanie Peacock (Lab, Barnsley South) chose statistics from NHS Health Surveys rather than the GSGB. 

Last year, the Gambling Commission wrote to the Betting and Gaming Council (‘BGC’) to ask it to stop referring to Health Survey statistics. It now transpires that it did so on behalf of the activist organisation, Gambling with Lives (‘GwL’). On 2 October 2024, GwL wrote to the Commission to ask whether it would take action against the BGC for continuing to use NHS figures (which have the status of Accredited Official Statistics) in preference to those from the GSGB (which don’t). Eight days later, the Commission did precisely that – copying and pasting the GwL objections into an email to the trade body. It did so despite the fact that the BGC’s actions do not constitute misuse; while turning a blind eye to cases of actual misuse. The regulator will presumably now also take the DCMS and shadow minister to task for the ‘non-crime statistics incident’ of believing the NHS.

The publication of the NHS Adult Psychiatric Morbidity Survey and the GSGB 2024 this summer will put another couple of ‘problem gambling’ figures into the mix; and these will be supplemented next year by the Health Survey for England – unless the Commission intervenes (it has told the Department of Health and Social Care that it wishes to ‘manage’ statistics that compete with its own). The chances of clarity or coherence breaking out any time soon seem slim. 

Regulus Partners – February 2025

the growth illusion

UK: industry stats – the growth illusion
 
In September 2019 we wrote a blog titled ‘the myth of growth’, using UK data to show that gambling had not grown materially in real terms for twenty years. A lot has changed in five years: online gambling has grown by another 30% and lockdowns have transformed the way people consume entertainment in a lasting way. However, fundamentally nothing has changed: people are spending less on licensed gambling in Great Britain now than they were in FY19. There are a number of important reasons for this which should shape domestic policy and international comparison as well as UK-facing operations management.


 
The Gambling Commission’s annual industry stats for FY24 (to March) look optically robust. The top five online group operators, for which the Commission publishes monthly revenue each quarter, have continued to lose share as expected, meaning underlying growth was higher. In the more consolidated betting market, top-five (really 4) share loss was 0.7ppts to 86.7%, which meant betting licensees outside the top operators grew by 10% YoY while the top operators grew by just 3%. The difference in gaming was even more pronounced, with 3.0ppts of share lost to 67.5%, meaning gaming operators outside the top five grew by 20% YoY, vs. 4%. While there are some operational reasons for this difference in performance (biggest isn’t always most innovative and at least two of the top five have suffered from self-inflicted problems caused by weak leadership), we continue to believe that the biggest reason for the shift is an uneven regulatory landscape. In our view, the £5 slots limit which is now been brought in will help to level the regulatory landscape down (something many of the top five advocated for on the basis their performance against the black market wasn’t being judged), thereby pushing a material volume of future underlying demand growth into the black market. Stronger-than-visible growth concentrated principally into the gaming long-tail is a double-edged message for future growth and channelling therefore.
 
UK online growth has accelerated into calendar 2024 (see Financial Update on Q3), in part because of comps but also because of a dangerously misunderstood phenomenon: the lag effect of money printing and inflation. It has been a while since a gambling operator tried to blame a ‘cost of living crisis’ on poor operational performance. The real reason for the 2022 economic shock (which had a negligible impact on gambling) was a hangover from frantic state money printing during lockdowns; these have now washed through, but average salaries in 2023 were 15% higher than in 2019 (note the gambling sector is not 15% bigger), broadly based salary increases are still coming through (c. +5%), while the government continues to use deficit spending to fund the public sector, adding to inflation risk going forward. When the economy was sclerotic, but inflation was consistently c. 2%, then 4% growth meant something; with inflation likely to remain volatile regardless of central bank predictions, absolute growth is far less relevant than relative growth. Largely due to wage increases and inflation, we expect high single digit growth for online gambling in the UK subject to black market leakage, but we expect a relative decline in gambling revenue – with landbased gambling bearing the brunt.
 
FY23-4 marked a period of optical landbased recovery, with all landbased sectors except the struggling National Lottery in growth. However, while landbased sectors in total added a net £63m to Britain’s gambling industry (excluding pub gaming machines, likely down), online added £471m, or 88% of all growth. This is a clear case of channel shift at work in ‘frog boiling’ form: landbased sectors are relieved to see some absolute growth but are losing relative market share. Again, inflation is an enemy in disguse – revenue goes up as businesses become less relevant and more fragile.
However, three long-term consumer demand trends are much more sticky than channel shift.
 
The first is that the National Lottery has failed to maintain early levels of consumer interests (note, now under new ownership). This has been compensated for in part by the strong rise of the Charity Lottery sector, but this is a complementary rather than competitive product: nothing can replace a well-run lottery in terms of mass market customer engagement.
 
Second, is the slow rise of slots content as the digital experience proved more flexible and increasingly more appealing than Britain’s stunted landbased offer. The new online stake restrictions are likely stymie and probably reverse this trend, in our view.
 
Third, is the consistency of betting: football has overtaken horseracing in absolute revenue (by only 15% in FY24 after a generation of predicted doom for racing from betting commentators who preferred opinion to evidence), but betting maintains remarkably consistent in terms of revenue mix over twenty-five years despite all the hype over growth. The relative growth in slots has therefore partially mitigated the relative decline of National Lottery revenue to keep gambling expenditure as a proportion of Household Disposable Income relatively stable at c. 1% over 25 years (note, FY9 was low because of the implementation of the Smoking Ban, the loss of S16/21 machines, and the onset of a global recession). However, an underlying decline can be detected and if the National Lottery is not turned around then it is likely to become more visible, in our view.For all the hype about a changing landscape, very little is changing in terms of underlying consumer behaviour other than channel shift. British consumers are, if anything, gambling less, albeit with revenue concentrated in a smaller number of participants.
 
The growth visible in the FY24 industry stats offers more to be concerned about than relief for a recently battered industry. For the British gambling industry to have a future that is not a story of increasingly pronounced relative decline temporarily disguised by inflation, it needs to achieve ‘just’ two things, in our view:
 ensure the legislative and regulatory framework keeps high value players in the licensed ecosystem; the opposite is currently being achieved (note, London has already largely lost a c. £150-300m annual high roller casino segment taxed at a marginal rate of 50% – sufficiently specialist to disappear largely un-noticed) create products that have genuine mass-market appeal (the Charity Lottery sector is the unsung standout success story here) 
These two drivers of industry sustainability sound simple, but they are proving dangerously elusive to deliver.
 
UK: RET policy – money, money, money: why the levy is far from funny
“What operators rightly hate being told is that they ought to be contributing more than they are to RG programs without being told what they are actually paying for. They then readily form the suspicion that most of their money is spent on the cost of employing an army of hostile public and quasi-public officials. These officials are then perceived as having as their primary concern not the alleviation of suffering but the retention or expansion of their own jobs. This in turn, can be suspected of leading to the proliferation of regulations that have little or no empirical basis.”
Professor Peter Collins, 2003
 
The decision to impoae a safer gambling levy on licensed gambling operators in Britian is by far the most ill-considered of the policies contained within the previous British Government’s white paper on regulatory reform. It is also likely to be the most significant in the longer term, with far-reaching consequences for the functioning of the gambling market, harm prevention and policy coherence.  In this article, we set out why we believe the levy is bad policy, what its outcomes are likely to be and how some of its worst consequences might be mitigated.
Why the levy is bad policy
The imposition of the ‘safer gambling’ levy has been dressed up by proponents as self-evident. After all, what could be more reasonable than requiring gambling businesses to fund the treatment of people suffering gambling disorder as well as work to better understand harm and to prevent its occurrence? The polluter, as the trope goes, should pay. 
 
The problem is that is not how our society works. In the normal world, businesses pay taxes at rates set by HM Treasury, which are used to fund public services, including healthcare, research and education. Charities, community groups, and private businesses address gaps in what the state is prepared to fund. The safer gambling levy breaks this model by requiring treatment and other costs to be funded directly from the expenditures of gambling consumers. In so doing, it sets a precedent for levies to be funded against general retail businesses (to recover costs from compulsive buying behaviour), internet providers (internet use disorder), coffee shops and teahouses (caffeine use disorder), pubs and bars (alcohol use disorder), and restaurants (obesity) among others. Followed to its logical conclusion, it proposes a healthcare system paid for by citizens according to their lifestyle choices. There is a dark and unsettling logic to this if applied consistently – but no obvious justification for its imposition on gambling consumers alone.
 
Combined with the draft guidelines of the National Institute for Health and Care Excellence, the levy will make treatment providers dependent upon the NHS through the stipulation that they may not seek funding or engage with gambling businesses – effectively penalising those organisations that support the current regulations. One consequence of this model is that – contrary to the spin – the levy increases the dependence of treatment and harm prevention providers on the industry (as a number of public health figures have already observed). In replacing a voluntary system of funding with a tax, the government will tie financing to industry revenues. If consumer spending with licensed operators reduces, so will funding. Organizations lobbying for tighter restrictions on gambling consumers (or higher taxes on operators) will do so in the knowledge that new measures may negatively impact their own finances. The Department for Culture, Media and Sport has forecast a net market contraction of 8.2% as a result of its white paper reforms but this is speculative, and the impact could well be greater (particularly if modernising reforms for landbased operators are delayed). There is a very good chance that the levy brings in less than expected, which would be a major problem if the levy was underpinned by an actual budget or assessment of need. 
 
The levy has been justified by reference to two factors: concerns over the perception of research independence under current arrangements (regardless of whether those perceptions are grounded in fact)the fact that some operators have contributed derisory amounts under the voluntary system 
The first suggests that government policy is now dictated by perception (which is in turn influenced by lobbying) rather than actual evidence. The second is a red herring – no gambling business of any scale has been guilty of under-funding; and the parsimony of the few is poor justification for the creation of a new tax, although it does justify targeted intervention.
 
The levy is also likely to be wasteful. HM Revenue and Customs already collects c. £3.5bn in specific gambling duties (in addition to general taxes less Output VAT) from the gambling industry, under direction from HM Treasury. The levy, however, envisages the establishment of an entirely new tax system, designed to collect roughly £100m under a non-fiscal authority, overseen by a levy board. While a Levy Board works well in racing, it is independently supervised with formal betting input (a board seat) and levy collected pays for clearly defined common interest objectives, neither of which apply to the safer gambling levy (although they could). Without these governance guard rails, the potential for waste, error and fraud is enormous, in our view.
 
The suggestion that the levy Is ‘smart’ appears to be Ir of those Orwellian conceits that has come into vogue in recent years (such as the idea recently expressed in the Lancet that state control is freedom). The logic for determining who pays what – including the exemption of the National Lottery – appears non-existent beyond the results of a sector and product popularity contest among the levy’s engineers. The application of a 1.1% rate to online gambling is justified by the idea that: i) it is associated with higher rates of ‘problem gambling’; and ii) remote operators have lower operating costs. The first is solely true of online gaming and is not true for betting – the ‘problem gambling’ rate for online sports bettors in the most recent Health Survey for England was just 1.2% (albeit it is dangerous to leap to causality given that PG rates are principally set by a product’s popularity). The second is true for some remote operators some of the time – but not for the many others: plenty of landbased businesses have higher margins than plenty of online businesses and the channel has little to do with the outcome. More generally, the suggestion that efficiency should be penalised hardly fits with the Government’s growth agenda. There is a reason why tax policy is generally set by finance ministries and not by regulators. Ironically, based on the premise that online gambling operators are able to pay more because of higher margins, they should be able to offset any margin-reducing tax increases with a reduced Levy rate, though we doubt the logic will be applied so robustly.
 
The levy is not so much smart as unfair. To provide one example, operators of gaming machines in bingo clubs and arcades are required to pay; but pubs and social clubs providing precisely the same machines are not. Further, the way that the Government has presented the tax is misleading because it is levied on suppliers (at 1.1%) as well as B2C operators (at between 0.1% and 1.1%). The effective rate of the new tax will therefore be applied inconsistently and at rates higher than claimed since we do not believe a recoverability mechanism (ie, the way VAT works outside the gambling sector) has been proposed – and it would make no sense if it did since gambling suppliers exist to serve gambling customers, who are being taxed through gambling operators. There is an additional irony that this highly complex levy, with multiple and arbitrary rates across different gambling products and channels, comes as the government simultaneously seeks to copy another of the previous government’s soundbite-driven schemes, since it will: consult next year on proposals to bring remote gambling (meaning gambling offered over the internet, telephone, TV and radio) into a single tax, rather than taxing it through a three-tax structure. This will aim to simplify, future-proof and close loopholes in the system. Perhaps someone needs to tune the governments’ wireless.
 
What can we expect next?
It has been claimed that the ‘safer gambling’ levy will result in greater resources and more certainty for harm prevention services, which would be a good thing. It will probably (depending on events) bring in more money than under the voluntary system; but that is not the same thing. For one thing, it will involve the creation of new administrative bureaucracy for which no published budget exists (a major lacuna) and, given the way that the state spends money, is unlikely to be either modest or well governed.
 
Half of the funds left over after as yet unknown administrative costs will be allocated to the perennially over-stretched National Health Service, which will almost certainly prioritise its own services over the requirements of the Third Sector. The charities, who have in some cases been effectively and diligently providing treatment to people with gambling disorder for more than half-a-century, will now be required to bid for the funds that were previously theirs. Several harm prevention organizations have already started to shut down programmes (including training for licensees) and making members of staff redundant (up to 150, if reports are correct). Made dependent on the state, treatment providers may find that they are required to fall in line with radical public health ideologies, such as the belief that adults bear no responsibility for their actions and harm is solely the result of exposure to ‘addictive products’. This denial of human agency breaches a core tenet of psychotherapy and has the potential to cause enormous damage to vulnerable people by institutionalising victimhood.
 
A further 30% of net funds will be allocated to the conveniently vague domain of ‘harm prevention’. Rumour suggests that the commissioner will be either GambleAware or OHID. The former has already called for mandatory health messages on all gambling advertisements (including for the National Lottery and horseracing); while the latter has manufactured suicide statistics and proposed ‘plain packaging’ (no colours, logos or images) for all gambling products. GambleAware may be slightly less illiberal than OHID, but both have trouble distinguishing between harmful gambling and gambling – a blind spot that ultimately leads to long-term prohibition via a medium-term funding bonanza. We can only imagine what they might get up to with up to c. £30m a year.
 
The final 20% is allocated to research under UK Research and Innovation (‘UKRI’). It is to be hoped that UKRI demonstrates greater scientific rigour and moral neutrality in commissioning research than the Gambling Commission, GambleAware, or OHID. The risk, however, is that it becomes a slush fund for anti-gambling activism that will be used not just in Britain but internationally to campaign for the prohibition of gambling once all the funding that can be extracted has been. In recent years, a profusion of clearly agenda-driven journal papers and reports of low academic quality have been published – often as a consequence of Gambling Commission or government funding – alongside a very small number of high-quality studies. There is a risk that the levy will be used to fuel a propaganda engine for an international anti-gambling movement. The reason why activists have prioritised the levy above all other matters is because they know just how large the prize is – up to £20m per annum.
 
For all the high-minded rhetoric, the levy seems destined to result in disruption to treatment services, increased stigmatisation of gambling as a legitimate adult pastime, and the production of misinformation on an industrial scale which politicians and bureaucrats seek to lack the discipline or inclination to critically assess. 
 
What should be done now?
The safer gambling levy may be bad policy, but it is now policy, and it will come into force next year. The question is therefore what ought to be done by licensees and others. We make three suggestions:
 Governance – there is a good chance that money raised by the levy will be used inefficiently, unscientifically and inappropriately. The process for how funds are allocated and assessed therefore requires close public attention. Scrutiny should be applied to the levy’s governance arrangements and the process of evaluation in 2030. Given what has gone before, it would be naive to trust those responsible to mark their own homework Continued support – a large number of harm prevention organisations now face uncertain futures. It would be a mistake, in our view, for operators to cease their support for charities and other harm prevention organizations once the levy kicks in even at the cost of ‘paying twice’. Several important programmes now face defunding (in addition to those that have already fallen by the wayside); and operators need insights from these groups in order to inform their own ‘safer gambling’ initiatives – for the sake of disordered gamblers and the sustainability of effective treatment, a distinction must be made between the sunk cost of a pollicised levy and productive expenditure on mitigating the harms that the licensed gambling sector does cause or exacerbate Critical analysis – the levy is likely to result in an expansion of anti-gambling activism, particularly in the domain of ‘research’, which will reach into other jurisdictions. To date, the licensed gambling industry in Britain and other jurisdictions has done an extremely poor job of assessing and (where appropriate) rebutting bad science. It is critical that it develops both the technical capability to scrutinise research and the willingness to call out misinformation (including misinformation which seems to support the industry). There is a good case to be made for building this capability on an internation basis.Ironically, the new levy is at least in part the unwitting handiwork of some of the largest licensees in Britain’s gambling industry whose lobbying made the policy almost inevitable. The Betting and Gaming Council’s endorsement of the policy was unfathomable to us at the time and continues to be so; it makes a lobbyist’s job much easier in the short-term but the industry’s job far harder in the long-term. There is a lesson here which the industry should now be able to perceive – policymaking is difficult in this space; and the pursuit of easy fixes is liable to end in disaster. Unfortunately, the government may have to wait a little longer before it arrives at this epiphany.  

Regulus partners
Disclaimer; The analysis provided in this report represents the opinions of the authors. Any assessment of trends and change is necessarily subjective. The information and opinions provided herein are not intended to provide legal, accounting, investment or policy advice, nor should they be used as a forecast. Regulus Partners may act, or have acted, for any of the companies and other stakeholders mentioned in this report.

Abusing NHS statistics

UK: ‘We don’t need no thought control’ – why the Gambling Commission should leave NHS stats alone

In recent years, the Gambling Commission has been on the receiving end of criticism from all sides of the so-called gambling debate. Last year, the MP, Sir Philip Davies declared that the regulator was “out of control”, while the Social Market Foundation has described it as “not fit for purpose”. The Commission has not publicly endorsed either of these views – or advertised them on its website – presumably because it considers them to be untrue as well as unflattering. Last month, however, the Betting and Gaming Council (‘BGC’) was asked by the Commission to make claims about the prevalence of gambling harms which are probably false – and to publish them on its website.



In an email recently released under the Freedom of Information Act, the Commission wrote:
 
“We’ve been keeping an eye on use of GSGB [Gambling Survey for Great Britain] data and use of figures as the official statistic. We’ve noticed that BGC still refers to previous stats, it’s not a misuse of stat issue but we’d be keen for you to start using the official figure moving forwards.”
 

This invitation was politely declined by the BGC on the grounds that it has greater confidence in NHS statistics (which are accredited by the UK Statistics Authority) than in the Commission’s (which are not). The BGC is similarly unlikely to profess that its members are (to borrow from Blackadder) ‘head over heels in love with Satan and all his little wizards’; but the Commission can always try.  

 
The regulator’s entreaties should be considered in the light of the following circumstances:
i) the balance of evidence indicates that the GSGB substantially overstates levels of gambling and gambling harm in Britain
ii) the Gambling Commission knows this
iii) in asking the BGC to go along with the charade, the Commission is acting, at best, inconsistently
iv) the GSGB is already being used (and misused) by activists, seeking to reopen the Government’s Gambling Act Review.



We examine each of these points in turn.  

 
1. The balance of evidence
The GSGB may be the new source of official statistics, but this does not mean it provides a reliable picture of gambling prevalence in Britain. To believe that it does, it is necessary to subscribe to the following:
        i.            Every single official statistic on gambling and harmful gambling produced over the last 17 years – by the National Health Service (‘NHS’), the Department for Culture, Media and Sport and the Gambling Commission itself – has been substantially wrong
      ii.            The NHS has serially misreported the prevalence of health disorders in general – and continues to do so
    iii.            Audited data on actual customer numbers using licensed operators is incorrect (or there is a massive black market that failed to show up in previous studies and of which the Commission was previously unaware)
     iv.            The opinion of the independent review (conducted by Professor Sturgis of the London School of Economics) that the GSGB may substantially overstate true levels of gambling and gambling harm is misguided
 

To believe that all these things are true (and to cajole others into professing the same) requires more than blind faith and a sheriff’s badge. Tellingly, the Gambling Commission does not have very much confidence in the GSGB itself; and has issued guidance that key results should be used “with some caution” or not at all.


2. Withholding evidence (again)
The Gambling Commission’s defence of the GSGB has largely consisted of attacks on NHS statistics, claiming that they have under-reported rates of ‘problem gambling’. While scrutiny is important, undermining accredited official statistics on health is a step not to be taken lightly. Some sort of evidence is required. For this, the Commission has relied upon a 2022 study which claimed social desirability response bias (ie, the fact that people sometimes answer survey questions in what they consider to be an acceptable rather than accurate fashion) caused under-reporting of ‘problem gambling’ in NHS surveys. This ‘evidence’ was thoroughly debunked by Professor Sturgis as part of his independent review – but for reasons known only to the Commission, the analysis was suppressed. It required a Freedom of Information Act request to secure the release of the information. This is not the first time that the Commission has prevented publication of critical evidence – having previously withheld survey data on customer opposition to affordability checks. Disclosures also reveal the Commission was warned by its lead adviser, Professor Heather Wardle, that social desirability response bias was likely to be a “marginal factor” in explaining differences between the GSGB and Health Surveys (and that the dominant factor of topic salience bias resulted in over-reporting in the GSGB). 
 
3. Two-tier thought policing?
In recent years, various parties have taken highly selective approaches to the use of ‘problem gambling’ statistics – often ignoring official estimates in favour of more convenient alternatives. Last year, the National Institute for Economic and Social Research did so in a report funded by a Gambling Commission settlement – using a rate two or three times higher than the official statistic. There is no suggestion that the Commission objected to this. In public consultations, the Commission itself relied on ‘problem gambling’ prevalence rates from the 2018 Health Survey for England rather than lower figures from the 2021 edition (ie, the official statistics at that time). In a speech in Rome last month, the chief executive of the Commission, Andrew Rhodes criticised those who wished to “turn the clock back” to previous official statistics, and in the very same speech cited participation estimates from ‘previous official statistics’.

 
4. The weaponisation of research
The importance of all of this has been amply demonstrated in recent weeks. Both the Institute for Public Policy Research and the Social Market Foundation cited the GSGB’s inflated rates of ‘problem gambling’ in support of demands for ruinous and self-defeating tax rates (as high as 66% of revenue); while GambleAware has used the survey findings to call for tobacco-style health warnings to be slapped on all betting and gaming adverts (including those for the National Lottery). The Commission appears, therefore, to be encouraging the use of inaccurate statistics on gambling harms in the knowledge that they will be used in support of an anti-gambling agenda.

Perhaps Sir Philip had a point after all…

REGULUS PARTNERS NOVEMBER 2024

Speed Kills!

The British Horseracing Authority is committed to a reduction of fatalities in the sport of horse racing. To that end they have embarked on a number of initiatives to achieve that end

I want to focus on the National Hunt. An area that once again hit the headlines with the loss of 3 horses over the weekend at Cheltenham. Two appeared to be post race heart events. I’m told these are not attacks as we understand them. Both of these took place over the chase course, in the same race. One other horse fell in the Greatwood Hurdle and died

The time of this chase event was the fastest chase of the day. It was as quick an event as I’ve seen, and I’ve verified this view with other form judges. These days it has become a rarity to see horses actually fall in horse racing, it seems to have become unacceptable, even if the sport is supposed to revolve around jumping ability, and clearly that’s what people pay to see. I observed at Cheltenham, whilst reviewing races, how horses clear fences at this premier racetrack with ease. Often several feet above the birch.

This was also readily apparent in the 2024 Grand National, where the fences have been lowered, softened and landing areas eased, to such a degree that no horse fell in the entire race. What is of most note is horses no longer bend, or arch their backs to jump. They clear fences with speed undiminished. The first fence is fairly infamous for speed based falls, as the 40/34 strong field would be at their quickest at that stage.

Whilst the BHA, under Nick Rust embarked on a programme of overall diminution of fence heights and stiffness, the fatality rate in the Grand National is currently running equal to the highest percentage rate ever. Without comment from the BHA. Since the 1960s 29 horse fatalities have occurred where ground is either good or better than good. 43 if we include good to soft. Just 5 have died in ‘heavy’ ground, and no horse fatalities were registered when ground is officially ‘soft’

Of further note, long term injuries have increased in the sport for the 4th year in a row since 2020. The lowest rate of fatalities? In 2020, when the winter was the wettest on record

With these facts in mind, is the BHA approach gaining the required results? To me their approach is centred upon optics. Where they have defined form! If we have fatalities, make the test easier has been the code

I would argue their approach focusses on the difficulty in jumping hurdles, or chases, when they should be focussed on ground, and speed. In simple terms the horses have quickened up. This is the inevitable consequence of making the obstacles easier

When the Grand National fences were at their fiercest, in the 1960s, just 2 fatalities were registered. Can the BHA explain this? Anyone who wandered around the track in the 3 or 4 decades since then, could only have been impressed by the scale of the fences. It was what people tuned in to see. The BHA’s approach in my opinion has been naive on two fronts. It increased the rapidity of racing, and it made the sport’s showcase less compelling to the viewing public, as evidenced by television audiences worldwide

This is what happens when you allow a betting executive free reign to mess about with the sport, with optics as his focus. I recall his comments on the heavy ground 4 miler at the Festival, where several horses finished notably tired and jumping became ragged. There were no fatalities in that race, but the race was identified by Rust as having ‘more fallers and horses brought down.’ Hardly surprising at Cheltenham’s longest chase event! It became clear that Nick Rust’s epitath was to nailed to his views on horse welfare. He reduced the race by a quarter of a mile and questioned the participation of the amateur riders involved.

One final point, before I leave you to discuss these points. Remember Cheltenham’s ill fated 3rd last fence? A notorious obstacle, not because it was taxing, but because it was at a critical downhill part of the track, where horses were speeding up. They tended to overjump, and collapse with fatigue on the landing side.

Make me the CEO of British Racing – I would increase the height of fences once again, and their stiffness. Force horses to slow down several times a race. I would demand tracks water more assiduously in the winter to produce soft ground. I would do everything possible to slow these impressive animals down. Speed is the killer in British Racing. Not the difficulty of the obstacles they face