Researcher Challenges GSGB Participation Estimates With Administrative Data

A new analysis presented at a leading gambling research conference has questioned the reliability of the Gambling Survey for Great Britain (GSGB), the U.K Gambling Commission’s flagship prevalence survey.

Daniel Waugh, a researcher at the University of Liverpool Management School, compared GSGB participation estimates with administrative data from licensed casinos, Betfair, and Football Pools.

His analysis found that the survey’s participation estimates substantially exceeded recorded visits across all three gambling sectors examined. Waugh presented the findings last week at the University of Nevada, Las Vegas International Conference on Gambling and Risk-Taking, commonly known as the Eadington Conference.

The analysis follows the latest GSGB wave, covering July to October 2025. The survey reported an address-level response rate of 18%, which was below the target of 22%.

The survey generated 5,883 responses and uses weighting adjustments designed to account for non-response and improve representativeness.

Administrative Data and Survey Estimates Diverge

Waugh’s analysis compared GSGB participation estimates with operator and industry data collected during similar periods.

For casino gambling, he estimated that GSGB participation data implied between 1.7 million and 2.9 million casino visits during the study periods. He compared that with roughly 1.0 million recorded visits across licensed casinos.

The presentation noted that the disparity may be even greater, as the survey focused specifically on in-person table game visits. At the same time, casino operators estimate that 40% to 80% of casino visits do not involve table game play.

The analysis also compared betting exchange participation with customer data from Betfair, which Waugh estimated accounts for approximately 85% of the U.K. betting exchange market.

According to the presentation, GSGB estimates the number of betting exchange participants at 467,499 to 611,768. Meanwhile, Betfair’s data showed 172,409 to 177,051 active customers.

For Football Pools, where Football Pools Limited effectively operates as a monopoly, the presentation estimated 862,961 participants based on GSGB data, compared with 108,699 unique customers recorded in Football Pools Limited’s data.

Overall, Waugh estimated that casino participation exceeded administrative data by 408% to 628%. Meanwhile, betting exchange participation increased by 164% to 225%, and Football Pools participation increased by 694%.

Waugh Warns of Broader Policy Implications

Asked about the most significant implication of the findings, Waugh said the discrepancies raise broader concerns about the survey’s reliability as a measure of gambling participation and gambling harm.

The data shows that – for the activities where I was able to obtain data – the GSGB massively overstates gambling participation,” Waugh told Gambling Insider.

At the very least, this means that the GSGB cannot provide accurate data on these activities – but it also indicates that the survey as a whole should not be considered reliable for estimating population-level statistics, whether for gambling participation or harmful gambling.”

He added: “This in turn raises the problem that the Commission – and potentially the DCMS too – will base regulatory policy on inaccurate information.”

The presentation concluded that the findings may indicate systemic bias in the survey. It also highlighted concerns about coherence between GSGB results and other official gambling and health statistics.

Waugh Questions Gambling Commission’s Handling of Criticism

Waugh said he shared the analysis with the Gambling Commission several months ago. However, he believes the regulator has failed to adequately engage with criticism of the survey.

“At the outset, the Gambling Commission was warned by its academic advisory board that taking prevalence statistics in-house (previously they had been collected by the NHS) may cause them to lose independence. That is precisely what appears to have happened.”

“The Commission has spent millions on this survey (the latest award to the University of Glasgow and NatCen was worth £4.5m) and staked its reputation on it.”

It is unsurprising, therefore, that it now appears incapable of admitting that the survey may be inaccurate – despite clear evidence that this is the case.”

Waugh also referenced recommendations issued last year by the Office for Statistics Regulation. The agency encouraged the Commission to remain receptive to feedback and challenges regarding the GSGB.

“Instead, the regulator appears to have gone out of its way to belittle those raising concerns,” he said.

Gambling Commission Defends GSGB

Responding to Gambling Insider’s questions, the Gambling Commission defended the survey’s methodology and development process.

The Gambling Survey for Great Britain is one of the largest and most comprehensive gambling surveys in the world,” a Commission spokesperson said.

“The development of the GSGB was independently peer reviewed and considered ‘exemplary in all respects’ by Professor Patrick Sturgis from the London School of Economics.”

The spokesperson added that the survey underwent an extensive development process beginning in 2021, including pilot and experimental phases, before becoming an official statistic in July 2024.

We continue, in line with best practice, to undertake work to understand the impacts of the methodology and compare results alongside relevant datasets.”

The Commission also emphasized that it welcomes information from external sources while continuing to compare findings across multiple datasets.

Whilst we don’t routinely comment on all gambling research, especially if it has not yet been peer reviewed, we welcome data from other sources as part of our continued drive to gain a thorough understanding of the gambling sector.”

The spokesperson pointed to initiatives, including the Regular Feed of Operator Core Data (ROCD) Pilot Project and previous work with The Bingo Association, as examples of the Commission’s efforts to incorporate additional data sources.

“Our approach is always to triangulate data across several sources.”

The Commission emphasized that Waugh’s analysis has not been peer reviewed.

Broader Debate Over GSGB Continues

Questions surrounding the GSGB are not new. Following the publication of the survey’s first official results in 2024, industry stakeholders and researchers questioned the large discrepancies in participation rates and problem gambling estimates compared with previous studies.

Despite his criticism, Waugh said the survey may still provide useful insights when viewed alongside other sources of evidence.

The GSGB may offer some useful insights on gambling participation and harmful gambling, if viewed within a wider context of evidence,” he said.

“That wider context should include NHS statistics, operator data, and insights from open banking.”

However, he argued that the survey cannot currently be relied upon as a standalone measure of gambling participation.

It is quite clear, however, that it cannot currently be considered to provide a reliable picture of the British gambling market.”

“The Commission has said that it wants the GSGB to provide ‘one version of the truth’ – but this is naive.”

“Either the GSGB is wrong, or the Industry Statistics are. That’s not a matter of opinion; it is an unambiguous statement of fact.”