OnlineLegal & RegulatoryIndustry

Debate: Do the APPG’s recommendations have any merit?

The Gambling-Related Harm All Party Parliamentary Group (APPG) has called for sweeping changes to online gaming in the UK, including a ban on all gambling advertisement and £2 ($2.53) stake limits for online slots.


The Betting and Gaming Council (BGC) has since responded to the APPG’s recommendations, while a gaming lawyer has said they may be implemented in the not too distant future.

But, with so much attention being afforded to just one report, do the APPG’s proposals actually have any merit? The Gambling Insider editorial team discusses…

Iqbal Johal: Proposals won’t solve problem gambling

When groups like the APPG propose radical changes to the online gambling industry, it does strike me as not taking the entire picture into consideration.

Firstly, there is no doubting several of the 30 recommendations are sensible, credible proposals that have merit. It’s true the 2005 Gambling Act needs updating to fit the modern, digital age we now live in. It’s also true affordability limits need to be addressed and perhaps the time has come to end, or certainly limit, the highly controversial VIP accounts and incentives scheme, which seem to be doing more harm than good.

However, whether it’s paying lip service to get the APPG on side with the public and gambling bashers in what they think is the most obvious way to deal with problem gambling, too many of the measures are restrictive and unnecessary. Never mind the fact getting all 30 recommendations implemented is frankly an unrealistic target.

Out of the more than 20 million adults who gamble in the UK, only 1% are classed as problem gamblers. Yes, ideally, we’d like that to be lower but it still represents a small amount, which means the majority gamble responsibly. Introducing a blanket advertising ban across all channels and the £2 online slot limit are too prohibitive, and punish the majority of gamblers, let alone operators who bring in millions each year in tax.

The bigger picture is that restrictions such as the ones the APPG proposes will only drag players to the black market, where player safety goes out the window, thus having completely the opposite effect. Problem gamblers will still find ways to bet in the unregulated market if the regulated market limits them.

It seems to me the issue of addiction goes far beyond problem gambling and the best way to deal with it is getting to the root cause of the problem, which could come from individual experience, rather than the way they gamble. So education, which five BGC members pledged £100m towards on 15 June, is key;  especially with younger people to help stop any addiction manifesting, because the fact it’s gambling could just be circumstance – it could easily be a number of different types of addiction.

The industry has been implementing plenty of measures as of late, particularly during the COVID-19 pandemic, to tighten up player regulation. More should be done and hopefully some of the APPG proposals are implemented. But with the majority, the bigger picture must be looked at.

Tim Poole: Concentrate on making a difference, not the politics

Having reported on our industry for nearly two years, this is the closest I have found myself to siding with the APPG – to my own great surprise and unlike my colleagues. Whether the industry wants to hear it or not, problem gambling progress is still nowhere near where it should be.

As I’ve written recently, that is more down to mentality than lack of resources or technology. If the APPG’s recommendations can help shake up the negative aspects of the industry and encourage some overdue considerations of long-term sustainability, I’m all for it.

The problem again, though, is that my colleague is right: how much of this is designed to genuinely encourage change? So much of it is simply political, with the Betting and Gaming Council dismissing the APPG’s claims, and the Gambling Commission also defending its position amid criticism in the APPG’s report. It’s just PR tennis – back and forth.

It’s difficult to decipher what will really make a difference amid all the noise – but what really matters is helping problem gamblers. On that note, where I disagree with the APPG:

The suggested £2 online slot stake limit won’t help problem gamblers. Gamblers should be free to stake as they wish but, when signs of gambling harm are displayed, regulation needs to encourage operators to genuinely intervene. Changing the stake won’t change the overall process here, or encourage organisational change, and will indeed boost the illegal market. It is my firm personal belief a Gambling Ombudsman would be a waste of time – and simply an excess layer of bureaucracy to use taxpaying funds. If the Gambling Commission stands accused of not doing enough to stop industry malpractice, creating a sister organisation would just recreate the situation. In-play sports betting cannot be restricted to venues or telephones (who uses telephones to bet nowadays, anyway, with Bet365 recently closing its telebetting service?) You cannot simply recommend the removal of a key product in any industry – this is lazy from the APPG. Why not just ban all vodka, for example?

Where I agree, however:

NDAs should be looked into. If any operator wants to hide what it has done, it is an immediate admission it has not acted in the best interests of the player. VIP practices need to be scrutinised closely. Consumers should be provided accurate information on their chances of winning, as misinformed players try to play to earn money, rather than simply be entertained with a small chance of winning money. There is a key difference between the two.

Owain Flanders: Creating a dialogue will lead to progression 

When I first read the APPG’s report, I couldn’t help but think of an annoying toddler tugging at the skirt of his weary mother. Never satisfied, the toddler persists with his tugging for no real reason other than to let her know he is there. 

There are no surprises within the APPG’s report. In fact, a report that confirms the group’s desire for strict regulatory measures barely constitutes news. Despite assurances the APPG is “not anti-gambling” by group chair Carolyn Harris, the body has been a main opponent of the UK industry since its formation. 

The most significant regulatory suggestions proposed by the APPG are in no way revolutionary. Its desire for restrictions on gambling advertisements and staking limits for online slots has been common knowledge for some time. In its January work programme for the year, the APPG made clear it would be campaigning for these very measures, in addition to a ‘smart’ levy to fund research, education and treatment. 

The argument against instigating both of these measures ultimately comes down to a phrase we hear a lot in regards to regulatory discussions – “the black market.” When faced with limits to online slot machines in the UK, problem gamblers will simply look towards other unlicensed offshore sites with less protection. Meanwhile, if there is a ban on advertisements for all gambling sites, how are customers expected to know which ones are licensed – particularly if they’re new 

While I might disagree with some of the APPG’s proposed measures, it is the tone with which it provides these recommendations which I find most like the unsatisfied toddler. The group has labelled the Gambling Commission “not fit for purpose,” when there is no evidence to suggest the body is not working well to protect the UK’s customers. On the contrary, last year the regulatory body dished out a record number of fines as it fought to bring its licensees in line with expectations for protection. 

It seems clear that instead of an industry which contributes over £3bn in tax each year, the APPG sees it as a “multi-million pound industry” which “has destroyed people’s lives.” For that reason, rather than assist the industry in its journey towards player protection, it would rather criticise it at every turn – including now the regulatory body which oversees it.  

If the APPG really wants to help in the fight against problem gambling, I would advise it to create a dialogue with both the Gambling Commission and the Betting and Gaming Council. Rather than suggesting that the industry is a force for evil, the APPG will quickly realise that it is full of people who hold the same aim – the protection of customers. 

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