Andrew Rhodes, Chief Executive, UK Gambling Commission delivers speech at ICE 2025

Since the beginning of this financial year in April, he said, the UKGC has referred more than 102,000 URLs to Google, with 64,000 of these being removed and 264 websites taken down.

ICE 2025 World Regulatory Briefing - Andrew Rhodes Speech

21 January 2025

This speech was delivered by Chief Executive Andrew Rhodes at the ICE World Regulatory Briefing on Tuesday 21 January 2025.

Please note: This is the speech as drafted and may slightly differ from the delivered version.

Hello everyone, thank you for that introduction and thank you everyone for being here. It is great to be back at ICE albeit I have noticed a few changes since last year and yes, even in January, it appears the weather is better in Barcelona than it is in Great Britain! Weather aside though I am looking forward to some interesting conversations and thought provoking meetings and workshops whilst I am here and I am sure that is the same for many of you. Whether what I have to say today meets that bar I will let you judge but of course I am also looking forward to your questions as well.

So this morning I am going to spend some time laying out where I and the Gambling Commission see things today. I’ll address issues in the ecosystem that we think all operators need to be mindful of and I’ll also highlight a couple of the areas where we think behaviours in the sector have the potential to hold back further progress. Progress that is in the interest of consumers and operators alike. And whilst the examples and the specifics I am talking about might be focused on Great Britain, I know from the regular conversations I have with fellow gambling regulators that these issues and perspectives are shared. It might not always be all the same notes but the tune will be familiar.

So with that said, for the operators and advisors in the room and those reading this elsewhere, I think there is something that can be learned from our experience for the industry and others in many jurisdictions.

But what are these experiences rooted in? Where are they coming from. Let us have a quick look at how things stand for the gambling sector in Great Britain today.

The most recent industry statistics were released in November, and we have seen that gambling in Great Britain has reached the highest Gross Gambling Yield (GGY) we have ever seen: £15.6 billion. And with four waves of official statistics for participation from the Gambling Survey for Great Britain (GSGB), we are continuing to see a stable four week participation rate of 48 percent. I’ll touch on the GSGB further later on, but this most recent industry data allows us to ask some questions. If participation remains pretty static and at what is a high level, then if some products grow it is at least possible that could be at the ‘expense’, if I can put it that way, of other products. So, depending on how you see it, there will be ‘winners’ and ‘losers’ from these movements, which reflect the market activity of some 22.5 millions consumers in Great Britain (GB).

The GGY figure I started with also allows us to pose some further questions. It is the highest ever in GB. And that increase tracks through in some areas below the top line figures too. One example is horseracing, which now has the highest GGY on record. This brings though, the question of what happens if you adjust for inflation and what we know there is if you did adjust for inflation then the relative value of gambling has fallen in recent years, in terms of its share of consumer spend. Gambling, in Great Britain at least, has often weathered economic downturn pretty well, but we have not really seen that consumer staking necessarily tracks in line with inflation. For example, we have not seen evidence that if inflation rises to 10 percent that someone’s normal £10 or £100 bet becomes £11 or £110. If you did expect staking in gambling to track with inflation then you would need to overcome that inelasticity – margins, return to player ratios, offers and other things can be changed, but the consumer is always able to decide how much they want to stake – it is not like buying other consumable goods where the consumer simply has to pay more to get it.

When we look at the latest industry statistics, that we published in November 2024, the picture gets bigger again and some things stand out as we go into 2025. For the first time large society lottery sales have passed the £1 billion mark, as they continue to grow, which is a consideration around the National Lottery. Whilst not regulated as gambling, we are also seeing how big participation in prize draws have become in terms of consumer participation. Bespoke questions we added to the GSGB recently tell us participation in prize draws now sits only a little behind betting as an activity, and well ahead of a number of other activities.

Discussions with operators are showing a widening out of the sports offering in particular, with sports beyond the traditional horseracing and football growing in use, such as cricket, basketball, NFL and a host of other US-based sports. This smooths the seasonality of gambling to some extent and we will need to see what this does to the overall peaks and troughs in participation. We see some much higher peaks of consumer engagement in horseracing around big marquee events, with some data specialists telling us they expect to see higher bets-per-minute thresholds in the year ahead, which might suggest that peak demand is increasing. Again, as I have said – if consumer spend flattens out across a broader range of products for sports betting, then other products may well decline in participation. We will have to see how these patterns continue.

So the numbers themselves start to give us a picture. Such numbers give the headlines, but they do not explain what has been going on since ICE was in London last year and the answer of course is a whole lot. We need to continue to build a bigger picture.

In April it will be two years since the UK Government at that time published its Gambling Act Review White Paper. And at the Gambling Commission we have been working hard to implement the recommendations that it laid out. Whilst the UK went through a General Election last year that resulted in a change of Government, we have not seen a particular political change to the fundamentals to the Government direction on the regulation of gambling and our Government Minister, Baroness Twycross, stated her support for continuing the implementation of those recommendations and gave everyone her view on the path ahead in late 2024.

But the gambling ecosystem is unfortunately not just made up of those who wish to trade and play in the licenced, legal sector. It is one thing setting the direction for the licenced market. It is quite another to do so for illegal gambling. And that is why over the last year or so, those of you who pay attention to what we at the Gambling Commission are saying will not have missed us increasingly talk about how we are looking to frustrate those operators who are not licenced. Operators who are not regulated and who are often more likely to either cheat those people who choose to gamble with them or leave them open to higher risks of harm.

In Great Britain, there has always been an illegal presence, but awareness and the nature of it has changed. Our aim is to prevent the illegal market from operating at scale in Great Britain. A significant part of our strategy in doing that is to target our efforts as far upstream as we can – at the level of hosts, payment providers, software providers, search engines and others. We have spent the last two years in particular not just targeting illegal activity but also building our own resources, skills and capabilities. Since the start of the Financial Year, our team has issued over 770 cease and desist, and disruption notices - this includes 262 cease-and-desists issued to operators and 205 to advertisers.  

Over that same period the Commission has referred over 102,000 URLs to Google with 64,000 of these removed by the search engine, and 264 websites taken down. This is more than a tenfold increase in URL takedowns in comparison to the whole of 2023 to 2024.

There is more to do of course and that also is true of others in the sector. I will not say any more about this as it is clearly a live case, but last month a public statement was made by a leading supplier of gambling games to the GB sector, that the Commission had commenced a review of their operating licence as a result of identifying their games being available to consumers in Great Britain from operators who do not hold a licence from us.

I have also made clear to licenced operators that whilst it is not their job to take action against illegal operators, I have firmly encouraged everyone to ensure they have undertaken due diligence regarding their own activities and those of any suppliers they rely on. If the Commission detects illegal activity in any operator – B2C (business to consumer) or B2B (business to business) – we may well immediately suspend their licence and, in any event, they face the very real prospect of having their GB licence revoked, which means anything they are supplying to anyone else in Great Britain will cease immediately.

It is not an accident that we have been working closely with other regulators around the world, nor that we created through the International Association of Gaming Regulators the Illegal Gambling Working Group, which now covers every populated continent in the world. Respectable regulators around the world all want the same thing – illegal gambling to stop, which is why we are active in signing Memorandum Of Understandings (MOUs) with those regulators and sharing information to help them as well as us.

As is the case in many countries, the debate about gambling, gambling regulation, personal freedom and on the other hand consumer protection is often tense. The interactions I have with operators on a weekly basis tells me that the vast majority of this industry wants to do the right thing and wants the clarity the implementation of the 2023 White Paper would bring. And that is why it is so frustrating at times to see what is said in public by people on all sides of the debate.

Now not everyone here will be following the day to day nuances of the debate in Great Britain and why would you? So let me give you an example from when we published our Industry Statistics in November. Those official statistics will tell you plenty about what is going on in gambling in Great Britain. They tell you for instance that Arcades - or Adult Gaming Centres (AGC’s) - GGY has increased significantly, outstripping the rise in machine numbers and relatively static premises numbers. They tell you that online GGY is increasingly reliant on casino games and especially slots. They also tell you that GGY on Horseracing is up even when turnover is down. They tell you that with participation being stable, consumers have been widening out their activity. Our Industry statistics tell us plenty. But if you distort how you view something, you are never going to get an accurate picture. We all need to be responsible on how we use information.

I have already talked about the risks of assuming consumer spend or staking would track with inflation – there is little reason why it would, even if operational costs in the industry or in any given sport are climbing. There are also some very polarised blocs of opinion in GB, who have very strongly opposing views to each other and often want very conflicting things.

The evidence base is sometimes bitterly fought over and whilst I do not think it has been a surprise as such, moving to a new methodological approach for estimating gambling participation and rates of problem gambling has been challenging, despite the many years of preparation, consultation, engagement and external evaluation. The previous methodology used – the Health Survey – was very good in its time, but the methodology relied on face-to-face interviews and that has become increasingly difficult to do, with the 2023 England survey unable to take place at all. Other parts of Great Britain have also already changed their methodology. When you consider surveys took place with multi-year gaps between them, with long gaps between fieldwork and eventual publication, in a world where we are seeing something new all the time that is just not sustainable in this day and age – especially when that survey might not happen at all.

I think it is important for regulators to have access to the best evidence base they can, as frequently as they can. Everyone in the debate should be clear about the strengths and weaknesses of any data or evidence, but being clear about the limitations does not mean the same thing as a lack of confidence or saying something cannot be relied on. Nor should anyone be trying to distil an entire complex industry with a wide range of activities and mixed consumer behaviour into a single number – we certainly are not. Estimates of problem gambling are important – of course they are – but we also need the widest evidence base possible and everyone should recognise the nuances in consumer experiences.

The focus in 2025 for the Gambling Commission is obviously on the things I have already mentioned, and that was not an exhaustive list, but will also be on our statutory objective that gambling should be Fair and Open. This is an increasingly complex area as operators contend with large-scale identity misuse by organised gangs, more routine bonus abuse and multi-accounting as well as a range of other issues, including AI Know Your Customer (KYC) spoofing and so on. In this mix are customers who are not engaged in any of those activities but might have been caught by the efforts to prevent them. We have also seen some operators advising customers they are conducting checks or requesting information for ‘regulatory reasons’ or because the Gambling Commission require them to, when this is simply not the case whatsoever. We are considering what action we may need to take with these operators.

Overall, we expect to be saying far more about the area of gambling being Fair and Open, as well as continuing to press on the issue of transparency for consumers and understanding the level of restrictions in place in the GB market. Any operator can refuse business for commercial reasons and nobody is suggesting that will change, but we do need to have a better understanding of the scale and impact of this in a very liberalised and channelised market.

As I wrap up my remarks, what is the high-level picture for gambling in Great Britain as we have entered 2025?

• Overall GGY is up and to the highest level ever

• Participation is static at just under half the adult population engaging with gambling on a regular basis

• Lotteries remain the largest area of participation with sales now for large society lotteries over £1 billion annually, but large prize draws, which are not regulated as gambling, have a very large presence in terms of participation and are just behind betting and far ahead of bingo and land-based casino

• Online casino games have continued to grow in terms of market share

• Consumer spend looks to be spread over a longer period of time and potentially a wider range of products, according to some operators

• The debate is tense and with a lot of work still to be done implementing the 2023 White Paper, perhaps that is to be expected.

Thank you very much for taking the time to listen to me today and I hope to be able to answer some questions from the audience.

Before I finish, I just wanted to briefly update you on where things stand with the implementation of the Gambling Act Review itself. I said earlier we have been working hard to implement the outcomes of the 2023 White Paper and that work continues. Very soon - by which I mean days or weeks – we will be publishing our next consultation on Games Machine Technical Standards. And I want to say we are grateful for the feedback industry provided during pre-consultation phase last Autumn. That information has been invaluable.

And I’ll end it there.

Thank you for listening and I am looking forward to your questions.

Thank you.

Last updated: 21 January 2025