High stakes. Commentary on the 2023 United Kingdom government white paper on gambling reform.

The Academic Forum for the Study of Gambling (AFSG) broadly welcomes the long-awaited white paper on gambling published by the United Kingdom (UK) government on 27 April 2023 [1]. The AFSG is a group of academic researchers in the United Kingdom dedicated to advancing the research needed to effectively prevent, reduce and address gambling harm. The white paper addresses many concerns that have been expressed by those affected by gambling-related harm. In some parts, the proposals are based on the existing evidence, but in other parts, this is not the case. AFSG is keen to see evidence used appropriately to inform regulatory reform and to ensure that relevant research continues to develop and be supported in ways which best lead to a greater understanding of, and reduction in, gambling related harm. A Royal Commission in 1978 recommended establishment of an independent Gambling Research Unit [2], and the Gambling Review Body [3] and DCMS committee [4] both recommended that this should happen with the 2005 Gambling Act. It did not happen and little gambling research has been funded by established medical or social research councils. Research has continued to be piecemeal and continues to be influenced, to some degree, by the industry. Because of the perceived influence of industry many academics have shunned gambling research funding, which has been available via organisations such as GambleAware [5], and this has arguably led to a brake on the quantity and quality of research in the field. We trust that plans in the white paper to raise meaningful amounts for research from a statutory levy and use those funds in a clearly thought out manner, with advice from the research councils and academic experts, will now come to pass. We briefly note several specific items in the white paper that remain of concern in relation to gambling related harm. Advertising does succeed in recruiting individuals to gambling, and those who are vulnerable are then particularly likely to experience gambling related harm [6]. Voluntary codes of practice and partial bans (such as that in relation to premier league football teams, but not teams in other leagues) send mixed messages and are unlikely to do much to reduce harm. The white paper is largely silent on the subject of the gaming industry and issues raised in the space between gaming and gambling. In the United Kingdom, the Gambling Commission, the House of Lords and others have noted a very strong correlation between use of the so-called loot boxes (an in game purchase which contains random unknown contents) and problem gambling [7, 8]. The evidence has persuaded a number of countries to ban these products. The AFSG has funded research that shows that over 80% of highest grossing iPhone games in Belgium were still selling loot boxes despite bans by the regulator, the Belgian Gambling Commission [9]. This highlights an issue that is pertinent to a number of aspects of gambling regulation; the need to not only have restrictions on products and features that are highly correlated with harm, but also to ensure that those restrictions are properly monitored and enforced and that regulators are given sufficient resources to be effective in those activities. Affordability checks are a logical way to ensure that people do not come to harm by spending more than they can afford. However, there are questions regarding proportionality and inequity if those who are vulnerable and disadvantaged financially are subject to excessive surveillance and limitations on their freedoms. Again, adequate support for compliance and monitoring will be important in ensuring that the checks are effective and balanced. Children feature as a concern in every review of gambling legislation [10]. It is good that young adults (under 25) are also now recognised as a group particularly vulnerable to gambling harms. The white paper refers to distinctions between gambling products for adults and lower risk products for children, such as crane grabbers. Another researcher supported by the AFSG has shown clear correlations between high levels of use of gambling activities/products as a child and subsequent gambling harm as an adult [11]. We trust that the consultation period will lead to effective regulation within the lifetime of this parliament and that the architecture for better research and better regulation is constructed before significant further gambling harm accrues. None. Data sharing not applicable - no new data generated.