The impact of gambling marketing

On 25 April 2024, the House of Lords is due to debate the following motion:

Lord Foster of Bath (Liberal Democrat) to ask His Majesty’s Government what assessment they have made of the impact of gambling advertising, marketing and sponsorship on problem gambling, and in particular the risk of exposure to gambling advertising on children.

1. Problem gambling and its prevalence

The Gambling Commission, which regulates the individuals and businesses that provide gambling services in Great Britain, has referred to problem gambling as “behaviour related to gambling which causes harm to the gambler and those around them” and “gambling to a degree that compromises, disrupts, or damages family, personal, or recreational pursuits”.^[1]

In an evidence review updated in January 2023, Public Health England (PHE) identified the following types of harms associated with such behaviour:

• Financial, such as debt and bankruptcy. As well as being harms in themselves, the report said they could lead to other types of harm on the list.
• Relationship, including lower levels of family functioning and social support and an increased risk of domestic abuse.
• Mental and physical health, such as an increased risk of dying from any cause and a significantly increased risk of suicide. Problem gamblers were also more likely to suffer from self-harming, depression, problems relating to sleep, alcohol and drugs.
• Employment and education, for example a loss of concentration at work that can mean a higher risk of losing a job or being demoted. Child gamblers, and children of gamblers, also experienced difficulties at school.
• Criminal and anti-social behaviour, such as theft, fraud and selling drugs.
• Cultural, for example shame and isolation resulting from societal attitudes to gambling.^[2]

Until recently, the Gambling Commission had assessed problem gamblers to account for less than 1% of adults, with that rate having fallen over recent years. A telephone survey it conducted estimated problem gamblers to be 0.8% of the population in the third quarter of 2016, with the figure decreasing to 0.3% by the first quarter of 2023.^[3] However, in 2023 it started publishing experimental estimates based on updated methodology and new survey questions which assessed the problem gambler rate to be closer to 2.5%.^[4] Based on the Office for National Statistics’ latest population estimates, this would imply that over 1 million people in Great Britain are problem gamblers.^[5]

The number of people actively seeking help for gambling related harms has increased in recent years. In January 2024, GamCare—a provider of information, advice and support for people affected by gambling harm—reported that their national gambling helpline received 52,370 calls and online chats in 2023, a 24% increase relative to the previous year.^[6] In July 2023, the NHS reported significant growth in referrals for its gambling harms services and announced that it was opening up seven new gambling clinics, adding to the eight already in operation.^[7]

2. The impact of gambling marketing

The precise role that the marketing of gambling services, such as advertising and sponsorship, plays in generating problem gambling is not clear. In July 2020, the House of Lords Committee on the Social and Economic Impact of the Gambling Industry reported that, while there was a correlation between gambling advertising and problem gambling, it had “received no evidence nor been pointed to any research which proves that there is any causal link” between the two.^[8] This lack of robust empirical evidence was reflected in a PHE evidence review published in September 2021.^[9] The review examined studies attempting to identify risk factors for gambling and harmful gambling, and found that, while advertising and marketing influences gambling activity in general, there was a “a lack of review-level evidence examining if marketing and advertising is a risk factor for harmful gambling”.^[10]

However, while empirical studies may not have established a causal link, the following observations have been made:

1. The activity of problem gamblers has been reported to contribute significantly to the profits of the gambling industry. A 2018 report from Respublica, a think tank, estimated that almost a quarter of online gambling profits are derived from problem gamblers, with a further third of the profit share derived from those who are at risk of becoming problem gamblers.^[11]
2. A significant portion of gambling industry revenue is spent on marketing. Up to date figures regarding how much the gambling industry spends on marketing are not publicly available. However, a 2018 report from Regulus Partners estimated that gambling advertising and marketing spending increased from around £1bn in 2014 to over £1.5bn in 2017.^[12] Statistics published by the Gambling Commission estimated total industry revenue in the year to March 2017 to be £13.8bn, suggesting, therefore, that over 10% of industry revenue is spent on marketing.^[13]
3. Problem gamblers self-report to be more affected by gambling advertisements than non-problem gamblers. In February 2023, the Public Health journal published an article reviewing evidence on “the impacts of gambling-related advertising that could lead to gambling-related harm”.^[14] This evidence review noted that a “higher percentage of those experiencing moderate risk or problem gambling reported that social media promotions for gambling increased their problems compared with low-risk and non-problem gamblers”.^[15]

In relation to such observations, the Lords committee examining this issue expressed scepticism that a link between advertising and problem gambling did not exist:

Plainly the companies would not spend increasingly large sums on advertising if they did not believe that this would increase either the overall amount gambled, or the amount gambled with their company, or both, and it does indeed seem counter-intuitive that this should not also result in an increase in gambling-related harms.^[16]

3. Exposure of children

In March 2018, GambleAware, a charity dedicated to preventing gambling harms, commissioned two independent consortia (one led by Ipsos MORI and the other led by the University of Stirling) to assess the “extent, nature and impact of gambling marketing and advertising on children, young people and vulnerable groups in the UK”.^[17] The final report, published in March 2020, found that, while children were not being targeted directly (for example, with adverts in children’s media), almost all children and young people reported to have been exposed to gambling adverts, with only 4% of 11- to 24-year-olds participating in the study reporting to not have been exposed in the previous month. The most common routes for exposure to gambling advertising were through television (85%), shops on the high street (70%) and social media (66%). The report found that for young people who did not currently gamble “exposure to advertising was significantly associated with likelihood to gamble in the future”.^[18]

The 2023 iteration of the Gambling Commission’s young people and gambling survey reported 40% of 11- to 17-year-olds to have had experience with gambling, with 26% reporting “active gambling involvement”.^[19] The foremost types of activity were arcade gaming machines and bets for money between friends or family. However, small portions also reported experience of fruit or slot machines and betting on a betting website or app. The survey estimated 0.7% of 11- to 17-year-olds to be problem gamblers, with a further 1.5% at risk.

Regarding the link between advertising and problem gambling among children and young people, the Public Health journal evidence review referenced above assessed that advertising exposure would not of itself encourage young people to start gambling. However, it did suggest that advertising exposure would “generate difficulties for existing young gamblers, especially those experiencing problems, who reported that gambling advertising had some impact on their behaviour”.^[20]

4. Government policy

In April 2023, the government published a white paper, ‘High stakes: Gambling reform for the digital age’, which set out its plan for reforming gambling regulation.^[21] In the white paper the government said:

We recognise that people should be free to spend their money as they choose, but when gambling poses the risk of becoming a clinical addiction the government needs to ensure there are proper protections.^[22]

The government said that “gambling harms can wreck lives, impact families and communities, and even lead to suicide in extreme cases” and that the package of measures outlined in the white paper would “significantly increase protections with the aim of preventing harm”.

With respect to marketing and advertising, the white paper said it had “expanded into new channels and grown significantly since 2007” and that:

There is good evidence that it can have a disproportionate impact on those who are already experiencing problems with their gambling. We also know some forms of online advertising have a strong appeal to children (under 18) and young adults (aged 18 to 24), and some aggressive marketing practices are particularly associated with harm.^[23]

The government assessed that voluntary actions by the industry to reduce the risk of these kinds of harm had not gone far enough and that it was, therefore, proposing a series of actions, including the following:

• The Gambling Commission will “undertake a review of incentives such as free bets and bonuses to ensure that they are constructed and targeted in a socially responsible manner which does not encourage excessive or harmful gambling”.^[24]
• The Gambling Commission will “take forward work to strengthen consent for direct marketing for online gambling, with both new and existing customers given more choice on what offers they want and how marketing is sent to them”.^[25]
• The Department for Culture, Media and Sport’s (DCMS) ‘Online advertising programme’ is reviewing the role of platforms to ensure the ads that appear on them are safe and socially responsible.^[26]
• Working with the gambling commission, the government will develop a “new, evidence-based model for independently developed safer gambling messages” replacing the current model of industry ownership of such messages.^[27]

Two consultations were subsequently published by the Gambling Commission regarding these actions in July and November 2023. However, the findings of and response to these consultations had not been published at the time of writing.^[28]

An Online Advertising Taskforce ‘action plan’ was published on 30 November 2023, following DCMS’s Online Advertising Programme.^[29] The task force, which brought together various government departments, agencies and industry associations, committed to two headline objectives: improving evidence of in-scope harms and enhancing initiatives to tackle in-scope harms. Actions to “raise industry standards and improve diligence” (such as increasing standards of age assurance for age-restricted advertising online) were taken away by the Incorporated Society of British Advertisers, the industry body that “represents brand owners advertising in the UK”.^[30]

In a March 2024 debate on gambling advertising in sport, Stuart Andrew, parliamentary under secretary of state at DCMS, said:

There is no single intervention that effectively prevents gambling-related harm, and that is why we have taken an evidence-led approach to implement a package of reforms targeted at different levels, including advertising. We absolutely recognise that advertising can have a disproportionate impact on those experiencing gambling harms. Technological advances and developments and the increasing dominance of online gambling have necessitated a doubling of efforts from us as a government. We and the Gambling Commission are now taking targeted action to ban harmful practices and to ensure that advertising remains socially responsible wherever it appears.^[31]

Stephanie Peacock, shadow minister for DCMS, said she had observed “the devastating effect that gambling can have on people’s lives” and said she was “pleased that the government are finally under way with the implementation stage of the long-awaited gambling white paper”, noting that it had cross-party support.^[32]

5. Read more

• House of Commons Library, ‘Gambling advertising: How is it regulated?’, 7 March 2024
• House of Commons Culture, Media and Sport Committee, ‘Gambling regulation’, 21 December 2023, HC 176 of session 2023–24
• House of Lords Library, ‘Gambling advertising and harm caused by gambling’, 2 February 2022
• Raffaello Rossi and Agnes Nairn, ‘What are the odds?: The appeal of gambling adverts to children and young persons on Twitter’, Bristol University, October 2021

Cover image  by Nik on Unsplash