Britain’s New Gambling Review Goes Beyond the White Paper

The review looks back to the Budd Report of 2001 and the legislation that followed. The Gambling Act 2005 created the central framework under which the Gambling Commission regulates commercial gambling in Great Britain. It came fully into force in September 2007.

There is a temptation to treat the age of the Act as sufficient evidence that it has failed to keep up. The history is more complicated. The original legislation explicitly recognised remote gambling, including participation through the internet and other electronic communications. Online activity was already part of the framework lawmakers were designing.

What has changed is the environment in which those provisions operate. Smartphones have made gambling continuously accessible, while digital payments, personalisation and new forms of trading have complicated the boundaries between products and regulatory responsibilities.

The government’s April 2023 White Paper, High Stakes: Gambling Reform for the Digital Age, was itself an attempt to respond to that change. Measures subsequently introduced include online slot stake limits of £5 for customers aged 25 and over and £2 for those aged 18 to 24. The statutory gambling levy commenced on 6 April 2025, creating a compulsory funding mechanism for research, prevention and treatment.

The new review therefore begins with a system that has already undergone significant intervention. Its historical task is to distinguish provisions that remain useful from those that constrain an effective response, while assessing reforms whose effects are still developing.

Some of the most consequential questions appear in the commission’s terms of reference.

For particular forms of remote gaming, the document invites comparison between conventional commercial licensing and alternatives including restricted licensing, concessions and exclusive public provision, potentially through a state monopoly. It also asks whether a reformed Act should provide for civil liability for gambling-related harm.

The relationship with sport receives separate attention. The committee will examine whether a statutory Sports Betting Levy could replace part of General Betting Duty, alongside the existing economic relationship between betting and British horseracing.

These are options and questions for investigation, rather than recommendations the commission has already adopted. They nevertheless show the potential breadth of the exercise. The discussion could reach the commercial basis on which some gambling is offered, the allocation of responsibility when harm occurs, and the distribution of income generated around sport.

Any comparison of market structures would need to consider how each model performs in practice. Limiting the number of providers, for example, could change competition, product choice and the incentives facing the regulator. Public ownership would also require scrutiny of the relationship between revenue generation and consumer protection. The institutional label alone would settle very little.

For the industry, that makes participation worthwhile. Evidence about how a market functions will be more useful than assuming the present licensing model is either indispensable or beyond repair.

The commission’s decision to examine taxation alongside regulation is particularly relevant to current conditions.

Remote Gaming Duty increased from 21% to 40% for accounting periods beginning on or after 1 April 2026. That change sits alongside obligations relating to product design, customer protection and the statutory levy. Operators encounter the combined effect through the economics of the products they offer.

Our examination of the proposed free-spins tax rewrite following Jumpman illustrates why the wording of a fiscal measure can matter as much as its headline rate. Promotional design, prize costs and tax treatment interact within the same offer.

That creates a legitimate subject for research. Operators may respond to changing costs by altering promotions, reducing investment, narrowing product ranges or changing their approach to less profitable customers. The review should seek evidence of which responses occur, how large they are and what consumers experience as a result.

Lower operator margins alone would not establish that a policy has failed. Equally, higher tax receipts would provide an incomplete account of success if accompanied by adverse consequences elsewhere. The useful assessment connects commercial changes to public outcomes, including protection, competition and continued participation in the licensed market.

This also requires care with claims about customers moving offshore. A plausible incentive is a reason to investigate behaviour. Establishing what actually caused that behaviour requires stronger evidence.

The review’s clearest opportunity is to improve how competing claims are tested.

Gambling policy involves several different questions: how many people experience harm, how much money reaches unlicensed businesses, whether an intervention changes behaviour, and whether that change improves people’s lives. A measure designed to answer one question can easily be stretched into an answer to another.

As our analysis of the Gambling Commission’s Illegal Gambling Index explained, a survey estimate of participation and an estimate of illegal operators’ revenue describe different things. Website traffic provides another perspective. The definitions and denominators matter before any of those figures enters a policy argument.

The same discipline should apply when evaluating the White Paper reforms. A change in a reported harm measure after an intervention does not, by itself, establish what caused it. Researchers need to consider the timing of implementation, changes in the population being measured and other developments affecting gambling behaviour.

Our view is that the most valuable report would explain which conclusions the evidence supports, where findings remain uncertain and what further work could resolve that uncertainty. That would give policymakers a firmer basis for choosing between targeted amendments, improvements in enforcement and wider legislative change.

Operators have a useful contribution to make through data on customer behaviour and the effects of interventions. Researchers and treatment organisations bring different forms of evidence. The committee’s task will be to assess their strength and limitations consistently, including findings that complicate its emerging conclusions.

The commission’s published principles include independence, evidence, proportionality and transparency. Its terms envisage publishing submissions, commissioned research and discussion papers where appropriate before the final report.

That process will be important to the credibility of the recommendations. Clear information about funding, relevant interests and research methods would help readers assess the work. Explanations of how contradictory findings were handled would be equally valuable. Independence becomes more persuasive when the reasoning can be examined by people who disagree with the outcome.

There is also a risk in the timetable. A report planned for 2028 will arrive in a market that continues to change while the research is being conducted. Policy may develop during that period, and new products may expose problems that were less apparent at the outset.

The work would therefore benefit from a clear distinction between findings that justify action under existing powers and questions requiring longer legislative consideration. Otherwise, a broad review could allow immediate problems to disappear into an extended argument about the ideal future system.

For established operators, the exercise opens a further period of policy scrutiny. It offers a chance to make a substantiated case for workable rules, while also exposing business models and assumptions to independent challenge. For consumers, its value will depend on whether the eventual proposals make protection, fair treatment and access to redress more effective in practice.

The next concrete stage is the evidence submission deadline on 12 February 2027. The document published on 9 November gives a formal opening date of 4 November, with research continuing through 2027 ahead of the planned 2028 report.

Britain now has another forum in which to debate its gambling laws. Whether it produces a useful basis for reform will depend on what happens between that invitation and the final recommendations: the quality of the evidence, the openness of the analysis and the strength of the case for each proposed change.