Last week Lord Foster of Bath took us once again through the looking glass of gambling policy discourse. Just as the Queen of Hearts professed to believe six impossible things before breakfast, Foster seems to dream up any number of fantastical claims before his Horlicks’ has brewed. In the space of just 30 seconds last Thursday, the Liberal Democrat peer told the House of Lords five things that are untrue about children and gambling.

Perhaps the silliest of the noble Lord’s claims was that there are 80,000 children in Britain addicted to gambling. This, as the Gambling Commission and others have pointed out in the past, is a corruption of findings from the 2023 edition of its Young People and Gambling Survey (‘YPGS’) and constitutes a misuse of official statistics. It is based on the self-reported behaviours of 25 schoolchildren, many of whom reported no harms from gambling but were classified as ‘problem gamblers’ on the basis of risky behaviours. The most commonly reported activities engaged in by these children were entirely legal, including seaside amusements and wagering or playing cards with family and friends. Several of the children involved reported no participation in age-restricted forms of gambling. According to Lord Foster’s interpretation of the YPGS, there are as many as 54,400 children in Britain addicted to seaside amusements (or 44,800 addicted to playing cards within the family or betting with schoolfriends).

It is easy to see how the casual reader might misinterpret the YPGS statistics – but this is not an excuse that Lord Foster can easily claim. As a Member of Parliament, he fulfilled the role of Liberal Democrat spokesperson on gambling. Between 2019 and 2020, he sat on Lord Grade’s House of Lords Select Committee on Gambling; he is currently chair of the pressure group, Peers for Gambling Reform; and a member of the activist organisation, Action on Gambling. In short, Lord Foster considers himself a subject matter expert. He recently served on the House of Lords Liaison Committee on Gambling where he received evidence from the Gambling Commission and others regarding the meaning and reliability of data from the YPGS – evidence that he appears to have disregarded. The possibility must therefore be considered that Lord Foster knew that what he told his fellow peers was not strictly accurate.

As I described in a recent article in the Racing Post, some consider it acceptable to disseminate misinformation on gambling harms in support of what they perceive to be a just cause (the suppression of licensed betting). This is a version of Plato’s ‘noble lie’ – the idea that it is permissible for the state to mislead the populace in what it considers to be their best interests. There are, of course, instances where a lie might be considered justified (during times of war or national emergency), but this is neither liberal nor democratic and not something to be encouraged. It should be no more acceptable to manufacture statistics on harmful gambling as it would be for heart disease. Misinformation is a lousy basis for sound policy.

The interminable debate on the regulation of gambling is crying out for those in positions of authority to set the example and demonstrate moral leadership. Almost three years ago, the then chief executive of the Gambling Commission, Andrew Rhodes, published an open letter on the unacceptability of statistical misuse, threatening robust action. After a brief flurry, this war on misinformation petered out, with the regulator explicitly watering down its guidance in order to avoid the need to act. The Commission occasionally requests corrections where official statistics are misused but these are invariably ignored. Mr Rhodes’s threat of referral to the Office for Statistics Regulation for repeat offenders has been exposed as a paper tiger.

Among serial abusers of statistics, a novel line of argumentation has emerged – the proposition that factual accuracy is beside the point because the evidence base as a whole indicates the need for ever more draconian state intervention. Quite aside from the fact that good research tends to be messy (and rarely points in a single direction), this ignores the fact that the evidence base itself is constituted of a wide array of facts and figures. Once the principle is accepted that reliability is no longer a prerequisite for individual data points, the validity of the so-called ‘evidence base’ as a whole must be called into question.

The Gambling Commission has fatally undermined its ability to hold others to account by itself publishing misleading statistics, misrepresenting research findings, suppressing evidence on the basis of convenience, funding numerous research projects of questionable quality and even paying campaigners to lobby for regulatory reform. Over the course of the last seven years, The Commission has squandered the reputation for trust and competence built so carefully by its first two CEOs, Jenny Williams and Sarah Harrison. A growing number of commentators, including Vaughan Lewis, have questioned whether it can any longer be considered fit and proper.

The great tragedy of the current situation is that – at a point where funding has never been greater for the study of gambling behaviours and gambling harms – the quality of research has never been poorer. The establishment of a new £10m a year national centre for the study of gambling harms should create the foundations for scientific progress. The decision to locate this centre at the University of Glasgow – a hotbed for anti-gambling activism – means that these hopes are unlikely to be fulfilled.

The indifference to factual accuracy of the regulator, parliamentarians and academic researchers bodes ill. The industry has been far too tolerant of misinformation – perhaps because it is a game that it has played itself at times. Unless that changes, the very laws that govern the operation of the licensed market are at risk of subversion. For now, the noble Lord Foster and several others in Parliament might accept a little wisdom from the March Hare: “Ah, but that’s the point! If you don’t think, you shouldn’t talk!”

On Thursday this week the Gambling Commission crosses a line. The British gambling market regulator will publish results from its Gambling Survey for Great Britain (GSGB) in the knowledge that the results are inaccurate; and that they will be used to agitate for tighter controls on consumers and higher taxation for licensees.

First published in 2024, the GSGB reports substantially higher rates of ‘problem gambling’ (as measured by the Problem Gambling Severity Index or ‘PGSI’) than all other sources of official statistics, stretching back almost two decades. These include the ‘gold standard’ NHS Health Survey for England, the NHS Scottish Health Survey, the NHS Adult Psychiatric Morbidity Survey and the British Gambling Prevalence Survey. Last year, the Commission was provided with hard evidence that the GSGB over-reports rates of participation in landbased casino gaming, exchange betting and the football pools – three sectors where the availability of reliable administrative data can be used to test self-report survey estimates. The landbased casino gaming, exchange betting, and football pools sectors are clearly discrete modes of gambling, which means the over-reporting in the sectors that can be tested strongly implies a problem endemic to all sectors in the survey as well as participation as a whole.

The Gambling Commission does not dispute the quality of the administrative data presented (indeed, it formerly collected and published the casinos data itself); but it has proved distinctly unwilling to admit that its survey might be wrong despite glaring and incontrovertible evidence that it is. In supplementary evidence provided to the House of Lords Liaison Committee last month, the regulator set out a two-pronged defence. First, it asserted that the GSGB had been “developed by experts, reviewed by experts and approved by experts”. Second, it drew attention to conclusions from three experiments conducted last year by researchers at the London School of Economics (LSE), which it seemed to think put it in the clear.

The first of these arguments is clearly unscientific. It implies that the Commission is willing to disregard cold, hard evidence on the basis that it is inconsistent with expert say-so. Neither is it the case that all experts are fans of the GSGB – many are not. Some of those who have endorsed the survey are heavily involved in anti-gambling activism. The regulator’s decision to elevate the opinions of researchers whose goal is to ‘denormalise’ gambling (and who liken betting to tobacco and asbestos) over hard, empirical evidence reveals just how little interest it has in evidence-based policy or carrying out its duty as a balanced and objective regulator.

The second argument is more complex than the Commission would like us to believe. Last year’s ‘three experiments’ conducted by researchers at the LSE produced two main findings. First, survey description matters. In one experiment, a ‘gambling’ survey elicited much higher rates of gambling participation and higher PGSI scores than an otherwise identical ‘health’ survey. In a second experiment online data collection resulted in higher rates of gambling participation and higher PGSI scores than interviews conducted by telephone.

These results are unsurprising. They reinforce findings from studies in Canada and elsewhere dating back a decade-and-a-half. The first supports the theory of topic salience bias - that the GSGB is likely to over-sample gamblers (and highly engaged gamblers in particular) because it is advertised as a gambling survey. The second indicates that telephone surveys may under-report gambling and problem gambling. The relevance of this latter finding to the question of NHS data reliability is unclear. Health Surveys are conducted in-person (rather than by phone) and use self-completion booklets specifically to guard against the effects of social desirability bias. Previous studies have shown that in-person interviews are much less likely to be affected by this bias than telephone surveys. The Health Survey was therefore deservedly considered a 'Gold Standard' within the parameters of the possible; the GSGB represents more than a few steps backwards in terms of reliability, but in a direction that seems to suit the Commission and the 'experts' it likes to fund.

Taken together, the results of these experiments reinforce concerns that the GSGB overestimates participation and prevalence. The second experiment might indicate under-reporting in the Health Survey and other NHS surveys – but this is a matter of speculation (because the experiments did not test for this) and the size of any effect cannot be guessed at. If the experiments tell us anything about the GSGB, it is that it inflates estimates. The Commission believes that we should ignore these results and focus instead on subjective interpretation – once again encouraging policymakers to ignore the science and focus on the opinion. It is therefore relevant that one of the researchers involved in the study described the experiments as being, “not very informative about general population surveys”.

The Gambling Commission has expressed confidence that GSGB over-reporting cannot be explained by respondents misunderstanding the questions. This means that the over-reporting can only be the consequence of skew in the survey or the existence of massive and hitherto undetected unlicensed markets for landbased casinos, exchange betting and the football pools. Under either scenario, the survey results cannot be considered reliable for understanding consumer activity in the licensed markets. This however is precisely how the results are used – by campaigners, by politicians and by the Commission itself.

There should be only one course of action for the Gambling Commission. As well as the ethical responsibility to do the right thing (one of the regulator’s stated values), the Commission knows that the GSGB is being used by those who wish to subvert the Gambling Act 2005 (ie, the legislation that it is charged to uphold). As a producer of statistics, it is bound by the UK Statistics Authority’s Code of Practice, which requires it to “prominently explain the quality of the statistics, including strengths and limitations, and communicate the uncertainty in estimates”.

In recent years, the Gambling Commission has funnelled millions of pounds into anti-gambling activism, suppressed evidence on the basis of convenience and promoted illiberal speech codes. It has skirted with conduct beyond the pale. On Thursday, by publishing statistics it knows are not to be trusted, it crosses a line.

At the centre of the controversy is a study published in August last year by researchers from the London School of Economics (‘LSE’) and NatCen. The study (Sturgis et al., 2025) used three experiments to test for the effect of different biases on survey results, to help explain why the Commission’s Gambling Survey for Great Britain (‘GSGB’) produces much higher estimates of gambling participation and potentially harmful gambling than NHS surveys. Findings from the study were consistent with previous research but largely inconclusive. Headline results support the hypothesis that otherwise identical surveys produce higher estimates of gambling and ‘at risk/problem gambling’ where the topic is described as ‘betting, lotteries and games’ (rather than ‘health, wellbeing and recreation’) and where it is conducted online (rather than by telephone). If anything, the results of the experiments appeared to support concerns that the GSGB over-estimates participation and prevalence; but not much new was learned.

On 6^th August - eight days before the study was published - the Gambling Commission wrote to the LSE to ask whether the experiments might be used to justify a loosening of guidance on the GSGB. The Commission explained that unnamed ‘stakeholders’ wanted to have some of the restrictions on use of statistics to be removed – particularly the stipulation that the GSGB should not be used to provide population estimates of the prevalence of ‘problem gambling’. The LSE replied in the negative, with the researcher approached by the Commission writing, “I don’t think the experimental results really makes much difference to this [the GSGB guidance]”. In the weeks that followed, two of the Commission’s own officers warned that the LSE/NatCen study could not be used to justify a relaxation of GSGB guidance; but on 2^nd October, the Commission did just that. The regulator declared (without explaining why) that the results of the experiments provided greater confidence in the GSGB and loosened its guidelines in accordance with the wishes of the unnamed stakeholders. One Commission officer wrote at the time “hopefully we will get less reports of misuse in the future”, because the grounds for making complaints had been narrowed.

In January, the Gambling Commission claimed that the LSE/NatCen study absolved it of responsibility to apply more prominent reliability disclaimers to the GSGB, as had been recommended by the Office for Statistics Regulation the previous May. Why this should be the case was not explained.

Further FOIA disclosures show that the Department for Culture, Media and Sport was unaware of the Commission’s sleight of hand. The market regulator appears therefore to have knowingly misrepresented the significance of the LSE/NatCen study to the Government as well as to the OSR and the public. The Commission’s conduct appears therefore to be in breach of the Civil Service Code, the Nolan Principles on Public Life and the UK Statistics Authority’s Code of Practice for Statistics. Evidence of misrepresentation was provided to the Commission in January this year. So far, the regulator has not disputed the accuracy of the evidence.

In a further development, the Gambling Commission has refused two FOIA applications to disclose the information it provided to HM Treasury in the run-up to the Budget, arguing that to do so would not be in the public interest. This is also problematic. In January, its outgoing CEO, Andrew Rhodes, revealed on a podcast, that the information provided by the Commission to Treasury suggested caution where changes to duty rates were concerned. The Commission’s refusal to release that information raises several questions regarding the conduct of both bodies. Did Treasury ignore the gambling market regulator? Was the information supplied accurate? Did the Commission really suggest that caution was the best policy? If the Commission restricted its commentary to facts and figures rather than advice, why is it so reluctant that anyone else should see it? The episode carries echoes of its refusal – for more than three years -to release evidence showing strong consumer opposition to affordability checks.

Based on the information that is in the public domain, the Gambling Commission appears to have contributed positively to HM Treasury’s decision to hike online taxes. According to papers from its now defunct Advisory Board for Safer Gambling, the Commission discussed lobbying Treasury officials on the economic costs of gambling and spoke of its desire “to find the thing that hurts” the licensed industry. It facilitated the funding (at £140,050 in quasi-public money) of a shockingly inept report on the fiscal costs of gambling by the National Institute of Economic and Social Research (‘NIESR’). The Commission ignored complaints that NIESR had broken funding rules, and the Social Market Foundation used the report to lobby for hikes on gambling duties.

Over the course of the last five years, the Gambling Commission has funnelled millions of Pounds into anti-gambling activism, published statistics on gambling harm in the knowledge that they are unreliable, promoted anti-gambling speech codes, agitated for a tax increase on licensees (the Statutory Levy) and presided over the mushrooming of the illegal market for gambling in Great Britain (having initially sought to downplay legitimate concerns). According to a poll this year from More in Common, just 33% of British adults trust the Gambling Commission. It seems likely that the figure is even lower amongst those whom the Commission regulates. Whoever is appointed as the regulator’s ‘new broom’ would do well to reflect on the culture that permits the weaving of such tangled webs. Problems swept under the carpet tend to accumulate rather than disappear.

It is said that good manners cost nothing, but such is the state of public finances these days that the Department of Health and Social Care (‘DHSC’) cannot stretch to even an ounce of civility. In December, the Director-General of the Office for Statistics Regulation (‘OSR’) wrote to the DHSC to bring to its attention the repeated misuse of departmental statistics on economic costs associated with gambling harm; and to advise on corrective measures, including the addition of prominent disclaimers. According to Global Gaming Insider however (UK Department of Health responds to public rebuke from OSR Director General), the DHSC believes that it knows better than the state regulator how statistics should be treated and has snubbed the OSR.

At the heart of the matter lie two controversial reports, produced by Public Health England in 2021 and the Office for Health Improvement and Disparities (‘OHID’) in 2023. The PHE report claimed that ‘problem gambling’ was associated with £1.3bn in annual economic and social costs. In January 2023, this report was withdrawn and replaced by a new OHID report putting the costs at either £1.0bn or £1.8bn a year. The OHID replaced the PHE report because it had found a major error with the way that its costs of depression had been calculated (according to disclosures made under the Freedom of Information Act). Further, it misstated official statistics on the prevalence of problem gambling, thus inflating all costs buy more than 20%. Instead of admitting this, it claimed that it was simply following departmental standard practice to review (and then update) reports within ten months of publication - a blatantly false claim.

The replacement report by OHID was little better than its predecessor - the credibility of its cost estimates, undermined by mathematical error and speculative methodology. The PHE-OHID reports have been criticised by several experts (including a former chief economist at KPMG) and even the Gambling Commission (see A Very Public Deception – Cieo). The OHID’s response to this scrutiny has been to claim that its report “does not seek to establish a causal link between gambling” and harms – raising a question about just what purpose it believes these estimates serve. It is this dubious defence that lies at the heart of the current controversy with the OSR.

Over the course of the last four years, the PHE and OHID costs have been widely misused by those wishing to construe causal relationships between gambling and the alleged costs. The OHID – an organisation that has said it wishes to ‘tackle’ gambling in a similar way to tobacco smoking and has proposed annual tax increases, blanket marketing bans and even ‘plain packaging’ for all gambling products - has not lifted a finger to discourage this; suggesting perhaps that misrepresentation was always the plan. It is the OSR’s indifference to how its data are used that prompted the intervention of the statistics regulator.

The DHSC’s dismissal of the OSR’s concerns (and the OHID’s prior refusal to even acknowledge OSR correspondence) reveals an unprofessional disrespect for another public body. It is also disingenuous, for the following reasons:

1. The DHSC’s claim that the OHID report is sufficiently clear about its limitations (i.e. that it is explicit that it does not reveal causal relationships) is undermined by the fact that so many public figures, campaign groups and media outlets have misused the statistics to allege causality. In a parliamentary debate last week, both Labour’s Kevin McKenna MP and the Liberal Democrat Munira Wilson MP misrepresented the data. The OHID’s failure to discourage misinformation has created a significant burden in terms of casework for the nation’s statistics regulator (which is not short of other work to do). The DHSC’s indifference to its impact on another public body appears irresponsible and arrogant.

2. The OHID report itself contains several statements that indicate causality, when this is not supported by the data. It describes, for example, the “economic burden of gambling” in reference to the estimates. The OHID report itself therefore misuses its own data (which itself encourages misreporting).
3. The list of those who have misused the cost estimates includes Kevin Fenton, a senior director at OHID, who was recently appointed to the Gambling Levy Programme Board. It is difficult to contend that the report is clear about its limitations when even OHID personnel appear to misunderstand – or choose to misunderstand - what the data refer to.

4. In 2024, when the OSR originally investigated the issue, it advised the OHID to amend its report to better highlight areas of uncertainty and weak evidence. At the time, the OHID agreed with this in principle but argued that it would be politically awkward and too time-consuming. The first of these contentions was rightly rejected by the OSR. The second stretched plausibility to the level of homework-eating canines, but the OSR agreed that the OHID should be allowed to make the necessary changes when time permitted. In arguing that the report is perfectly clear about its limitations, the DHSC appears to be going back on a previous commitment.

The OHID thus considers the expenditure of half-an-hour to apply a disclaimer to its work to be excessively burdensome, even though it would cut down on the OSR’s casework (where the time taken to investigate and respond to complaints is measured in days or weeks) and is clearly necessary.

As the OSR’s letter to the DHSC last year stated, the OHID has failed to even respond to the statistics regulator’s correspondence. Sadly, this is in keeping with the OHID’s general approach. In 2024, the Director-General of the OHID, Jonathan Marron was forced to apologise for the “offensive” behaviour of OHID officials involved in the production of the economic costs report, describing their conduct as falling “below the standards expected of civil servants”. Despite this apology, the OHID ‘spots’ – including an aversion to scrutiny and an unwillingness to engage with critics – remain unchanged.

The gambling industry has an unimpressive track record when it comes to holding public bodies to account – but this is something that needs to change. As a levy commissioner, the OHID now occupies a position of considerable influence – and has its sights set on the dismantling of the licensed market in Britain. The longer operators allow the OHID and others to get away with unethical behaviour, the ruder the eventual awakening will be.

In commencing discussion of a subject as emotive and sensitive as self-harm, it is helpful to start with agreed facts or statements of the obvious. One such statement is that people with a gambling disorder are at elevated risk of self-harm. That this is true of mental health disorders in general does not diminish its significance. A second observation, which should be uncontentious (but lately is not), is that suicide is complex. Professor Rory O’Connor, who leads the Suicidal Behaviour Research Laboratory at the University of Glasgow has written: “Without question, suicide is not caused by a single factor. Rather suicide results from a perfect storm of factors and…these factors can be biological, psychological, clinical, social or cultural, and many of them may be hidden.” The relationship between disordered or excessive gambling and self-harm demands a response; but that response requires context.

In recent months, a number of figures have claimed – specifically in relation to gambling – that invocations of complexity are “cynical”. We would agree in cases where complexity is used to deflect attention away from responsibility for actions (or inaction) that contribute to self-harm; but it is not cynical to reflect on repeated research findings on the large number of inter-related risk factors associated with suicide. Attempts to reduce this complex issue to a single factor are likely to impede understanding and may in fact expose well-meaning proponents to accusations of cynical behaviour themselves. If stakeholders are able to grasp these two precepts of acknowledged risk and complexity – and suspend (at least temporarily) vexed questions of culpability – we may hope to move the discussion forwards.

The licensed gambling industry (with a few notable exceptions) has generally adopted a position of non-engagement. Demonstrably unscientific claims that it is killing 496 of its customers a year have largely been met with silence – a silence that could be mistaken for tacit acceptance. At the same time, it is not obvious that operators are doing very much about legitimate concerns, beyond putting in place procedures (including staff training) for situations of threat to life. Tolerance of wildly inaccurate claims about the prevalence of ‘gambling-related suicide’ and inaction in relation to genuine risk is a particularly disastrous combination. It is understandable why operators may not wish to spend their time talking about suicide; but the conversation therefore takes place around them.

In any case, the issue is not going away. The Gambling Commission has commenced a suicide research programme and consulted on a regulatory requirement for licensees to notify the regulator should they be made aware that a customer has died by his or her own hand. The Commission has also included questions about suicide ideation and suicide attempt in its new Gambling Survey for Great Britain (with the first iteration due to be published in February next year). The NHS Adult Psychiatric Morbidity Survey 2022 will cover similar territory when findings are published in 2024 and 2025. Gambling has been included for the first time in the National Suicide Prevention Strategy for England – suggesting action of some sort from the Department of Health and Social Care; and the Bishop of St Albans continues to push through Parliament his Coroners (Determination of Suicide) Bill. While Private Members’ Bills rarely make it onto the statute books, his efforts will ensure further discussion in Westminster. Even in the absence of such laws, it seems likely that gambling disorder may continue to feature in some inquests.

The Gambling Commission’s position may be well-intentioned but is also illogical. Its fixation with ‘gambling-related suicide’ – a term so loosely-defined as to serve little practical purpose – appears to reflect its own obsessions rather than anything resembling coherent policy. Given the complexity and heterogeneity of self-harm, it makes little sense to consider any associations with gambling disorder in isolation. The idea that one can prevent suicide by gambling policy alone is questionable (and antithetical to the principles of public health). It would be more cogent, in our view, to start with an understanding of general risk factors for suicide – including social isolation, poor sleep, depression and feelings of entrapment - and then consider the extent to which dysregulated wagering might contribute to these.

One unhelpful corollary of the Commission’s approach is that it may have inadvertently given its licensees the impression that they should only be concerned about suicide where gambling is implicated. This is both unhelpfully reductive and distinctly unambitious. An overwhelming majority of people who gamble do not develop a disorder (the past-year prevalence of DSM-IV ‘pathological gambling’ has been between 0.1% and 0.3% of the adult population, or between 0.2% and 0.5% of people who gamble); but many will experience other mental health conditions – entirely unconnected with their gambling - that may involve risk of self-harm. The NHS for example, estimates that 17% of the adult population suffers from a Common Mental Disorder. It is not simply the case that gambling businesses could do more to prevent harm; but they may have an opportunity to promote positive wellbeing, so long as this is done in earnest and not for superficial reasons.

Campaigners have been successful in raising the profile of suicide risk and should be commended for that. Having gained attention, they have an opportunity to move the conversation into a more objective and constructive orbit; but so far this has failed to happen. Instead, the issue has been used to justify a wide range of controls on consumers and operators, regardless of their relevance to self-harm. This may encourage suspicion that it is being used to secure an ideological agenda rather than to solve a specific problem. There is also the possibility that a focus on recrimination may discourage gambling operators from engaging meaningfully with what is already a difficult subject.

The manufacturing of evidence in this domain is unhelpful. It is now commonplace in Parliament and the media to assert that one ‘problem gambler’ dies by suicide every day in Britain – but such claims are patently manufactured (the Gambling Commission has described them as ‘unreliable’). The Department of Health and Social Care has admitted that Public Health England’s estimate of suicides ‘associated with problem gambling’ was incorrect (and its report has been withdrawn). There are serious problems too with figures produced by the Office for Health Improvement and Disparities. The most obvious is that they are predicated on the idea that there is no link between the presence, severity or complexity of mental health disorders and suicide risk (a ‘flat-earth’ theory in psychiatric terms). It is easy to see why, faced with a legitimate issue but lacking reliable data, there may be a temptation to make things up. On the other hand, the use of misinformation in any cause (no matter how noble) can have unintended consequences. One is that it breeds a dynamic of claim and counter-claim, with attention drawn to proving or disproving numbers rather than finding solutions to important issues. The suggestion that the prevalence of gambling-related suicide can be quantified when we don’t even have an operationalised definition of the term reveals the shallowness of the waters waded by so many allegedly independent researchers.

It is not cynical to highlight the complexity of suicide and suicide prevention; but that complexity must not be used to justify inaction. As awkward as it may seem, licensees must develop far greater curiosity about the extent to which their customers may be vulnerable to self-harm for whatever reason and the extent to which their actions can affect this for good or ill. The first step towards addressing any problem has to be an acknowledgement that it exists, followed by a willingness to discuss it. If operators are prepared to do this, they may find that organisations and researchers with expertise in this area – as well as the Gambling Commission - are prepared to engage rather than simply criticise. It may seem unpalatable, but the gambling industry needs to talk about suicide.

According to secret meeting notes from the Gambling Commission’s now defunct Advisory Board for Safer Gambling (‘ABSG’), the regulator may have been involved in lobbying HM Treasury to increase the tax burden on licensees (and consumers) as far back as 2021. Minutes from a meeting of the ABSG in March 2022, released under the Freedom of Information Act, include the following passage:

“[Gambling Commission CEO] Andrew Rhodes had noted that things have never been more favourable for a levy than now in terms of stakeholder and Government support. The blocker is the Treasury – there is little that the Commission and ABSG can do to influence that aside from pointing out the cost of gambling harm”.

The minutes go on to highlight “an opportunity around regulatory settlements” to address this ‘blocker’, which may be a reference to the regulator’s decision seven months earlier to award £140,050 in regulatory settlement funds to the National Institute for Economic and Social Research (‘NIESR’) for an assessment of the benefits and costs of gambling. This report was subsequently used to lobby for higher rates of gambling tax.

The NIESR report was eventually published in April 2023, having shifted scope from a cost-benefit analysis of gambling to a cost-benefit analysis of gambling harms (a patently absurd concept). The think tank estimated that there were £1.4bn in annual fiscal costs associated with harmful gambling in Britain (a figure it described as “conservative”). In a competitive field, the think tank’s report remains one of the worst policy papers and one of the most egregious wastes of regulatory settlement funds (which are supposed to be used to alleviate suffering) of the Gambling Act Review period. NIESR based 60% of its cost estimate on a dataset that contained no information whatsoever about ‘problem gambling’; and relied on manufactured diagnostics to produce its figures. It assumed, without any substantiation, that anyone who had won £500 from gambling over a two-year period and was out of work due to ill health was an ‘at risk gambler’ (i.e. it supposed that winning money was a greater indicator of risk than losing it); and that people who had never gambled could be classified as ‘problem gamblers’. Several of its calculations were mathematically incorrect, to boot.

The NIESR report was pointedly political, in contravention of settlement rules which stipulate that awards must not be used for lobbying or campaigning. Complaints were made to the Gambling Commission at the time of the report’s publication; but the regulator refused to act, claiming it had no resources to investigate or claw back misspent funds.

While the Gambling Commission did not call for tax increases in last year’s Budget, the episode is significant for several reasons. First, the ABSG notes (as well as earlier public statements by the Commission’s former chair, Bill Moyes) indicate that the regulator may have been involved in behind-the-scenes lobbying for a statutory levy. This would be a breach of the Regulators Code, which stipulates that regulators must not seek to impose unnecessary costs on those they regulate. Second, a question of self-interest is raised by the fact that the Gambling Commission is itself a beneficiary of the new levy (with a portion of the tax being retained by the regulator for research funding). Third, the NIESR report has been used – and misused - in support of anti-gambling activism, both in Great Britain and the USA. The Social Market Foundation misrepresented NIESR’s claims as part of its lobbying to increase taxation (for online and land-based operators) in the run-up to the 2024 and 2025 Budgets. Its error was to assume that costs correlated with problem gambling are the same as costs caused by problem gambling (as inept as NIESR’s analysis was, at least it didn’t claim this). The SMF report was co-authored by Dr James Noyes - who also chaired NIESR’s expert panel - and should therefore have known better[1].

The Office for Statistics Regulation upheld a complaint against the SMF for misrepresenting Department of Health figures as part of the think tank’s tax lobbying (see: Health Warning - Dan Waugh); but the Gambling Commission refused to act when complaints were lodged about the misuse of research that it had facilitated. Instead, the regulator decided to fund a further study by NIESR and the University of Glasgow (via an additional £402,184 settlement), which is expected to be published shortly. According to NIESR’s Dr Adrian Pabst, it will show that heightened regulation does not cause gamblers to transfer their spending to the black market - a contention increasingly at odds with channelisation data drawn from across Europe. Why the Commission considers either of the NIESR projects to be an appropriate use of quasi-public funds is anyone’s guess.

According to the regulatory expert, David S. Norman, “KYC [Know Your Customer] regulation demonstrates that existing requirements already incentivise black market migration among certain consumer segments; the taxation increases will compound this dynamic”. He describes the £26m awarded to the Gambling Commission to address this risk (itself, a dividend from the Budget) as “wholly inadequate to prevent this outcome”. It seems possible therefore that Britain’s gambling market regulator may have contributed to lobbying, the effect of which is to increase the prevalence of criminal activity in relation to gambling (in contravention of one of the three licensing objectives enshrined within the Gambling Act).

Over the last five years, Britain’s gambling market regulator has funnelled millions of pounds into anti-gambling activism, misrepresented research in public consultations, withheld evidence on the basis of convenience, published unreliable data on gambling harms, and promoted anti-gambling views (for example, the claim that people are harmed if they spend money on betting rather than going to the cinema) and anti-gambling speech codes. As we have seen in other domains, public bodies can get away with misbehaviour for quite a long time – and may even start to consider themselves untouchable. The longer this goes on however, the harder they fall in the end. As the New Year begins, the Gambling Commission would benefit from a period of honest introspection every bit as much as its licensees.

[1] Dr Noyes is a member of the Campaign for Fairer Gambling, which commissioned a report by Nera (another think tank) on remote gambling in New Jersey, in a report that also misrepresented NIESR’s claims.

More than 40 local authorities called for the reform of the ‘aim to permit’ provision within the Gambling Act (something that would have consequences far beyond the immediate objective of restricting licensing for machine arcades), and 11 have so far thrown their support behind the Coalition to End Gambling Ads. A statutory levy was introduced in April, creating a mechanism for the industry to fund its own destruction via £30m to £40m a year in annual funding for the explicitly prohibitionist Office for Health Improvement and Disparities. There was some good news for casinos (long overdue modernisation of machine allocations) and bingo clubs (the abolition from next year of bingo duty) but these were very much the silver linings in a stormy firmament.

Political risks to the gambling market have been building for some time; but the industry has been slow to react. Even now, few truly appreciate just how perilous its position has become. If things are to change for the better, gambling may need to be visited by three apparitions this Yuletide – the spirits of Gambling Past, Gambling Present and Gambling Yet to Come.

The Spirit of Gambling Past. To understand why gambling is in its current predicament, it is necessary to reflect on how it got here. Over the course of the last decade, the gambling industry at large - and particularly online operators - have gained a reputation in the popular media and in Parliament for predatory practices. In some cases, this is the result of genuinely poor standards of customer care by some operators that have been generalised across all. In part it is due to tolerance of the large-scale fabrication of statistics and research by anti-gambling campaigners. An industry that appears indifferent to false allegations that it is killing 500 of its customers a year (as well as to the reality that gambling may put some customers at greater risk of self-harm) can have little to complain about if such claims are then used as the basis of Government policy.

The Spirit of Gambling Present. Standards of customer care and operator awareness of the risks of harm from gambling are both higher today than they have been in the past. As the Gambling Commission has acknowledged, levels of regulatory compliance have improved markedly. One can still find examples of bad practice, but enforcement actions typically reveal far more minor infringements than in previous times - and sometimes these reflect genuine differences in interpretation of unhelpfully vague regulations. One would never realise this from general commentary on the state of the market, with hysteria mounting in inverse relation to cause. The industry meanwhile has fallen into the trap of defining itself in terms of safety, as if it were manufacturing Swedish station wagons in the 1980s; and justifying its existence by relation to the bogeyman of the black market, rather than taking pride in the enjoyment, socialisation and intellectual stimulation that it provides to millions of customers.

The Spirit of Gambling Yet to Come. The public health vision of gambling’s future looks something like this. In 2028, the World Health Assembly passes a resolution on gambling, modelled on the World Health Organization’s Framework Convention on Tobacco Control. This codifies the position of gaming and betting as pariah industries, preventing (among other things) any opportunities for meaningful engagement with the Government. All advertising is banned (with a carve-out for the National Lottery) and gambling duties are increased every year, using an ‘escalator’ mechanism. The Department of Health, which now has regulatory responsibility for the market, stigmatises participation through a high-profile public vilification campaign. Operators are required to display health warnings at all points of sale (on websites, on bingo tickets and on betting slips). The National Curriculum teaches schoolchildren that gambling is a health-harming activity (similar to smoking tobacco) and that gambling companies are immoral. Those who work in what is left of the industry tend to lie about what they do for a living. The Office for Health Improvement and Disparities (‘OHID’) is devising legislation for ‘plain packaging’ (which bans the use of ‘colours, logos and images on playing cards, roulette wheels and gaming machines). The minimum legal age for participation has been raised to 21 years, and this will increase by one year every year from 2030. There is a flourishing black market for gambling – but it is out of sight and out of most minds.

These are the results of what the late Peter Collins called “a combination of new moral puritanism and bureaucratic greed disguised, quite fraudulently, as a concern for ‘public health,’ buttressed by disgracefully and demonstrably bad ‘scientific research’”. By this point however, Professor Collins’s papers – and the works of anyone who disagrees with public health orthodoxy - have been banned too.

While this depiction may appear excessively gloomy or alarmist, most of the measures outlined above have been proposed by public health activists, including some within the Department of Health. In 2021, Public Health England called for gambling (all gambling and not solely harmful gambling) to be tackled in the same way as tobacco smoking. In their 2022 delphi study, OHID researchers proposed annual increases in taxation above the rate of inflation, universal bans on advertising and even ‘plain packaging’ (‘no colours, logos or images’ on any gambling products). UK Research and Innovation has announced plans to ‘blacklist’ researchers affiliated with industry and for the last year, the Gambling Commission has actively promoted speech codes. Public health’s vision for the future of gambling is bleakly dystopian – but at present, it is winning.

If the industry wishes to avoid the yawning grave prepared for it by public health, it will need to do four things: i) put the customer first always, making customer wellbeing rather than short-term profit its lodestar ; ii) participate in policy debate from a position of greater expertise and maturity, acknowledging the fact that gambling and the actions of operators can result in either positive or harmful outcomes for consumers ; iii) find the will to engage constructively, honestly and robustly in the policy debate (even where the subject matter is difficult) and to call out misinformation; and iv) reclaim the centre ground – and the moral high ground - in what has become a fractious, dishonest and polarised debate.

If Britain’s gambling companies can find a way, collectively, to do these things (while resisting the temptation to fight among themselves), the future may prove to be a rather merrier affair. God bless us, every one.

During the last week in July, the Social Market Foundation (‘SMF’) published proposals for swingeing tax increases on betting shops and online gambling websites in Great Britain. It justified these hikes (of variously 66% and 138%) by stating that social and economic costs of gambling may be as high as £7.2bn a year - upweighting figures produced by the Office for Health Improvement and Disparities (‘OHID’) in 2023. Following an investigation by the Office for Statistics Regulation, the SMF has now admitted that this claim was based on a misreading of the OHID report. Its mistake was to assume that the OHID’s estimate of costs associated with gambling harms was the same as costs caused by gambling. This, as the SMF seems to accept, is more than a semantic difference.

The significance of the SMF’s error, is made clear by the OHID’s treatment of suicide mortality, which constitutes 54% of the cost calculations (£962m a year for OHID; £4.8bn a year for the SMF). In its 2023 report, the OHID claimed that between 117 and 496 suicides in England each year are associated with harmful gambling (SMF: 585 to 2,480). These figures rely on a 2018 study by researchers at Lund University, who found that hospital patients in Sweden with a gambling disorder diagnosis were, on average, 15.1 times as likely to die by suicide as the general population. OHID incorrectly assumed that ‘problem gamblers’ (a sub-clinical classification and not the same as gambling disorder) in England are at similar risk; and ignored warnings from the Lund researchers about the generalisability of the findings. In subsequent analyses (Karlsson et al., 2025), the Swedish researchers revealed that gambling disorder was not in fact, a statistically significant risk factor for suicide, once comorbid health problems and economic status had been controlled for (see A Very Public Deception – Cieo for a more detailed examination of the myriad problems with the OHID report).

In response to the more nuanced findings from the team at Lund, the OHID has claimed, unconvincingly, that it never intended to suggest a causal relationship between gambling and suicide. This raises a question about what exactly the OHID’s mortality figures (and the wider cost estimates) do show. It is clear from the Swedish research that they can tell us nothing meaningful about the harmfulness of gambling - or indeed very much about anything. While the elision of correlation and causation is clearly tempting for those with an a priori indisposition towards gambling, it leads to difficulties, as findings from the Gambling Survey for Great Britain (‘GSGB’) illustrate.

The GSGB collects data in relation to a wide range of socio-demographic characteristics and lifestyle choices. One previously unpublished finding from the survey is that people who visit museums and art galleries are more likely to experience suicidal thoughts (13.5%) compared to people who do not (11.1%); and almost twice as likely to report a past-year suicide attempt (1.34% for museum-goers compared to 0.75% for others). According to the GSGB, visiting art galleries is more strongly associated with self-harm than gambling is. Those unwise enough to follow the OHID methodology, might therefore conclude that around 62,000 suicide attempts in Britain each year are associated with visits to museums and galleries – or claim that there is a cost to society of £1.2bn a year arising from ‘museum-related suicides’. Such figures would, however, be about as meaningful as observations about the sale of ice-cream and death by drowning.

Other, less trivial examples highlight the same issue. GSGB data reveal elevated risks of suicidal thoughts and attempts for some non-white ethnic groups as well as for non-heterosexual people. These data ought to be a cause for concern and investigation (indeed, there is a rich research literature on similar findings) but it would be morally repugnant to use them to claim an economic burden on society associated with ethnicity or sexual orientation.

Some have attempted to argue that because we know that excessive or disordered gambling can be a contributory factor to self-harm, it is acceptable to produce spurious statistics. In 2022, the chair of the Gambling Commission’s Advisory Board for Safer Gambling advised OHID that criticism of its cost figures was valid – but then intimated that accuracy in such matters was beside the point and that scrutiny of public health mortality claims was “a distraction from what matters to people and families harmed by gambling”.

The SMF upweighted the OHID figures by a factor of five to reflect the fact that the GSGB (which has itself been beset by controversy) provides substantially higher estimates of ‘problem gambling’ than seen in NHS surveys. The SMF therefore assumes that around 2,500 suicides in England each year (or about 50% of all such deaths) are caused entirely and exclusively by ‘problem gambling’, with no other contributory factors; but this flatly contradicted by the Swedish research that these calculations rely upon. If the Swedish data provide a reliable guide to gambling harms in England, then the SMF and OHID estimates cannot hold; if they do not, then the estimates crumble into dust.

That gambling gives rise to social and economic costs is not in dispute - nor is that fact that excessive gambling may contribute to self-harm (something that deserves more intelligent and serious discussion than it is usually afforded). Gambling also confers benefits on consumers, including sociability, entertainment and mental stimulation. Binde (2013) likened the process of betting on horseraces (including study of the form and bet selection) to the task of completing a crossword puzzle; and several studies have indicated that playing bingo may reduce risk of dementia. Data from the GSGB, the NHS Health Surveys and the NHS Adult Psychiatric Morbidity Survey reveal that non-problem gamblers have on average, better mental health than non-gamblers and are at lower risk of suicidal behaviour. It would be speculative to assume a causal relationship here (or to assign a positive economic and social value on this basis) – but no more so than is the case with the SMF’s and OHID’s treatment of costs.

The SMF deserves credit for acknowledging its error – although its report has not yet been corrected and it remains to be seen whether a change in the ‘facts’ leads to a softening in its tax proposals. The real question raised by the episode is why the OHID – at considerable public expense – bothered to produce cost estimates that have no obvious meaning. Perhaps in recognition of this, the Office for Statistics Regulation has asked the OHID to make clearer the limitations of its calculations and to act where figures are misused. The extent to which the OHID does so may be an indication of its fitness to serve as the new commissioner of gambling harm prevention.

Note: chart cannot be used to indicate overall trends due to issues of non-comparability between some surveys. Instead, it shows the rates of PGSI 'problem gambling reported in a variety of official statistic surveys.

The release of the APMS further emphasises issues of reliability with the GSGB, which remains an outlier when compared to all other official statistics on the prevalence of harmful gambling stretching back almost two decades (and encompassing the NHS Health Survey for England, the Scottish Health Survey the APMS, the British Gambling Prevalence Survey, the Wales Omnibus Survey and the Gambling Commission’s own Quarterly Telephone Survey). In the 11 months since the publication of the GSGB 2023, the Commission has responded to this inconsistency by variously, pretending that these other statistics don’t exist, attempting to undermine confidence in the NHS as a producer of statistics and publicly mocking those who have continued to use health statistics (a group which, rather inconveniently, includes its Government sponsor, the Department for Culture, Media and Sport). In May, the Office for Statistics Regulation (‘OSR’) warned the Commission against such tactics, urging it instead to explain issues of coherence with other statistics and to take more seriously legitimate concerns about the GSGB’s accuracy.

The APMS 2023/24 reinforces findings from previous surveys that people with ‘problem gambling’ are more likely to suffer from other mental health conditions (and that they are also more likely to receive counselling or medication for these issues); and it reveals elevated rates of problematic debt among PGSI ‘moderate risk gamblers’ and ‘problem gamblers’. While not exactly novel, these findings underscore the seriousness of harms that afflict some gambling consumers. At the same time, the survey reveals that non-problem gamblers (i.e. the vast majority of those who participate in any gambling) are, on average, less likely to suffer from a common mental health condition (depression, generalised anxiety disorder, panic disorder, phobias, obsessive compulsive disorder) or problematic debt, compared to the general population. This is consistent with results from NHS Health Surveys (which even Public Health England acknowledged in 2021) that have consistently shown that recreational gamblers enjoy, on average, better mental health and wellbeing than those who abstain entirely. It is generally foolish to mistake correlation for causation – but it is no less valid to calculate benefits from these data as it is to infer costs.

The Gambling Commission is shortly expected to respond to the OSR’s review of the GSGB, including details of how it intends to address the statistics regulator’s recommendations. Meanwhile, Professor Patrick Sturgis of the London School of Economics is scheduled to report back this month on results from a battery of tests of the GSGB’s reliability (although, given methodological limitations, it seems unlikely that this will be conclusive). In October, the Commission will publish results from the GSGB 2024; and this will be followed (either late in 2025 or early in 2026) by the release of results from the Health Survey for England 2024 (‘HSE’). There will, therefore, be three official estimates of the prevalence of ‘problem gambling’ in England – with the HSE figure expected to be closer to the APMS than to the GSGB. While there is merit in using all three sources of data to better understand gambling participation and its consequences, the reality is that many stakeholders – including the Gambling Commission on current form - select statistics on the basis of convenience rather than quality.

It is unclear when the next APMS will be conducted (the previous two editions were carried out in 2007 and 2014). NHS England has announced that it is “not prioritising population health surveys” and that the HSE 2025 (which is unlikely to contain gambling questions) will be the last in the series. Professor Sturgis has recommended the periodic use of traditional in-person surveys on gambling; and there is a strong argument for using levy funds to provide this – but the Gambling Commission has shown little appetite for this. Over time, the GSGB may therefore become the sole source of official statistics by default - which may be what the Gambling Commission is banking on. For a little while longer, however, the question of how many people in Britain are likely to suffer ‘problem gambling’ remains a matter of multiple choice.

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