The House of Lords Liaison Committee has called on the Government to introduce a comprehensive ban on gambling advertising in Great Britain as part of a public health approach to reducing gambling-related harm.
Its new report, Gambling Harm – Time for Action, follows up the July 2020 report of the House of Lords Gambling Industry Committee and concludes that a comprehensive advertising ban represents the “most effective policy option” available to the Government. The Committee recommends that such a ban be introduced “as soon as practicable”.
The Committee estimates that between 1.0 million and 1.5 million adults in Great Britain have a Problem Gambling Severity Index score of eight or more, indicating problem gambling. It says associated harms can include relationship breakdown, reduced spending on everyday items, borrowing or using savings to fund gambling and, in the most severe cases, mental ill health and suicide.
The report acknowledges significant disagreement between academics, civil society groups and gambling industry representatives over the scale of problem gambling, the relationship between advertising and harm and the potential consequences of further restrictions. It nevertheless concludes that gambling harm remains a major public health issue.
The Committee argues that Great Britain has developed a stronger evidence base on the relationship between gambling advertising and harm while other jurisdictions have moved further in restricting advertising.
It also challenges concerns that tighter restrictions on licensed operators would push players towards the illegal market, saying it had not received strong evidence that advertising restrictions would result in such displacement. It calls instead for restrictions on the licensed market to be accompanied by stronger action against unlicensed operators.
If the Government does not pursue a comprehensive ban, the Committee proposes a series of targeted measures covering advertising regulation, sports sponsorship, inducements, direct marketing, affiliates and social media.
Among the most significant recommendations is a ban on gambling advertising on sports shirts and other kit, including training kits, as well as advertising in or near sports grounds and venues. The Committee says voluntary measures have failed to reduce overall exposure to gambling advertising in sport and raises concerns that sponsorship is moving into alternative formats as restrictions tighten.
The report maintains the previous Committee’s proposed exemption for on-course advertising at horseracing and greyhound racing, while recommending that the Government consider separately whether other forms of off-course advertising connected with the two sports should be restricted.
Further recommendations include consideration of a broadcast advertising watershed, accompanied by restrictions on online advertising to prevent advertising simply shifting between channels.
The Committee also calls for a comprehensive ban on gambling inducements and recommends that the CAP Code prohibit the use of the term “free bet” and related formulations. It argues that the regulatory framework should distinguish more clearly between products according to risk, with stronger advertising restrictions applied to higher-risk products such as high-speed continuous-play online gaming.
Direct marketing receives particular attention. The Committee says there is strong evidence of a relationship between direct marketing and gambling harm and recommends a comprehensive ban on direct marketing by gambling operators and third-party affiliates. Operators would remain able to send essential account information, non-promotional safer gambling messages and interventions triggered by indicators of harm.
The report also recommends a comprehensive ban on content marketing by gambling operators, including content posted through their own social media accounts, arguing that the boundary between advertising and editorial-style content has become increasingly blurred.
Affiliate marketing is also targeted. The Committee revisits the 2020 recommendation that affiliates should be licensed directly by the Gambling Commission before entering contracts with operators. It additionally recommends that the Government consider prohibiting paid promotion of licensed gambling operators by influencers and content creators.
On social media, the report proposes that gambling advertising should not be served to under-25s and recommends changing advertising rules so that the “strong appeal” test currently protecting under-18s is extended to under-25s. It also proposes prohibiting gambling advertising alongside youth-oriented online content and considering an explicit opt-in system for users who wish to receive paid-for gambling advertising.
The Committee further calls for urgent clarification to ensure gambling advertising cannot appear in video games carrying a PEGI rating below 18 and questions whether current operator-led safer gambling messaging is effective in reducing harm.
Lord Ponsonby of Shulbrede, Senior Deputy Speaker and Chair of the House of Lords Liaison Committee, said six years had passed since the Gambling Industry Committee published its original report and that developments in gambling advertising since 2020 demanded a reassessment of the policy options.
Lord Foster of Bath, a member of the former committee and acting former Chair, said: “A ban on most gambling advertising would reduce gambling and therefore reduce problem gambling and the serious harm it causes. We are clear that this would shrink, rather than grow, the gambling sector.”
The Committee argues that any reduction in the size of the gambling sector should be considered alongside potential wider economic benefits. It recommends transition arrangements to allow affected sectors to adapt, while maintaining that reducing gambling participation and harm could contribute to tackling regional inequalities and support wider economic growth.
The report also recommends that, in the absence of an immediate comprehensive ban, gambling advertising regulation should be placed on a statutory footing and overseen by the Gambling Commission rather than continuing under the current partially self-regulatory model.