Gambling Advertising

Lord Foster of Bath Excerpts

Thursday 25th April 2024 Lords Chamber

Asked by

[Lord Foster of Bath]

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 posed by the exposure of children to gambling advertising.

[Lord Foster of Bath (LD)]

My Lords, I thank all noble Lords, including the Minister, who are taking part in this debate. I declare my interest as chairman of Peers for Gambling Reform, which was set up to press for the implementation of the recommendations made by the Lords committee on gambling. I am delighted that very many of those recommendations, either in whole or in part, were included in the Government’s White Paper. However, except for the Gambling Commission taking a closer look at bonus offers such as free bets and spins, and the Premier League’s voluntary ban on front-of-shirt gambling logos, the White Paper proposes very little action in respect of gambling advertising.

The Gambling Act 2005 liberalised gambling advertising, and now on Twitter/X alone there are 1 million UK gambling ads a year. Gambling companies’ annual spend on marketing now exceeds £1.5 billion. As the Lords committee noted, companies would not spend so much if it did not work, leading to more gambling and greater risk of harm. Yet very little action is proposed. Surely any Government should have been worried to read just this weekend in the Observer, under the headline “UK children bombarded by gambling ads and images online”:

“Young people feel their internet activity is overwhelmed by betting promotions and similar content”.


If the Government are not worried, other people certainly are. Opinion polls show that the vast majority of the public want a clamp-down on gambling advertising, including Conservative supporters. A very recent opinion poll found that 77% of Conservative councillors agree that tighter restrictions on gambling advertising would reduce gambling-related harm. With the Government doing very little, others are taking action. In March, Sheffield City Council joined over 80 other English councils in restricting gambling advertising on land, buildings, vehicles and even bus stops, websites and newspapers they own. The Mayor of London says that he intends to end gambling ads across public transport in the city. I hope he gets on with it quickly, as one gambling operator is currently advertising that TfL tube and train carriages are now casinos, with bus-stop ads saying: “Your bus is now a casino”. In sport, the absence of government action has led 35 football clubs to decide to go it alone and join the Big Step’s campaign to end gambling advertising in football. Can the Minister explain why the Government are so out of step with all these voices and seemingly so in step with the gambling industry?

I suspect public concern is about to rise because, in July, the Gambling Commission will release new figures about gambling harm. The Gambling Minister in the other place has already indicated that they are likely to show that 1.3 million people will classify as “problem gamblers” and that a further 6 million are at risk. If confirmed, these figures are far higher than those used to inform the Government’s work on their White Paper. This is a real cause for concern, further strengthening the call for action.

If public opinion does not persuade the Government, there are many other justifications for action, including research evidence. When he responds, I suspect the Minister may be somewhat dismissive of the research and claim—as the White Paper does—that it does not show a causal link between advertising and gambling harm. I am prepared to accept that this is largely true, but it does not mean that the research evidence does not support the case for greater action. Academics are clear that, in social science research, causal links are rarely even possible, but they are equally clear that the research findings justify a much tougher stance against gambling advertising. Some 50 academics recently called for “badly needed” restrictions on the promotion of gambling products. They drew attention especially to the unprecedented numbers of young people being exposed to gambling ads via the internet and television, and concluded that

“it has become quite clear that the gambling products being offered and the ways in which they are promoted are harmful to individual and family health and damaging to national life”.

Reviewing the evidence, the Advertising Standards Authority accepted that some studies were robust enough to support a link between advertising and gambling behaviour. The Government’s White Paper itself points to research showing that gambling advertising and marketing leads to people starting to gamble, to gamble more and to recommence gambling. With all this evidence, it is bizarre that the Government are not taking more action.

Unlike us, other countries do not seem to struggle with the evidence, despite having far less of it. Ipsos and researcher Dr Rossi have identified 496 published research papers about gambling marketing here, which is more than the combined number of similar ones in Belgium, the Netherlands, Italy, and Spain. Yet on their evidence they have chosen almost full bans on gambling advertising and sponsorship. Can the Minister explain why the UK Government’s assessment of our evidence is so different from neighbouring countries with similar research findings? Does the Minister really believe that there would be 1.3 million people classified as problem gamblers in the absence of gambling advertising?

Frankly, our Government seem confused. In one breath, they say that action is not justified because there is little causal evidence linking advertising to harm but, in another, without causal evidence, they welcome the removal of gambling logos on the front of football shirts as a harm-reduction policy. The Government’s position simply does not make sense.

The Government have accepted that gambling-related harm should be treated as a public health issue, so they should be adopting the precautionary principle and, on the huge weight of evidence, taking greater action. Yet, the Minister in the Commons said, on advertising causing harm, that,

“if new evidence suggests that we need to go further, we will look at this again”.—[Official Report, Commons, 13/3/24; col. 142WH.]

Can the Minister explain what more the Government need before they will act?

I believe that a public health approach to gambling should lead to significant curbs on advertising and a ban on direct marketing, an end to inducements such as so-called free bets, and the removal of gambling sponsorship in sport.

Time does not permit me to detail all that I think should be done. Noting that estimates suggest that as many as 60,000 children suffer gambling harm, I will end with just one area where I believe urgent action is needed: so-called content marketing, which a Guardian headline recently described as “‘Sneaky’ social media ads … luring young into gambling”. Just one example will suffice. A social media post with the heading, “When the barman asks if you want another one”, is followed by a photo of Liverpool manager Jürgen Klopp giving a thumbs-up. That is all there is to it.

This simple, humorous post was by Paddy Power, but there are literally hundreds of them, using cartoons and famous people, posted online by gambling companies all the time. In just one weekend, online gambling ads received 34 million views. Over half were content marketing. Research shows that such posts are particularly appealing to young people and that followers of gambling companies’ online posts are, disproportionately, young people.

Yet the voluntary code governing advertising says that advertisements should be clearly seen as such. I have met with the ASA, which oversees the code, and shown it numerous examples of content marketing that clearly breach the code. So I hope the Minister will agree that the time has come for a complete review of the code and its enforcement, including deciding whether self-regulation really is the right approach.

It is worrying that so many young people know the names of gambling companies, follow them online, think that gambling is part of growing up and see it as part of the enjoyment of sport. Gambling advertising encourages more people to gamble and to develop gambling harms. The figures are alarming, as are the consequences to individuals and our society. The threat to our children should be enough on its own to compel the Government to act. No primary legislation is required, as the Gambling Act 2005 gives the Secretary of State all the powers she needs to regulate gambling advertising as she sees fit. So my simple question is: will the Government get on and do something?

--- Later in debate ---

[Lord Parkinson of Whitley Bay (Con)]

I am grateful to the noble Baroness, and I hope what I have said is none the less helpful in relation to the points she raised in her speech, which I welcome.

We recognise that there is good evidence to show that gambling advertising can have a disproportionate impact on those who are already experiencing problems with their gambling, and that some aggressive marketing practices are particularly associated with harm. The noble Lord, Lord Trevethin and Oaksey, mentioned a study which reflects that.

Evidence from the Gambling Commission shows that 35% of problem gamblers received incentives of offers to gamble daily, compared with 4% of non-problem gamblers. Furthermore, while 10% of gamblers with a “non-problem” or “low-risk” score—according to the problem gambling severity index—were influenced to gamble more by direct marketing, this rose to 41% among those with a “moderate risk” or “problem gambler” score.

We also recognise that content often used in gambling advertising can inappropriately appeal to children and young people—the right reverend Prelate the Bishop of Derby raised such an instance. That is why we have introduced a suite of measures to further prevent potentially harmful impacts of advertising, specifically for children. Since October 2022, advertising rules have been strengthened to prohibit content that downplays the risk or overstates the skill involved in betting. The rules also ban content that is likely to be of strong appeal to children. In that regard, I will raise with officials the frog-based example that the right reverend Prelate gave. As a result of this ban, top-flight footballers or celebrities popular with children are banned from being in gambling adverts. In line with existing gambling advertising rules, the Premier League’s decision to ban front-of-shirt sponsorship by gambling firms will commence by the end of the 2025-26 season, breaking the direct association between gambling brands and popular players.

The noble Lord, Lord Trevethin and Oaksey, suggested that there should be warnings to potential players on gambling adverts. Robust Advertising Standards Authority rules prevent content and adverts that, for instance, promote gambling as a route to financial success, and adverts on television must direct people to available support services. We are also working with the Department of Health and Social Care and the Gambling Commission to develop independent information campaigns about the risks of gambling—taking that out of the hands of the industry.

[Lord Foster of Bath (LD)]

I apologise for interrupting the Minister, but I find it difficult that he stands at the Dispatch Box and talks about all these rules, when I gave a specific example of a Paddy Power advertisement—although it is not called an advertisement—that simply had a large photograph of the Liverpool manager, Jürgen Klopp. Does he believe that was a correct thing for Paddy Power to do, or should it have been banned?

[Lord Parkinson of Whitley Bay (Con)]

Well, as with the case that the right reverend Prelate raised, I will take that up with officials. I was spelling out some of the actions—some of which are still to come in. As I said, the Premier League rules will come in by the end of the forthcoming season. I am sure the noble Lord will reflect that some of the work has been done and some is coming shortly, but I will raise the case he mentions with the team at the department.

As we set out in our White Paper, we are also working closely with the Gambling Commission to take targeted action on advertising to ban harmful practices and ensure that it remains socially responsible, wherever it appears. The commission has recently consulted on new rules to give consumers more control over the direct gambling marketing that they wish to receive, and on strengthened protections to ensure that free bets and bonuses are constructed in a way that does not encourage excessive or harmful gambling. The commission will set out its responses to these consultations soon. Together, these measures will empower customers and prohibit harmful marketing practices, to prevent the risk of gambling harms.

The noble Baroness, Lady Bennett of Manor Castle, referred to the powers available to local authorities. As she reflected, these vary from local authority to local authority, but, as we heard in the debate, the metro mayors in London and Manchester are using the powers that are available to them.

There is no single intervention that provides the answer to effectively preventing gambling-related harm. That is why we have taken a holistic approach that includes action on products and protections for players. We recently announced the introduction of stake limits for online slot games, where we have seen evidence of elevated levels of harmful gambling, and are pursuing broader protections, such as financial risk checks that will require online operators to identify and take action in relation to customers who are financially vulnerable. That will prevent runaway losses, which we are still seeing happen too often. The Government are clear that effective and innovative collaboration to get the right mixture of interventions for the population as a whole—as well as those with specific needs or vulnerabilities—is required to tackle gambling harm.

A key part of that approach is the Government’s decision to introduce a statutory levy, which I know has been a long-standing priority for the noble Lord, Lord Foster, and which the noble Lord, Lord Bassam, and others raised. In his opening remarks, the noble Lord, Lord Foster, dwelt on the importance of evidence. Perhaps I should end my remarks by acknowledging that further work is needed to build the evidence base to ensure that policy and regulation are able to deal with emerging issues.

In response to the contribution from the noble Lord, Lord Bassam, I make clear that developing quality evidence is a priority for our statutory levy. Through the levy, increased and ring-fenced funding will be directed towards high-quality, independent research into gambling and gambling-related harms, including in relation to advertising. We will continue to monitor the evidence base and, if new evidence suggests that we need to go further, we will look at this again. The Government will also respond to their bespoke consultation on the levy and will set out their final decisions very soon.

I thank the noble Lord, Lord Foster of Bath, for tabling today’s debate and all those who have spoken in it. I am certain that we will return to this topic again before long.