Dan Waugh of Regulus Partners published an account on 2 October of his correspondence with the Gambling Commission about its Young People and Gambling Survey (YPGS). The article can be found here.
Among other things, despite standing by the robustness of their survey, when pressed on how 12-year-olds could report playing roulette and blackjack in casinos, the Commission suggested that they may have been thinking of ‘visiting’ a virtual casino in a computer game such as Grand Theft Auto. I recommend the piece; it is definitely the funniest thing a regulator has said this year without meaning to.
The survey is Waugh’s territory and he covers it better than I could. What interests me is how an organisation arrives at the point where that defence looks like the best available, no matter how ridiculous. My answer is that the Commission has been captured, though not by the people you might expect.
Regulatory capture is usually what happens when a regulator ends up serving the industry it is supposed to police. George Stigler, an American economist, set out the theory in 1971 and his point was that organised groups with a concentrated interest will spend time and money shaping regulation, while a diffuse public with little at stake will not.
The best-known route is the revolving door. The industry knows more than the regulator, has more at stake, and employs the people who understand the rules, so the regulator hires them. A few years later, they may return to the industry on better pay and the prospect of that job can soften how hard they push in the meantime. Surprisingly to my mind, Andrew Rhodes, former chief executive of the Gambling Commission, joined Hawkbridge, a new firm providing strategic advice to the gambling industry. Given the history, I would not be surprised if leavers from the Gambling Commission joined the anti-gambling lobby.
The US Federal Aviation Administration let Boeing certify much of its own aircraft and the 737 MAX was one result. American financial regulators have taken on so many people from Wall Street that smoke is coming out of the pivot point of the revolving door. Britain’s light-touch approach to the banks before 2008 rested on a similar cosiness. In each case, the regulator ended up seeing the industry as the industry saw itself.
That logic applies to any group with a concentrated interest and plenty of time, and nothing in it says the group has to be the regulated industry. A small, motivated, well-organised lobby that attends every consultation will beat a diffuse majority that has better things to do. Gambling customers number in the millions and do not, on the whole, form committees. The public-health lobby certainly does.
Let’s start with the money. The statutory levy took effect in April 2025 and according to figures from the Department for Culture, Media and Sport has raised about £120 million. Half goes to treatment, 30 per cent to prevention, and 20 per cent to research, which is somewhere around £24 million per annum. UK Research and Innovation (UKRI), the government’s research-funding body, receives most of the research share and the Commission holds a smaller amount to commission work itself.
The Commission also publishes ‘evidence roadmaps’ that list the research questions it considers important. The regulator therefore chooses which questions are worth asking and a large pot of money follows those who ask them. That is a very tidy arrangement and tidiness in a regulatory system should always send one looking for the loose bits.
In practice, researchers who have accepted gambling-industry money are treated as tainted and the taint persists when the money arrives through an intermediary such as GambleAware, the charity that commissioned research funded by voluntary operator donations. Money that arrives through UKRI or the Commission is apparently squeaky clean, although it comes from the same operators; the levy is simply compulsory. This is the first occasion I can think of whereby a tax has improved the moral character of the people paying it.
Some academics want the taint made formal. An article in Times Higher Education reported calls for anyone previously funded by industry-linked bodies to be barred from UKRI money for at least three years, as with tobacco; Rebecca Cassidy of Goldsmiths suggested five. John McAlaney of Bournemouth University replied that this would stop nearly all established gambling researchers from working, which would leave a field with very few researchers and a great deal of agreement.
In fairness, UKRI says industry engagement is not mandated, that every application faces independent peer review, and that it has processes to manage conflicts of interest. I accept that is the intention, but the reality …?
Will Prochaska of the Coalition to End Gambling Ads said the early research themes and conflict-of-interest policy ‘could have been written by the gambling industry’. When the lobby’s response to a call that stops short of excluding the industry is that the industry must have drafted it, it is fair to ask what distance from the industry would count as sufficient.
The attitude shows in smaller ways too. I am told that one of the leading researchers in the field declined to attend a recent European academic gambling conference in Copenhagen, because representatives of the industry would be there. I am not sure what the fear is. Perhaps their methods would be infected by proximity to someone who runs a casino. A researcher whose findings cannot survive being in the same room as an operator has told us something about the slant of their findings.
Consider the incentives. Some £24 million per year is on offer. The qualification is an absence of contact with the people who run the businesses under study and the questions are set by the regulator. A researcher who finds that most customers gamble without harm, or that gambling advertising has no impact on children’s gambling activities, or that a restriction has pushed players to unlicensed sites will not have found what the funder was hoping for. Nobody needs to be dishonest for this to work. Selection does the job, in the way that a recruitment panel that only interviews tall people will conclude that tall people make excellent employees.
Which brings me back to the survey. The ‘prompted-to-gamble’ question asks children whether adverts or promotion have ever prompted them to spend money on gambling when they were not otherwise planning to. The Commission now describes this as a measure of feeling prompted, rather than of spending real money gambling. Waugh points out that the statistic has been used for years as evidence that advertising makes children gamble.
In 2019, Professor Heather Wardle and colleagues told the House of Lords inquiry that approximately 200,000 children aged 11 to 16 had gambled as a result of advertising, marketing, or sponsorship exposure. In 2025, Dr Matt Gaskell, who leads the NHS Northern Gambling Service, told the Lords Liaison Committee that 7 per cent of children who reported seeing gambling adverts said it led to unplanned gambling spend. The Commission itself cited the survey when advising the government in 2023.
Waugh asks whether, on the Commission’s logic, those witnesses misled Parliament and leaves it there. The question asks about money spent, so the Commission’s new interpretation of it as a matter of feelings is clearly wrong. The trouble lies with the answers. Children cannot lawfully gamble in a casino and it is absurd to think that they could, yet the same survey has 12-year-olds reporting just that, gambling in a casino, and some children reporting having done every one of the 17 listed activities in a single week!
Professor Wardle and Dr Gaskell are seasoned researchers and they will have known that a figure built on answers like these is fragile. The Commission never corrected them and laughably now says that the results are descriptive and do not show that advertising causes children to gamble. But that cat is out of the bag: The spurious figure has been put to Parliament as robust and showing exactly that. And it will doubtless be quoted by many an MP and journalist from here on in.
There is a further wrinkle. Waugh reports that in June 2026, the Commission described the survey to the Liaison Committee as ‘robust’ and has since conceded that the concerns about reliability rest on sound analysis. However, the Committee went on to recommend a complete ban on gambling advertising. An independent methodological review of the survey is planned for spring 2027, which seems a long wait for a committee that has already reported. By then, advertising causes children to gamble will be a fact rather than a fiction.
The model in the minds of those who built the current system is tobacco, where industry funding was used to manufacture doubt and where the WHO Framework Convention now requires governments to limit their dealings with the industry. The model has a serious flaw. Tobacco harms when used as directed, whereas the great majority of people who gamble do so without harm (and many enjoy it), which is why gambling is licensed rather than prohibited (at the moment!). A policy built around a product with no safe use will overshoot when applied to one that has plenty.
What the field needs is a room. Researchers, clinicians, psychotherapists, regulators, and operators should sit down with the data and argue about it. The operators want a safer customer base; a customer who loses their house or job is not something the licensed industry wants and the licensed industry has a commercial interest in treating people well. I am sure that if people are rational and honest, they will be surprised at how much common ground they can find.
A declaration of interest: I work with companies in the gambling industry, which on current form would count against me for any levy-funded research. I shall bear it with fortitude. The independent review of the YPGS is due in spring 2027 and it will be interesting to see who was asked to carry it out, who has paid them before, and what they were paid for.
