GambleAware has published its letter of 31 March 2021 to the Secretary of State for Digital, Culture, Media, and Sport, constituting the submission of the trustees of GambleAware in response to the UK Government’s Call for Evidence in relation to its Review of the Gambling Act 2005 (on which we have previously reported here).

Its core submission is the need for a mandatory levy to fund research, education and treatment related to gambling and gambling-related harm. Under the heading “Advocating for a mandatory levy”, GambleAware states:

Under the current arrangements in place for the regulation of the gambling industry, GambleAware is funded exclusively by the gambling industry via a voluntary donation system.

The system requires operators licensed in Britain to donate funds to support research, prevention, and treatment of gambling harms. However, there is no stipulation as to how much ought to be donated and on 1 January 2020 the Gambling Commission published a list of several organisations to which operators may direct their annual financial contributions.

In the twelve months to 31 March 2020, GambleAware received £15.6 million in voluntary donations as compared to £11 million in the previous year. In June 2020, the Betting and Gaming Council, on behalf of the four largest gambling operators in Great Britain, pledged £100 million to GambleAware over the four years to 2024.

The voluntary nature of the current arrangements results inevitably in uncertainty of funding year to year and to significant variations in cash flow within the year. This unpredictable funding model represents a significant challenge given that a key function of GambleAware as a commissioning body is to provide assurance to funded services about recurrent income streams so that expert clinical teams can be established and sustained to provide treatment and support for those who need help.

Trustees have established a robust, independent, and accountable system of governance processes and procedures to ensure the gambling industry has no influence over the charity’s commissioning decisions. However, the voluntary nature of the current funding arrangements permits the industry to make deliberate choices about where its funding is directed, which may not always be in the best interests of pursuing a coherent and coordinated whole systems approach to preventing gambling harms. It is for these reasons that GambleAware continues to advocate for a mandatory levy to fund research, prevention, and treatment services.

Trustees note that under the current legislation the Secretary of State “may make regulations requiring holders of operating licences to pay an annual levy to the (Gambling) Commission” and that the Gambling Commission “shall, with the consent of the Treasury and of the Secretary of State, expend money received by way of levy for purposes related to, or by providing financial assistance for projects related to (a)addiction to gambling, (b)other forms of harm or exploitation associated with gambling, or (c)any of the licensing objectives”.

The question this raises is whether the Gambling Commission, as a business regulator, is best placed to commission the range of prevention and treatment services that are necessary to keep people safe from gambling harms.

You can download the complete submission below.