The London Assembly Health Committee is calling on the Mayor of London to bring forward proposals to ban all gambling advertisements on the Transport for London (TfL) network, and to provide advertising space to raise awareness of gambling harms, amid concerns that London’s rate of ‘problem gambling’ is almost twice the average seen across Britain. The Mayor’s 2021 manifesto committed to “instruct TfL to bring forward plans to extend the ban to harmful gambling advertisements on the network”. Such a ban has not yet been introduced.
As part of a two-part meeting investigation, including people with lived experience of gambling harms, key public health figures and charities, the Committee heard a range of evidence demonstrating an association between exposure to gambling advertising and gambling participation – particularly for young people and people who have already experienced problems with gambling. The report “Gambling Related Harms In London” is published today.
During the investigation, Mayoral representatives highlighted limitations in the evidence base linking gambling advertising with gambling harm, as well as the lack of a definition of ‘harmful gambling’ advertisements. However, Committee Members also heard that it is not possible to distinguish between ‘harmful’ gambling advertisements and ‘non-harmful’ gambling advertisements. The Committee is therefore calling for the Mayor to bring forward a blanket ban of all gambling advertising across the TfL network.
The Committee is particularly concerned to hear that there is a higher-than-average prevalence of “affected others” in the capital – those who are negatively impacted by someone’s gambling, such as the gambler’s children, family members or friends. It is recommended that public health messaging around gambling harms should be piloted by the Mayor, including the provision of advertising space on the TfL network.
Key findings
In 2017, GambleAware estimated that UK gambling companies spent £1.5 billion on advertising and marketing per year, a figure which had increased substantially on previous years. A poll conducted by YouGov for the Royal Society for Public Health in 2021 found that 63 per cent of adults are in favour of a total ban on adverts for gambling products.
Research commissioned by the Office for Health Improvement and Disparities (OHID) in 2022 and first published in December 2023 looked at the number of adults who might benefit from gambling treatment and support. It found that, in London, 3,835 adults per 100,000 might benefit from gambling treatment and support, which was the highest rate in England.
GambleAware’s analysis of the Annual GB Treatment & Support Survey found that London has a higher-than-average prevalence of affected others compared to the GB average (7.6 per cent compared with 6.9 per cent). The analysis also suggests that London has the highest rate of ‘problem gambling’ of all regions in GB, despite having a lower prevalence of gambling overall. London’s rate of ‘problem gambling’ was found to be almost twice the GB average (5.6 per cent compared to 2.9 per cent).
Gambling advertising can have adverse impacts on those already experiencing, or recovering from, gambling-related harms. One Londoner with lived experience of gambling harms as an affected other and who gave evidence to the Committee’s second meeting, described advertising for gambling products as “really triggering”.
In 2022, the Mayor commissioned researchers from the University of Sheffield and the University of Glasgow to summarise the evidence base on the health impacts of gambling advertising which concluded that “Gambling advertising restrictions could reduce overall harm and mitigate the impact of advertising on gambling-related inequalities. Public health harm prevention strategies should include policies which limit exposure to advertising, particularly among children and vulnerable groups.”[7]
There are challenges in developing a definition of what constitutes a ‘harmful gambling’ product, as opposed to a gambling product that does not generate harm. Marguerite Regan, Head of Gambling at OHID, explained that “harmful gambling is a term that we use for anyone who is gambling at levels that have a negative impact,” and that people experiencing gambling harms are likely to be gambling on two or more activities, rather than engaging in a single form of gambling that could be classed as ‘harmful gambling’. She told the Committee that it is not as simple as saying “one is bad and one is less bad… because they can be used together, and they can affect each other”.
The House of Commons Culture, Media and Sport Committee, which carried out an inquiry into gambling regulation in 2023, concluded that “the effect of advertising and its role in gambling harm is under-researched and not fully understood… There is an urgent need to better understand the effects of gambling advertising on the risk of harm”.
The Investigation
As part of its investigation, the Committee held two public meetings in City Hall. The first was held on 29 November 2023, at which the Committee heard from two panels of experts in the field, and the second was held on 1 February 2024, at which the Committee heard from people with lived experience of gambling-related harms. The Committee also published a call for evidence to collect further evidence from key stakeholders, and received 14 submissions in total.
Recommendations
- The Mayor should bring forward proposals in 2024-25 to ban gambling advertisements on the TfL network. He should consult with key stakeholders, including charity and health partners and representatives of the gambling industry, before implementing such a ban.
- The Mayor should work with the NHS in London to pilot public health awareness messaging relating to gambling harms. This should include providing advertising space on the TfL network.
- The Government should reconsider the ‘aim to permit’ duty, which would give councils greater powers to refuse applications for new betting shops, where there are already high numbers in a particular area.
- The Mayor should work with NHS England (London) to advocate for training on gambling harms to be adopted across all GP practices in London.
- The Mayor should use his convening role to help ensure that, while the new commissioning arrangements under the statutory levy are being rolled out, there is effective collaboration and integration between NHS services and the third sector in London in delivering support and treatment for gambling harms, and there is no disruption to existing service provision.
Dr Onkar Sahota AM, Chair of the London Assembly Health Committee, said:
“It is hard to escape the presence of gambling in London. From the betting shops which spread along the capital’s high streets, to our transport network, billboards, TV and online, there are invitations to gamble everywhere you look. It is deeply concerning to hear that London’s rate of ‘problem gambling’ is almost twice the average seen across Britain, and that Londoners are more likely to be negatively impacted by someone else’s gambling. This includes families and children.
“The majority of actions required to regulate the gambling industry and alleviate gambling harms rest at national level. However, the Mayor of London has some relevant powers to address the issue. One crucial area where the Mayor can make a difference relates to advertising on the TfL estate.
“The Committee acknowledges the limitations in the evidence base linking gambling advertising with gambling harm. However, the absence of evidence of harm does not equate to evidence of an absence of harm and it seems unrealistic to expect definitive evidence to emerge on this topic in the near future. Therefore, the Committee does not believe that the current evidence base should be seen as a prohibiting factor in introducing advertising restrictions.
“The Mayor’s 2021 manifesto committed to a ban on ‘harmful gambling advertisements’ across the TfL network. The Committee was informed that this could not be implemented as there has been no definitive definition of harmful gambling, awaiting the Government to define what harmful gambling is. However, the Committee believes the Mayor should bring forward proposals to introduce a ban.
“It is crucial that Londoners who are struggling to control their gambling can get appropriate support and treatment. Whilst I welcome the introduction of the new statutory levy to fund research, prevention and treatment, the new commissioning model for treatment must address the fragmentation of current service provision and build on the strengths of existing services delivered by both the NHS and the third sector.”