UK LEGAL COMMENT
Evaluating the impact of the White Paper
When it comes to the creation of new regulations and to the evaluation of those, it’s true to say that good intentions do not always lead to good results. So says Northridge Law’s Melanie Ellis.
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n a recent blog post titled “Evaluating the impact of the Gambling Act Review”, the Gambling Commission’s David Taylor (head of evidence, assurance and evaluation) identified the need to “monitor and evaluate the measures that are implemented carefully”. It is welcome
news that the Commission recognises the importance of the evaluation stage as, to quote its own customer interaction guidance, “Good evaluation helps you to understand which aspects of your approach are the most effective”. We must await details as to what the evaluation process will
look like but, in case Mr Taylor is reading, I would suggest there are three key issues it should assess: whether the new LCCP provisions are achieving their objectives, whether they have created any unintended consequences and whether they have proved to be proportionate (taking into account both their costs and effectiveness). The Commission does not have a great track record of
evaluating the impact of regulatory changes. In November 2021, it carried out an interim assessment of the effectiveness of the April 2020 ban on gambling with credit cards. Whilst this found no evidence of an increase in illegal money lending, gambling with other borrowed funds or a spike in ATM withdrawals, the period being assessed coincided with the strictest covid measures. The regulator commissioned NatCen Social Research to carry out a full evaluation of the credit card ban, scheduled to be completed in early 2023, however the results of this appear to have either been severely delayed or brushed under the carpet. A further attempt at evaluating the impact of significant
regulatory changes was made in June 2023, when the Commission assessed the impact of its online game changes for slots products (which included a minimum 2.5 second spin speed). This seems to have been a more thorough examination than was completed for the credit card ban, however the assessment cannot be said to conclusively show that the changes were effective at reducing gambling harm. The aim of the new requirements was to make slots products safer, but the evaluation did not appear to find any significant positive changes to customer behaviour (for example while the proportion of play sessions lasting over 60 minutes fell from 7.8 % to 6.9%, there was a 6.1% increase in the total number of slots sessions and the total number of sessions over 60 minutes) and it was not able to assess whether problem
22 APRIL 2024
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