UK LEGAL
category had been diagnosed with gambling problems by a professional.
Compared to previous sentiment from the regulator, including criticism of those who wished to “turn back the clock” to previous official data by Commission CEO Andrew Rhodes in 2024, there are signs that the Commission is softening its stance, accepting that other sources of data also have value. It’s acceptance of the OSR’s recommendation that it does more to investigate the comparability of GSGB statistics and intention to review it against the APMS data is a good start. It now mentions in its GSGB guidance that the survey is just “one source” of evidence and “should be considered alongside a wealth of other evidence and information”.
The next major milestone is the next release of GSGB data on 2 October 2025. A technical report, including a section on data validation, an evidence roadmap and research governance framework are also due to be published this Autumn. Results of additional experimental research are expected in August.
published a survey improvement plan on its website and established a GSGB statistics user group, which had its first meeting on 29 July. It also outlines plans to use the APMS data to investigate the coherence and comparability of GSGB statistics with other relevant data, along with results of further experimental research being undertaken to implement earlier recommendations from Professor Patrick Sturgis. The Commission’s guidance on the use of the GSGB has also been updated, including to add a recommended wording for comparing the statistics to other sources with lower estimates of problem gambling rates. The APMS data, released by the NHS at the end of July, brought the GSGB’s challenges back into focus. This was a survey covering a range of topics such as mental health conditions, alcohol and drug use, autism and eating disorders, as well as gambling behaviour. It involved around 7,000 interviews (at phase one) conducted between March 2023 and July 2024. Like the GSGB, this survey used the PGSI scale to assess behavioural symptoms of gambling disorder. The APMS found baseline figures of 0.4% of respondents having a PGSI score of 8+ (defined as “problem gambling”) and 1.6% scoring 3+ (at least “moderate risk gambling”). The GSGB, by contrast, had found figures of 2.5% of respondents in the 8+ PGSI category and 6.2% scoring 3+. The APMS publication does note that the 0.4% estimate of problem gambling rate is “likely to be conservative”.
Other notable findings in the APMS are that 30% of those in the “at least moderate risk” category were receiving treatment for a mental health or emotional problem, and that only one in fifteen respondents in this
28 AUGUST 2025
Melanie has been providing UK legal and regulatory advice to betting and gaming clients since the advent of the Gambling Act 2005. She advises on all aspects of gambling law including licence applications, compliance, advertising, licence reviews and changes of control and is described in the legal directories as “a very impressive lawyer” who “demonstrates commercial pragmatism supported with a great deal of technical and operational knowledge and experience”.
Melanie has acted for a wide range of gambling operators including major online and land-based bookmakers and casinos, B2B game and software suppliers and start-ups. She also frequently advises operators of raffles, prize competitions, free draws and social gaming products. Melanie has a particular interest in the use of new technology for gambling products and
novel product ideas. She is a regular contributor to industry publications and often speaks at industry events. Melanie is listed as a ‘Leading Partner’ in the Legal 500 guide and is also ranked in Chambers.
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