SIMON THOMAS


THE EVIDENCE AT A GLANCE How reliable is the evidence?


One of the paper’s central themes is that evidence should always be open to scrutiny, particularly when it is being used to justify significant tax or regulatory changes. Regulus examine the Gambling Survey for Great Britain and highlight examples where participation estimates differ substantially from Gambling Commission industry statistics. They also discuss observations previously made by the Office for Statistics Regulation and the Office for Health Improvement and Disparities, arguing that the strengths and limitations of survey data should be fully recognised whenever it informs public policy. Their broader point is not that the survey lacks value, but that confidence in any policy depends upon confidence in the evidence on which it is based.


Correlation and causation are not the same thing


A recurring theme throughout the paper is the importance of distinguishing between association and causation.


Regulus argue that many people participate across multiple forms of gambling over the same period, making it difficult to attribute complex behavioural outcomes or economic costs to a single gambling product with confidence.


Their conclusion is not that gambling-related harm should be ignored, but that policymakers should be cautious before drawing firm conclusions where behaviour is influenced by numerous overlapping activities.


International experience offers a warning The paper also looks beyond Britain.


Drawing on international experience, including developments in the Netherlands, Regulus argue that substantial increases in gambling taxation do not automatically produce higher government revenues. Where higher taxes undermine commercial viability, businesses can close, investment falls and the taxable base contracts. The lesson, they suggest, is that behavioural responses should always be considered alongside fiscal forecasts.


Why the regulated market matters


The paper also examines the wider consequences of weakening the regulated sector. Licensed operators contribute taxation, employment, investment, safer gambling initiatives, anti-money laundering controls and consumer protection. Illegal operators provide none of these safeguards. Regulus argue that regulation should therefore be judged not only by the restrictions it imposes, but by whether it keeps consumers within a regulated environment where those protections exist. Regulus’s paper won’t settle every argument, nor does it claim to. What it does demonstrate is the value of rigorous analysis and the importance of questioning assumptions before they become accepted wisdom.


Whether readers ultimately agree with every conclusion or not, the paper deserves to be read because it reminds us that good public policy depends on evidence that is continually examined, challenged and refined.


Your action is required


There is a wider reality that those of us who care about a fair, evidence-led debate need to confront. Research critical of gambling can generate headlines almost instantly; serious rebuttals, however well evidenced, rarely receive the same attention. We can complain about that imbalance, or we can do something about it. That means engaging with the debate, supporting rigorous research, challenging questionable claims, meeting our MPs and making sure policymakers hear directly from the people who understand this industry, employ thousands within it and see its realities every day. If we want our voice to count, we have to use it – and sometimes we have to shout rather loudly to be heard.


Paul Leyland is a co-founder and partner at Regulus Partners, advising on the economics, regulation and commercial development of gambling and related sectors. A highly experienced financial analyst, he has followed the gambling industry for more than 25 years and previously served as Corporate Development Director at William Hill. His work focuses particularly on the economic and commercial consequences of regulatory and tax change.


Dan Waugh is a partner at Regulus Partners and a leading analyst of gambling regulation and safer gambling policy. He has published academic research, given evidence to parliamentary committees and previously served as Group Strategy Director at The Rank Group. A former founding chair of the gambling education charity YGAM, his work focuses on the quality of evidence used to shape gambling policy and regulation.


attributed to gaming machines, 81% also reported playing online slots, 70% bought scratchcards, 61% played instant-win games, 57% played the National Lottery, 54% placed sports bets in person, 53% played online casino games and 50% placed sports bets online over the same four-week period.


Their question is an entirely reasonable one. If people participate across so many different gambling activities simultaneously, can we confidently attribute the associated harms almost entirely to a single product?


Readers may ultimately agree or disagree with Regulus’s answer. I simply think the question deserves to be asked.


The final section of the paper looks at what economists often call unintended consequences. Regulus argue that if licensed businesses become less viable, demand for gambling does not simply disappear. Instead, consumers increasingly migrate elsewhere.


They point to forecasts suggesting stakes with illegal online operators could rise from around £17 billion in 2025 to more than £33 billion by 2028, meaning almost one pound in every five wagered online could be taking place outside Britain’s regulatory framework within just a few years if current trends continue.


That should concern everyone, whatever their views on gambling. Illegal operators pay no British gambling taxes. They contribute nothing to racing. They provide none of the consumer protections, affordability safeguards or anti- money laundering controls required of licensed operators.


Weakening the regulated sector does not strengthen consumer protection if consumers simply migrate into an unregulated one. That, perhaps, is the biggest lesson I took from Dan’s paper.


I’ve deliberately devoted more space than usual this month to somebody else’s work because I think this debate deserves more than headlines and soundbites.


You may agree with every one of Dan and Paul’s conclusions or disagree with some of them, but I hope you’ll read them because good public policy is strengthened when evidence is challenged and assumptions tested. The Regulus team’s rigorous analysis deserves to be part of that conversation.


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JULY 2026 13


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