UK LEGAL


February 2023 and was finally published in August 2024. Its objectives included examination of whether the ban had been implemented as intended, the extent to which credit card users changed their gambling behaviours as a result of the ban, its impact on gambling-related financial harms experienced by people who gamble with borrowed money, its impact on affected others and people who gamble who are not currently experiencing harm, and the effect of the COVID-19 pandemic on the implementation and outcomes of the ban. Data from online surveys conducted pre and post ban, along with some in-depth interviews, were used to carry out the analysis.


A key area of analysis was the extent to which behaviours changed as a result of the ban. Interestingly, when looking at the overall sample, the research did not find any change in the proportion of people using a credit card to fund their gambling, before and after the ban. This is somewhat explained by the fact that, despite the ban, there remained ways people could use funds from a credit card to fund their gambling. The research mentions that over half of respondents who had used a credit card had done so indirectly, for example by withdrawing cash on a credit card to pay for gambling or using a credit card to pay for other expenses to free up funds for gambling. 74% of people who had gambled with a credit card post-ban had done so directly. This indicates that some people may have gambled on unlicensed online sites not subject to the ban, but NatCen found only a small proportion of respondents reporting using a credit card on a gambling website. Whether there was any significant migration to the black market was unclear from NatCen’s research. Once the results were grouped by PGSI score category, some significant differences in use of credit cards post-ban were


24 SEPTEMBER 2024


discovered. Among those experiencing no reported problems from gambling and those experiencing a low level of problems from gambling (those with a PGSI score of 0, 1 or 2), those in the post-ban waves were less likely to report using credit cards to gamble, compared with those in the same PGSI categories in the pre-ban waves. However, among those experiencing a high level of problem from gambling, the likelihood of using credit cards to gamble had increased in the post-ban waves compared with the pre-ban waves. This is very concerning, given that it is those experiencing problems with their gambling that the ban sought to protect. According to this data, it is primarily those who are not experiencing problem gambling who are affected by the restriction on the use of credit cards, whereas those who are experiencing problem gambling are no less likely post-ban to be gambling with borrowed money.


The report notes that, “If the changes above are due to the credit card ban, it appears that controlling for


sociodemographic characteristics the ban has worked best for people experiencing a low level of problems from gambling, but has not changed the behaviour of people experiencing a moderate or high level of problems from gambling.”


NatCen considers that the increased prevalence of use of credit cards for gambling in the period following the ban “may partially reflect the influence of the pandemic, which seems to have had a greater impact on the gambling behaviour of people with more serious gambling problems”. It notes that “among those experiencing a moderate or high level of problems from gambling, 22% reported the pandemic had made them more likely to borrow money to gamble, compared with one percent among all those experiencing no reported problems from gambling. This suggests that the credit card ban was introduced at a time when it would be difficult to reduce borrowed money use among people who were gambling frequently.” It also notes that a higher proportion of respondents were experiencing a moderate of high level of problems from gambling in the post-ban compared to pre-ban waves. The report focusses on one positive outcome of the ban, which is that it appeared to have been effective in creating some ‘friction’ among those with low level gambling problems, which may encourage them to reflect on their gambling expenditure before seeking other forms of borrowed money for gambling. This was not necessarily the primary goal of the Commission in introducing the credit card ban and, if creating a forced time to pause and reflect was the objective of regulatory change, this could have been achieved in a more deliberate and proportionate way, for example by mandating a cooling off period before deposits are processed in certain circumstances.


The report does not seek to address the important question of whether the ban was a proportionate way to achieve the benefits that have been demonstrated. This is a question for the Commission, but NatCen’s recommendations include further evaluation and research which focuses on those at highest risk of gambling harm and, for future policies, a focus on those most at risk.


Melanie is a gambling regulatory lawyer with 13 years’ experience in the sector. Melanie advises on all aspects of gambling law including licence applications, compliance, advertising, licence reviews and changes of control. She 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.


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