Industry Pushes Back on House of Lords Gambling Ad Ban Call After Disputed Survey and 2024 Data

The House of Lords Liaison Committee wants the government to ban gambling advertising “as soon as practicable”, but the industry says the report leans on contested evidence and ignores the practical mechanics of how advertising rules and black-market displacement work. For PSPs, the important bit is simple: when policymakers build a case for tighter ad controls, the quality of the underlying harm data matters.

1. On 17 September, the committee issued a follow-up report urging ministers to abandon their aim of growing the licensed industry and return to the pre-2005 view that gambling should be tolerated but not promoted. Its core claim is blunt: there is “no evidence for the safety of gambling advertising”.
2. The first number in the report is that between 1 million and 1.5 million adults in Great Britain gamble in a way that may be called problem gambling. That estimate comes from the Gambling Commission’s Gambling Survey for Great Britain (GSGB), which puts 2.4% of adults at a score of eight or more on the Problem Gambling Severity Index. The report also notes that the NHS Health Survey for England found a rate of 0.7% in 2024, which would imply about 350,000.
3. Dan Waugh, a partner at consultancy firm Regulus Partners, says the GSGB is producing higher rates than every other official source going back almost two decades, including three NHS surveys and the commission’s own telephone survey. His explanation is topic salience: because the GSGB presents itself as a gambling survey, it may over-recruit gamblers and more engaged gamblers.
4. Waugh also points to the survey’s 18%-19% response rate, below its 22% target, and says Heather Wardle warned the commission in 2023 that topic salience bias was the likely cause of over-reporting. He says that advice came to light only through a freedom of information request.
5. The Gambling Commission stands by the GSGB, saying it was “designed by experts, reviewed by experts and approved by experts”, and argues that respondents are more honest when no interviewer is present. The report cites Patrick Sturgis of the London School of Economics as endorsing the method, although his own 2024 review for the commission advised caution about a risk of overstatement.

The committee also dismissed black market concerns on the strength of interviews with state monopolies, which is the sort of evidential shortcut that tends to irritate the people who actually have to operate in regulated payments. Grainne Hurst, chief executive of the Betting and Gaming Council (BGC), called the report “a deeply misguided report which risks weakening, rather than strengthening, consumer protection”.