Daniel Waugh

A reminder that the Gambling Commission refused to release the results of this survey for more than three years - despite Freedom of Information Act requests. Important evidence deliberately withheld from the public consultation on these checks... racingpost.com/news/gambling-…

'The threat of the black market is overblown' Has @AlexBallingerMP not read the latest @YieldSec report that suggests black market in UK up from 0.43% in 2020 to 9% now? Alex Ballinger's points: 1⃣ Moving from turnover tax to gross profits tax in 2001 did not increase black market. Not surprising considering one of the main reasons for the tax change was encourage offshore operators back to the UK. 2⃣ 2014 point of consumption tax did not increase black market. Not surprising considering one of the main reasons for the tax change was to force offshore operators back to the UK. 3⃣ Mentioned a 2021 (5 year old) Gambling Commission study on the unregulated market. £12bn has been wiped off the regulated betting market in recent years. 2021 was before affordability checks kicked in deeply. This was before Gamstop expanded and expanded. This was before the tax changes kicked in.

An insightful read. There are clearly questions to answer. The gambling harm prevention world has become very murky in the last 3 years since certain charities appeared, and funding is less transparent than ever before. Less help than ever available for those who need it @DCMS

Racecourses losing sponsorship income isn’t “performative.” It’s what happens when you nearly double the tax rate. The people who advocated for these increases now dismissing the consequences as empty gestures is something else entirely.

@ThomasAkoo Great reporting Zak. Funny how your comment about the architects of the levy washing their hands of the mess (which has been underway for some time) automatically triggered a pro-levy lobbyist to do just that. Keep digging.

Mark my words - when this starts making the national newspapers the architects of this farce will be the first to wash their hands of it.

So many people who have devoted their lives to fighting problem gambling treated like dirt while there’s something that feels like a conspiracy of silence about the vast damage being done to the actual existing harms system. This is a huge scandal and yet no one seems to care.

@ThomasAkoo @jranoyes The Government provided two reasons to enact the levy: 1) perceptions of undue influence (rather than evidence of undue influence); & 2) the need for greater stability of funding. What has transpired is 1) actual undue influence & 2) the destabilisation of the treatment system.

@jranoyes Thanks for engaging James. The offensive isn’t meant at the concept of the levy in the first place - those are valid points and don’t think most people would object. What makes me angry is the so-far shambolic execution…

The body that is responsible for allocating public funds (OHID) has been revealed to be collaborating directly with certain campaign groups (who are asking to receive funding) while not answering emails to existing providers. Frontline services are suffering

Also worth noting that the Office for Statistics Regulation wrote to the OHID last year to ask it to make it clear that the figures have no causal meaning (which the OHID has admitted). The OHID response underscores their junk credentials…. open.substack.com/pub/danwaugh/p…

It’s a junk science approach to a serious subject. According to the same OHID methodology, there are tens of thousands of suicide attempts in Britain each year associated with visiting museums and art galleries…open.substack.com/pub/danwaugh/p…

A case study of contemporary British government at its worst. You cripple the nightlife economy with higher taxes, costs plus more rules, regulations and compliance demands. Then you propose a Minister for Nightlife to revive the nightlife economy.

When will the likes of @Betfred and @bet365 stand up for UK gamblers by coming out publicly against the anti-gambling brigade and UKGC? @geoffbanksbet thinks we have reached a "Tipping Point" in the UK: slotshawk.com/news/martin-cr…

In 2021, I became very wary of the statutory levy, not against it's implementation, but about how, and why the policy was being pushed. It became clear to me that hardline anti gambling organizations had developed immense power within Public Health circles, particularly OHID/PHE and within councils and combined authorities, and stood to benefit from the levy. Very senior OHID officials were working closely with campaign groups from as early as 2020. Whilst this is not something inherently problematic, The decision for OHID to engage so differently with it's favored organizations, and blank others rang serious alarm bells for me. When OHID became commissioners of the levy funds, It had to be on the basis that this wasn't funding for friends, and commiserations to those that had been working in the previous system, but whilst most charities and organizations were left in the dark, some groups have had unfettered access to key decision makers, including the most senior levy decision official. The Men's health strategy was being shared with those organizations before anybody else had seen them, insider information from a government department, simply because OHID felt they may oppose their strategy. Any organization looking for funding from OHID received clear, and valuable information is to where to place their funding strategy, information not available to anybody else. What is more, those organizations, in spite of concerns, agreed not to challenge, showcasing what i perceive to be a system that is not independent. The levy shouldn't be a political football, It should have been an independent fund to help protect those impacted by gambling addiction, something @jrnoyes intended it to be. I don't want to be saying, I told you so in a years time, and i seriously hope no levy funds have been used to prop up campaign groups in the interim. @OHID @DHSCgovuk @lisanandy next.io/news/regulatio…

This isn’t public health. It’s political capture. And the people suffering most are those who need help. next.io/news/regulatio…

The same body that penalises charities for previously accepting industry funding under the old officially sanctioned system is quietly coordinating strategy with Gambling With Lives and Lord Foster.

Andrew Rhodes took over the Gambling Commission at a moment when the regulatory mood was already shifting, but before the most far-reaching changes had been fully locked in. In the period immediately preceding his arrival, the Commission published its National Strategic Assessment 2020, which set an important baseline. Using what it described as the best available survey data, the report concluded that problem gambling rates were not increasing and had been statistically stable since at least 2012. The overall rate was around 0.6 percent of the population. Yet despite this stability, the report described the level of harm as “simply unacceptable” and in need of drastic reduction. That tension, between stable prevalence and an uncompromising policy ambition, framed everything that followed. This assessment emerged during a time when public and political attention was being driven less by population data and more by highly visible failures. VIP schemes, stories of individuals losing very large sums in short periods of time, and perceived regulatory lapses became a staple of media coverage in the late 2010s. These cases were rare in statistical terms but powerful in narrative terms. By the time Rhodes arrived, the debate had already moved away from proportionality and toward the expectation of decisive, visible intervention. The regulator was under pressure not merely to monitor risk, but to be seen to be preventing it. Rhodes did not create this environment, but he inherited it at precisely the moment when it was being translated into hard policy. The Gambling Act review was under way, online gambling had accelerated sharply following Covid, and there was growing political consensus that the existing framework had failed to keep pace. Under his tenure, the Commission’s role shifted decisively. Gambling increasingly came to be treated as a population-level public health issue requiring systematic friction, surveillance, and early intervention, rather than a mainstream leisure activity with a small but serious tail of harm. Affordability, even when carefully rebranded, became the centrepiece of this approach. What began as concern about extreme cases evolved into formal concepts of “financial vulnerability” and “financial risk”, with thresholds triggered at levels of spend that many ordinary customers would not consider exceptional. The White Paper published in April 2023 crystallised this direction. Although authored by DCMS, it was heavily shaped by regulatory advice, evidence framing, and risk assessments provided by the Gambling Commission itself. The Commission was not a passive recipient of policy; it was a key adviser on its design and justification. From that point on, the Commission moved firmly into implementation mode. The pilot for financial risk checks began in August 2024 and was presented as a measured, evidence-gathering exercise. The checks were described as frictionless and data-led, relying on credit reference information rather than direct document requests. In practice, they introduced prolonged uncertainty. The Commission last provided a substantive public update on the pilot in May 2025. By February 2026, there have been no published conclusions, no clear success criteria, and no indication of how the results will be applied. This limbo has real effects. Operators are left unsure how to design systems, products, and customer journeys around rules that may yet tighten or expand. Punters face a deeper problem. Many are now reluctant to deposit funds into the regulated market at all, not because they are harmed, but because they fear that normal gambling activity could unexpectedly trigger intrusive requests for bank statements, payslips, or other personal financial data. The absence of clarity has created fear and hesitation, and uncertainty itself has become a deterrent to participation in the licensed market. Throughout this period, Rhodes consistently played down the risk that tougher regulation would drive consumers toward the black market. He argued that such risks were overstated and often exaggerated to resist reform. That assessment mattered because it underpinned the policy trade-offs being made. If offshore leakage is minimal, then the cost of added friction appears acceptable. Over time, that position became increasingly difficult to defend. Estimates of illegal gambling participation rose sharply in public debate, particularly around crypto casinos, influencer-driven platforms, and unlicensed operators promoted via social media. Even allowing for disagreement over headline numbers, the direction of travel became uncomfortable enough that the Commission itself began commissioning and publishing research into illegal online gambling, consumer awareness, motivations, and participation pathways. A risk that had once been treated as peripheral became a formal research priority, implicitly acknowledging that the earlier confidence may have been misplaced. Enforcement under Rhodes remained assertive. Large fines and settlements continued to be used to force operator change, with substantial sums flowing through penalty mechanisms in some years. The precise totals varied, but the behavioural impact was consistent. Compliance costs rose, risk tolerance fell, and operators responded predictably with tighter limits, worse margins, fewer promotions, and more aggressive account management. For punters, these consequences mattered far more than enforcement headlines. Regulatory cost is not absorbed by operators; it is passed on through reduced value and increased friction. The regulated market became progressively less attractive at precisely the moment it was being asked to compete with unregulated alternatives that face none of these constraints. Rhodes also oversaw a major shift in how gambling harm is measured, most notably through the Gambling Survey for Great Britain. The GSGB was positioned as a more comprehensive and modern dataset, but it quickly became contentious. Its findings differed sharply from earlier surveys and were used to support claims of widespread harm, even as critics questioned methodology and interpretation. Despite this expansion in data collection, outcomes remain unclear. By the Commission’s own measures, harm appears flat to slightly up, with changes often not statistically significant. A dramatic increase in regulatory intervention has not been matched by a clear improvement in the outcomes used to justify it. Alongside these developments, the Commission itself expanded. Fees increased, staffing grew, and new responsibilities were added, including preparation for the statutory levy. This growth matters because institutions adapt to their own scale. Larger regulators tend to measure success through activity, process, and intervention, rather than restraint or simplification. The final pressure on the system arrived from outside the Commission but landed squarely on its regulatory framework. In late 2025, the Treasury announced major gambling tax increases, including a sharp rise in Remote Gaming Duty from April 2026. While these decisions were not made by the Commission, they compounded the effects of the regime it had helped shape and advise. Higher taxes layered on top of higher compliance costs inevitably flow through to worse value, lower limits, and greater pressure on the regulated market, while unlicensed operators remain unaffected. So how should Andrew Rhodes’ tenure be judged? If success is defined as delivering maximum regulatory change, embedding affordability checks, expanding enforcement, and scaling the Commission’s authority, then his period in office was effective. The regulator he leaves behind is larger, more powerful, and more interventionist than the one he inherited. If success is defined by outcomes that matter to punters and the wider public, the picture is far less convincing. Harm has not clearly fallen. The black market appears to have grown. Ordinary punters face more friction, more uncertainty, and worse value, while confidence in the regulated market has weakened. What happens next will depend heavily on whether the Gambling Commission rethinks not only how it enforces policy, but how it advises government. The Commission plays a central role in shaping DCMS policy, as it did during the White Paper process, and will continue to do so going forward. If its advice remains rooted in the belief that broad intervention and enforcement can substitute for market competitiveness, the current trajectory will persist. If, however, it recognises that most punters are not harmed, that uncertainty drives people offshore, and that a strong, attractive regulated market is itself a form of consumer protection, a different path is possible. The tools of intervention are now firmly in place. The next phase will be defined by whether they are applied with greater restraint, better targeting, and a clearer focus on outcomes rather than activity. That cultural shift, more than any new rule or consultation, will determine the future of the UK regulated gambling market.

And yet the architects and proponents of these disastrous policies are already washing their hands of it, and saying “wait a year”. Try telling this to the people being laid off @theobertram @jranoyes

So far this week. William Hill closing stores and cutting jobs, Coral ending an iconic racing sponsorship; and the Govt asking gambling operators to pay more in fees so the regulator can keep its staff and police black market the tax hikes are fuelling. news.uk.cityam.com/story/2395635/…

I have written this piece about the incivility of public health's civil servants... danwaugh.substack.com/p/time-to-stan…

Name them.