Several months later than originally expected, DCMS – which meanwhile has become DDCMS, Department for Digital, Culture, Media and Sport – has produced, not the expected decisive action about FOBTs and advertising, but instead a further consultation document which postpones the decision on FOBTs for another several months and contains a string of other disappointments.
No decision yet on the Fixed Odds Betting Terminals
Government accepts that large losses are being experienced by players of B2 machines, that there has been no reduction in the prevalence of problem gambling and that the industry’s self-regulatory measures introduced in 2013 appear to have made little difference. It concludes that the maximum stake on a single play on a B2 machine should indeed be reduced, as has been widely suggested, from the current £100. This is the single part of the document that the media has picked up on, making it look as if Government has been listening and is taking decisive action. Unfortunately this is far from being the case. It is stated that evidence is lacking to inform their decision about what a new maximum stake should be. The document goes on to outline four illustrative alternatives: £50, £30, £20 and £2, although anything between £50 and £2 is possible. Since a reduction to £2, which would bring B2 machines into line with other categories of gambling machine, is what has been widely called for (by the Local Government Association and 93 local authorities across England and Wales, by a variety of campaign groups, charities and faith groups, by the All-Party Parliamentary Group on FOBTs, and by the campaign group 38 degrees which submitted a petition with over 100,000 signatories), whereas £50 would scarcely alter the nature of B2 machines at all, this is a surprisingly wide range of possibilities. It is difficult to know what is going on. Does this indicate that there is a major divergence of views on this issue within DDCMS which is playing for time? Does it suggest that we are being prepared for a compromise £30 or £20 which might be acceptable to the industry but which would preserve the special nature of B2 machines as high stake/high prize, high-powered machines with addiction potential, very different from other gambling machines capped at a much lower stake-level?
Gambling industry wants no change on FOBT stakes but increases elsewhere
Unsurprisingly the industry argued for maintaining the status quo on stake limits. But not content with defending abnormally high stakes on B2 machines, the industry had also made other proposals which clearly indicate their intention to press forward with further innovations which put people at risk. For example, the industry proposed increases in maximum stakes on B3, C and D category machines, increases in prizes in categories C and D, more machines in casinos, and a 500% increase in the maximum progressive jackpot prize for B1 machines in casinos. The British Amusement Catering Trades Association (BACTA) also made a further extraordinary suggestion which indicates the way they are thinking. They proposed a new sub- category of machine in amusement arcades, a B5, which would have a maximum stake of £10. They argued it would allow operators to offer a more varied selection of products including what they describe as ‘low stake roulette’. So, not content with having turned betting shops into mini casinos in the high street, they have now set their sights on doing the same for amusement arcades. To their credit, DDCMS are not persuaded about the need for these changes at this time and propose maintaining the status quo, at least for now.
No change on gambling advertising
If we were also hoping for decisive action on advertising, we will have been disappointed. In defence of its proposal to do nothing much about gambling advertising they argue that existing Advertising Codes and the industry voluntary code already restrict the content of gambling advertising. They repeatedly cite the review carried out a few years ago, published by industry-led Responsible Gambling Trust (now GambleAware), and much quoted by the industry, which came to the controversial conclusion that the impact of advertising on problem gambling prevalence was ‘likely to be neither negligible nor considerable, but rather relatively small’. The DDCMS report refers to what they call a ‘package of measures and initiatives... intended to address concerns about gambling advertising...’, but this appears largely to consist of making the existing regulations clear to everyone, tightening up on them a bit, welcoming the proposals of the Committees of Advertising Practice (CAP) to produce new guidance, and supporting GambleAware, broadcasters and industry groups who have drawn up proposals for a major responsible gambling advertising campaign. Such campaigns are of doubtful effectiveness and in the case of gambling may do as much to promote the normalisation of gambling as to reducing harm.
Nothing for local communities
The new consultation document contains yet more disappointments. It is made clear that Government intends to do nothing new to help local authorities control the concentration of betting shops in their communities, and the wider impact of the normalisation of gambling in society is not addressed at all.
Complacency about treatment for gambling problems
In a short sub-section on Treatment, there is a rather extraordinarily complacent statement: ‘Problem gamblers can already access treatment services in primary and secondary care including specialised mental health services. Local authority commissioned specialist drug and alcohol services may also be able to offer treatment…’! There is nothing at all in this section, or anywhere else in the document, about services specifically for affected family members, that largest of all stakeholder groups who are harmed by gambling.
Worst of all, a Government that supports gambling growth and is committed to taking a backseat
But there is even worse. The Executive Summary contains a clear statement of the overall position of the Government in relation to gambling regulation and its own responsibility in the matter. There are two statements in particular that stand out. This is the first: ‘The objective of the review was to ensure that we have the right balance between a sector that can grow and contribute to the economy, and one that is socially responsible and doing all it should to protect consumers and communities, including those who are just about managing’. That makes it abundantly clear that Government wants to encourage the growth of gambling in Britain. This is strange for a Government that must be concerned about its public image, since survey evidence is quite clear that the majority of the public do not want more gambling, in fact most people think there is too much of it already. The second, equally revealing and worrying, statement makes it clear that the present Government intends to take a back seat, giving the industry a central position: ‘... we want to see industry, regulator and charities continue to drive the social responsibility agenda, to ensure that all is being done to protect players without the need for further Government intervention...’.
It is Government’s overall position on gambling in Britain that needs to change. We will not see serious reform while Government continues to support the growth of gambling and refuses to contemplate a proper national debate on the role of gambling in modern Britain and a proper national gambling strategy which mandates cross-Government-department action on the prevention and treatment of gambling harm.