iGB Live 2025 - Helen Rhodes speech
04 July 2025
This speech was delivered by Director of Major Policy Projects and Evaluation Helen Rhodes at the iGB Live Conference on 2 July 2025.
Please note: This is the speech as drafted and may slightly differ from the delivered version.
Hello everyone, thank you for that introduction and thank you all for joining me here today. It's great to be here today, and have the chance to update you all on how we have been navigating the implementation of the Gambling Act Review.
I don't need to tell anyone here that the Review, published in 2023, is leading to significant change whilst maintaining the overarching aims and objectives of gambling regulation in Great Britain. But I’d forgive anyone for not being completely on top of the detail; we have moved at pace to implement and Government likewise, has made a number of significant changes. This has all happened - in regulatory terms - in a short period of time.
So what am I going to tell you about today? Well, given that rate of change we’ll start with an overview of where we’ve got to and I’ll detail a few key highlights and some of the more recent announcements. For those of you with an interest in land-based or in person gambling, the gaming machines consultation that closed last month has been a major focus this year and so I’ll update on that. I’ll then look ahead to next steps. As part of that I’ll not only look at Gambling Act Review projects, for example the Financial Risk Assessments Pilot, but also other areas of focus for the Commission. And when I’ve finished all that, I am of course happy to take any questions you have.
But let’s start with where we are now.
The last two years have seen a steady drum beat of announcements, consultations and changes from the Commission. And all of it planned to move the gambling sector in Great Britain through the implementation of the Gambling Act Review as quickly as possible, whilst making sure decision making is properly evidence based and everyone - from operators, third sector and the public - have a chance to make their voices heard. We have made real progress in that work and have already delivered changes that will help deliver safer, fairer and crime free gambling. It was about this time two years ago that we ticked off our first deliverables and we haven’t stopped since.
This year has been no different.
Starting with measures designed to empower consumers:
In May 2025, new rules to give consumers increased control of the nature of the direct marketing that they opt to receive - expressing preferences by product type and channel came into effect.
Following consultation we have also introduced new technical standards relating to customer-led tools. These new rules will give consumers more effective ways to manage their gambling by making it easier to set and maintain deposit limits on their online accounts, in ways that work best for them.
From 31 October 2025 all gambling businesses must prompt their customers to set a financial limit before they make their first deposit and make it easy to review and alter this limit at any point after.
These rules will take good practice already offered by some operators and expand that so customers can expect the same standards across the industry. As a result of our work, we also found that recent changes by some operators on how deposit limits are offered, could cause confusion for consumers. As a result, we carried out a supplementary consultation which closed in April.
Sticking with the fair and open theme, we introduced new rules to further increase the level of protection that an operator has put in place for the protection of customer funds so that customers can make effective choices about the risk that they are comfortable with.
Straddling the fair and open and the safer gambling theme, we also published new rules increasing the safety and simplicity of consumer promotional offers, following a further consultation. In changes that will come into force on 19 December 2025, our new rules will mean:
A ban on mixed product promotions
Limiting bonus wagering requirements to 10
And changes to our rulebook, the Licence Conditions and Codes of Practice, to make sure there is increased clarity of the Commission’s current expectations of operators in this space.
These changes are crucial in making gambling safer and fairer for consumers. For example, a ￡10 bonus with a 50 times wagering requirement, requires the consumer to play through ￡500 before the winnings can be withdrawn.??Such high wagering requirements can confuse consumers and lead them to gamble for longer and faster, than they are used to.
So it is our view that these changes will better protect consumers from gambling harm and give consumers much better clarity on, and certainty of, offers before they decide to sign up.
As with all the implementation of Gambling Act Review deliverables, these changes will be evaluated as well and if you want to know more about the Commission’s approach to evaluation, there is plenty of detail on our website.
But we haven’t just been publishing results and changes this year, we’ve continued to consult as well. And before I go further I just want to say something that some of you will have heard either myself or others from the Commission say before but it bears repeating: the views submitted to our consultations can and do lead to changes that make for better policy and better rules in the future. So never think we are doing a tick box exercise when we consult. We value every submission. And this is just as true for our recent gaming machines consultation as it ever is.
As many of you will already know, the consultation was focussed on the gaming machine technical standards and the related testing strategy. Even before the consultation was launched, we were really pleased with the level of pre-consultation engagement we received and that in itself made for a better consultation. We also, following feedback, extended the consultation to allow for more submissions and more data and evidence to be collected.
I hope that this shows how seriously we take this work: we want to get it right.
And on that I think it’s important to highlight what our intention was, based on what the White Paper called for. That was to arrive at a package of proposals that protects vulnerable people, ensures consumers can make informed decisions about their gambling and recognises the need to minimise the impact on consumers who are not experiencing difficulty in managing their gambling safely.
As a result, the consultation focused on proposals in the following key areas:
We proposed streamlining the 12 sets of technical standards into one document to make compliance easier.
We proposed fair and open measures such as ensuring that the machine makes clear the position when awards below the stake size are given.
And we proposed measures to support safer gambling – display of net position and session time, limit setting functionality and prohibiting game design features that are more associated with risk - player-led features that permit a customer to reduce the time until the result is presented.
As I say, we’ve been really pleased with the engagement with this consultation. We received approximately 1,000 responses to the consultation, and we are now of course working through what we received. But coming back to where I started, whilst we have clear policy objectives we intend to achieve through this consultation, we are open to new ideas and alternatives that may achieve them. All your submissions will help us achieve the best result and so for those of you who did make a submission, you have my thanks.
So 2025 has already been a very busy year for implementation but I haven’t yet said anything about one of the deliverables we’re implementing that, on balance, has probably received the most attention and that is of course the area of financial risk. We implemented light-touch financial vulnerability checks using publicly available data last August, first at ￡500 per 30-day rolling period and then since 28 February, ￡150 net deposits per 30 days. Again these will be evaluated as we continue.
On top of this we have also recently completed the pilot of Financial Risk Assessments and have moved to an analysis phase. Again, I am sure most of you here know what these are and what we’re looking to achieve, as set out in the White Paper. But for those of you who may not be living and breathing this with me, the objective of Financial Risk Assessments would be a very targeted way of identifying customers who are both high-spending and who are in current significant or imminently worsening financial difficulties by flagging customers who are for example in significant or multiple arrears, defaults or bankruptcy. To be clear, this is not just another way of saying “affordability checks” - we do not have any regulatory requirements for affordability checks and are not proposing any.
Recently we published an update on phase 2 and there were some interesting points to note:
In stage 1, approximately 95 per cent of assessments were possible in a frictionless manner, and for stage 2 this increased to 97 per cent. The findings from stage 1 and 2 are favourable compared to the 80 per cent which was estimated in the White Paper
Approximately 3 per cent of the assessments were not matched in this stage – this compares to 5 per cent in stage 1 of the pilot. This again is favourable compared to the estimated 20 per cent who would not have a frictionless assessment as set out in the 2023 Government White Paper
And if the proposed thresholds from the Commission’s 2023 consultation were introduced, stage 1 and 2 would suggest that operators would be unable to meet the requirements in a frictionless way for only 0.3 per cent of active accounts or one customer in every 1,000 accounts
The pilot also gave us some information about the risk associated with customer accounts that would receive an assessment if they were introduced. The results vary across operators with customers in the pilot cohort between twice and 4 times more likely to have a debt management plan and between twice and 5 times more likely to have a default in the last 12 months than the type of consumer in their comparison UK populations.?
The pilot findings represent a significant step forward, and our analysis phase will enable us to further explore how operators could embed assessments into their overall customer interaction approaches and how to reduce unnecessary inconsistency between credit reference agency reports. Watch this space for further updates on pilot findings and next steps.
Before I wrap up, I just want to briefly touch on 2 further areas of work for the Commission which focus more on our Licensing Objective to make sure gambling is fair and open.
As Andrew Rhodes said in a speech earlier this year, we are working closely with the Information Commissioners Office (ICO) on bringing the 1,000 most popular UK websites into compliance with making sure everybody has meaningful control over how they are tracked online. Some of those websites are gambling sites and so we are working with the ICO to ensure compliance.
And finally, we committed in our business plan to take forward a programme of work to improve transparency to consumers on the reasons for identity checks or restrictions, particularly where these take place later in the consumer journey, such as on withdrawal. This is an area of active interest for the Commission and so I would encourage you all to keep an eye out for what we may be saying on this in the future.
And I think I’ll leave it there. Thank you for listening and I look forward to your questions.
Thank you.
Last updated: 4 July 2025
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