The Department for Digital, Culture, Media and Sport (“DCMS”) announced on 5 December 2024 that it will work with the Gambling Commission to deliver an appropriate programme of work to evaluate the impact of the policy measures implemented following the Gambling Act Review (“GAR”).

The previous Conservative Government’s plans for reform of gambling regulation involved over 60 key policy proposals, which were set out in its White Paper: High stakes: gambling reform for the digital age (published in April 2023). In its announcement, DCMS recognised the difficulty of attributing observed changes to any one policy measure in this complex piece of work, particularly given that policy measures have different timeframes and implementation processes, and potentially intersecting outcomes and impacts, but emphasised the importance, nonetheless, of evaluating the collective impact of the GAR.

What has happened so far?

In January 2024, DCMS and the Gambling Commission commissioned the National Centre for Social Research (“NatCen”) to undertake an evaluation scoping study. As part of this study, the impacts and outcomes of specific proposals will be evaluated individually, as well in a package to understand the collective impact of policy measures that have been implemented so far.

NatCen then held a series of Theory of Change (“ToC”) workshops with DCMS and Gambling Commission colleagues to identify a series of specific policy measures that had been developed since the publication of the White Paper. The scoping work highlighted that this evaluation plan requires a proportionate approach, focusing on a number of specific policy measures in detail.

What will happen next?

The forthcoming evaluation will focus on evaluating the impact that can be attributed to a number of specific policy measures implemented under the GAR. For each policy change, the evaluation will aim to gather evidence and formulate findings to answer the following questions:

1. What intended and unintended outcomes and impacts have been brought about in the short and longer term by the Gambling Commission, DCMS and independently led proposals in the two-year evaluation that were introduced following the GAR?
   a. In what ways, if any, did these outcomes and impacts link and interact?
2. Were the proposals implemented as intended?
   a. Did the proposals introduced reach online and land-based gambling providers and consumers as intended?
   b. In what ways, if any, did implementation vary from that intended and why? If there was variation, what were the associated impacts?
3. What was the distinct contribution of the DCMS, the Gambling Commission and independently led proposals in achieving the observed outcomes and impacts?
   a. How and why did the proposals contribute to reducing gambling-related harm to vulnerable groups and their wider communities in the short-term and longer-term (or not)? What worked best for whom, why and when?
   b. How and why did the proposals contribute to increasing gambling protections, while ensuring a fair and open safeguarding of gambling-related consumer freedoms and choice for customers in the short-term and longer-term (or not)? What worked best for whom, why and when?
   c. How and why did the proposals contribute to regulating the online and the land-based gambling industries more equitably in the short-term and longer-term (or not)? What worked best for whom, why and when for the online and the land-based industries?
4. What was the combined contribution of the proposals in achieving the above observed outcomes and impacts?
5. What conditions were necessary for the proposals to achieve the above observed outcomes and impacts?
6. What internal and external influencing contextual factors supported or impeded the proposals to achieve the above observed outcomes and impacts?
   a. In what ways, if any, did internal and external influencing contextual factors interact with the proposals?
7. What are the implications of the findings from the evaluation for the implementation of future gambling-related policy changes?

The aim of the evaluation is to understand the impact and outcomes of specific policies – both individually and collectively – and also to establish plausible causation related to the GAR policy measures with a high degree of certainty, carefully factoring in the impact of alternative explanations. DCMS emphasises the importance of the latter given the “many and diverse” nature of the policy measures in an implementation context that “is complex, dynamic and evolving”.

How will the evaluation be designed?

With the aim of establishing a clear degree of confidence in each claim, the hypotheses (i.e. the causal contribution claims) will be developed using Contribution Analysis, which is a step-by-step approach to data collection, triangulation and analysis based on a ToC and testable causal contribution claims. Process Tracing will then be used to ensure that the hypotheses are empirically testable and guide data collection.

The evaluation will draw on multiple sources of evidence, including qualitative insights and findings from quasi-experimental quantitative analysis. DCMS believes that quasi-experimental designs “will enable robust causal estimates of the degree to which changes in outcomes can be attributed to specific GAR policy measures”.

What methodology will be used?

The quasi-experimental designs will draw from online and land-based operator data, whilst in-depth interviews, focus groups, diary studies, and surveys will be used for qualitative impact and process evaluation. The latter would involve a range of participants, including operators, people who gamble, and other relevant stakeholders, such as local providers of support services. This will run alongside periodical tracking of GAR policy implementation and external influencing factors.

Who else is involved?

NatCen will establish two independent groups to provide advice and guidance throughout the evaluation, but these groups will not play a direct role in policy development:

1. Lived Experience Panel
   This panel will work alongside the Gambling Commission’s pre-existing Lived Experience Advisory Panel, aiming to ensure that the voices of different groups with lived experience of gambling and gambling harm, including family, friends and colleagues of people who gamble (affected others) are considered.
2. Evaluation Advisory Group
   This group will comprise researchers, academics and evaluators with expertise and experience in the field of gambling policy, research and regulation. They will provide independent assurance for key evaluation products and outputs, and assist evaluators in the anticipation and mitigation of risks and issues which may impact the evaluation.

Next steps

NatCen and the Gambling Commission will start reaching out to stakeholders in the coming weeks, with elements of evaluation fieldwork planned to begin in January 2025. Bryony Sheldon, Gambling Commission Director of Policy added in a blog post:

“The experience of consumers, operators and other stakeholder groups will be a key part of the evaluation in the coming months, as we welcome participation in surveys, interviews and other planned research. We will also use existing Gambling Commission advisory groups, and Industry Forum to both promote participation in the evaluation and help shape how we collect data efficiently.”

Several outputs of evaluation findings will be provided to DCMS and the Gambling Commission during and at the end of the evaluation to enable evidence-based insights in ongoing policy development and decision-making.

DCMS expect the evaluation to report in 2026.

Please get in contact with us if you have any questions regarding gambling regulation in Great Britain, the White Paper or the GAR evaluation plan.