While the raw numbers from the 2024 UK Gambling Commission’s GSGB (Gambling Survey for Great Britain) suggest relatively modest year-on-year changes, the way they are being presented, and the uses to which they are being put by the anti-gambling lobby, could have far-reaching consequences for operators, campaigners and policymakers alike.
What Gambling Commission GSGB numbers say
The 2024 GSGB shows a decline in past-year participation, from 61.5% in 2023 to 59.6%.
“Problem gambling” prevalence, defined as PGSI scores of 8+, rose slightly from 2.5% to 2.7%, while moderate-risk gambling fell from 3.7% to 3.1%. For certain groups, harms appear to be easing: the proportion of gamblers reporting severe adverse consequences declined, particularly among women, where it fell 18%.
Serious financial harm indicators dropped by nearly a quarter, and more than halved among 18–24-year-olds.
However, other harms moved in the opposite direction. Reported rates of harm to “affected others” (such as partners, families and friends), including violence and abuse, increased.
These complexities are often lost in the headline framing: the figure that has dominated media coverage is the 2.7% PGSI rate, extrapolated to imply 1.4 million “problem gamblers” in Britain.
From caution to ‘official statistics‘
Until this year, the Gambling Commission had insisted on a health warning: GSGB survey data could not be scaled up to national totals due to methodological uncertainty. That caveat has now been removed, with the regulator describing the survey as “official statistics” and encouraging licensees to use the figures in risk assessments.
Melanie Ellis, partner at Northridge Law, believes this shift was a mistake: “It was premature of the UKGC to call these ‘official statistics’ and to take away the health warning, without sufficient scientifically rigorous testing to give confidence that the data is accurate,” she says.
Ellis stresses that while the commission was right to modernise its GSGB survey methodology, it failed to pause when early results diverged drastically from NHS health survey benchmarks. “The regulator blinkered itself to the impact these figures would have on the industry,” she adds.
Gambling Commission’s GSGC ‘an almighty headache‘
Dan Waugh, partner at Regulus Partners, is even more blunt. He describes the GSGB as the regulator’s HS2, an over-budget, politically committed project that cannot be reversed even if flawed.
“The survey has uncovered a previously unheralded huge degree of gambling participation overall. … It suggests a massive unlicensed market which was not picked up in the health survey. So, either the commission has not understood the market it is regulating, or it has let rampant gambling disorder flourish,” Waugh warns.
The removal of caveats, he argues, creates “an almighty headache for DCMS” as campaigners will now lobby ministers armed with the regulator’s own statistics.
“This will absolutely feed into the discussion on tax,” he adds. “You will see intense lobbying over further ad bans. And it will effectively have the GC’s badge on it.”
Bias, capture and sunk costs
Regulus’ own analysis frames the GSGB controversy as a case study in regulatory bias and institutional inertia.
The Gambling Commission, it argues, has shown a willingness to find vindication where none exists. Researchers at the London School of Economics conducted inconclusive experiments comparing survey modes, yet these have been cited as justification for lifting safeguards.
“The willingness of the commission to find vindication where none exists smacks of a prior bias,” Waugh wrote in an analysis sent to Regulus clients. “The alacrity with which some academic researchers have abandoned previously held views may indicate the presence of ‘in-group bias’ or worse.”
The problem is compounded by selection bias and self-reporting inconsistencies. Hard industry data on actual participation often fails to align with Gambling Commission GSGB responses. Waugh suggests in his written analysis that there are three possible explanations:
- The survey overstates gambling prevalence due to selection bias.
- There exists a vast unlicensed market previously undetected.
- Respondents misunderstand questions or answer inattentively.
None of these explanations, the consultant argues, inspire confidence that the GSGB can yet serve as a sound basis for policy.
Industry in denial?
Another theme emerging from Waugh’s critique is industry complacency. For years, operators have dismissed or downplayed research framing gambling as an “unhealthy commodity” akin to tobacco. By failing to engage seriously, they now face the risk of punitive tax rises and stricter controls.
“Within the next 12 months, UK Research & Innovation will start to distribute £20 million a year in levy funding, with gambling described as a ‘health-harming industry’,” Waugh notes. Without a coordinated response, the industry faces “over-taxation and over-regulation”.
Waugh suggests that operators have failed to mount a serious challenge. “The industry has just sat there and done nothing,” he says. “I can’t see that this will not negatively affect the industry.”
Black market blind spots
For Ellis, the critical missing piece is the role of unlicensed operators.
“If [the Gambling Commission] wants to assess whether player protection measures imposed on the licensed industry are effective, it urgently needs to be able to segment its GSGB data into customers using licensed and unlicensed operators,” she notes.
The commission has acknowledged this challenge but progress is slow. Without it, assessing whether regulatory interventions reduce harm risks becomes meaningless. Worse, restrictions on licensed operators may push consumers into the unregulated sphere, undermining protections altogether.
From survey to supervision
For licensees, the key issue is how the Gambling Commission GSGB will be operationalised. Commission CEO Andrew Rhodes has “strongly encouraged” firms to use GSGB data to assess risk within their customer bases.
Does this mean operators must assume that one in 10 online sports bettors are “problem gamblers,” as the GSGB suggests? If so, this would transform the expectations around customer monitoring and affordability.
Yet ambiguity persists. Ellis cautions that if the commission bases enforcement on GSGB-derived thresholds, “it must ensure that decisions are defensible and acknowledge methodological caveats”.
The politics of harm
The political consequences are already visible. The Guardian and other outlets have amplified the “1.4 million problem gamblers” figure, fuelling calls from campaigners for advertising curbs and affordability checks.
Ministers such as Culture Secretary Lisa Nandy have been attacked for not moving faster, while the Treasury eyes potential increases in Remote Gaming Duty.
For campaign groups, the GSGB is a gift: the regulator’s own data, stripped of caveats, can be used to push for prohibitionist-style measures. For operators, the risk is being judged and punished on contested statistics.
An unstable foundation
The GSGB represents a landmark for UK gambling regulation: a home-grown survey, positioned as the definitive evidence base. But critics warn it has an unstable foundation and is vulnerable to bias, misinterpretation and political misuse.
For Ellis, the task is ensuring accuracy and distinguishing between licensed and unlicensed activity. For Waugh and Regulus, the concern is deeper: that the commission has locked itself into a flawed survey, driven by sunk costs and institutional bias and, in doing so, has unleashed a wave of political and fiscal risks for the sector.
What seems certain is that the GSGB will dominate the debate for years to come. The challenge for the industry is not to deny its existence, but to engage critically, demand transparency and prepare for a regulatory environment shaped by numbers that – for better or worse – now carry the imprimatur of “official statistics”.
Gambling Commission’s GSGB has not only reshaped the conversation about gambling prevalence but also deepened a rift between regulator, industry and government.