There’s a massive disconnect between Ivory Tower policymakers and the reality of the modern digital marketplace, and that’s no more evident than in the House of Lords Liaison Committee’s Gambling Harm – Time for Action follow-up report.
The committee has called for a blanket ban on gambling advertising “as soon as practicable”, arguing it’s the most effective way to meaningfully reduce gambling-related harm.
But blanket advertising bans and heavy-handed paternalism don’t eliminate demand – they simply blind consumers to the difference between safe, regulated environments and the predatory black market.
While protecting vulnerable people is a universal goal, trying to legislate away human risk through prohibition is a naive policy failure.
The issue, of course, is that both parties – the prohibitionists and the gambling industry – become protective and defensive of their respective position, and this leads to little in the way of sensible discussion, proper debate and, ultimately, sound policy decisions.
You only need to look back at how the recent increase in remote gaming duty to 40% played out – resulting in retail closures and slashed jobs – to see the real-world collateral damage of poorly thought-out, punitive policy.
With that in mind, I’m not going to spend the next 600 words just arguing against an ad ban, I’m going to do my best to be a champion of the consumer and a protector of the legal online gambling industry.
The uncomfortable truth
I have a long-held belief that the vast majority of casual players can’t spot subtle distinctions between a licensed operator and an offshore, unlicensed entity.
The danger of imposing marketing silence – sweeping up operators and comparison platforms like Comparasino in the process – is that you hand a monopoly of attention over to unlicensed actors that have zero regard for affordability checks, data security, dispute resolution and problem gambling support.
Transparent comparison sites and licensed operators are not marketing nuisances; they’re the frontline educators and security guardrails of the internet.
At Comparasino, we hand over large amounts of page real estate to responsible gambling messaging and to providing players with direct access to support organisations and tools should they feel the need to use them.
Consumers become Comparasino users – and, indeed, members – because they know we only work with Gambling Commission-licensed online casinos and bingo brands, and put them under no pressure to sign up and play.
Ban marketing and you strip away our ability to combat the black market. Right now, the SERPs are a war zone between Google, reputable affiliates and black market actors, with the latter deploying every dirty tactic imaginable to claim victory.
But one thing these organisations can’t do is run mainstream, out-of-home advertising. And that’s why we have chosen to invest heavily in TV advertising – not only that, we have also put responsible gambling messaging at the core of our campaign.
Challenging paternalism
At the root of the committee’s report is an outdated, patronising philosophy: the belief that gambling is an activity that should be “tolerated” but never “encouraged”.
That archaic mindset belongs in a mid-century licensing committee, not a modern digital economy. It treats adult consumers like children who lack agency, framing a normal leisure choice – no different from a night out or a trip to the cinema – as a moral failing to be managed by the state.
The vast majority of players know exactly what they’re doing, what they’re spending and why they’re doing it. They treat gambling as a budgeted, entertainment experience.
When policymakers adopt a stance of mere ‘tolerance’, they fundamentally patronise these consumers, reducing autonomous adults to potential statistics and viewing their personal disposable income through a lens of suspicion.
Of course, a minority of people do suffer from problem gambling, and that demands serious, targeted protection. But you can’t legislate, regulate or ban your way to a risk-free society.
Blanket restrictions and moral panics don’t eliminate human risk; they simply alienate the 95+% of the population who play responsibly while driving vulnerable individuals straight into the arms of an unchecked black market.
A viable alternative
So, if blanket bans and moralising ‘tolerance’ are failures, what does a sensible, future-proof approach actually look like?
Real consumer protection is achieved through collaboration, not prohibition. Instead of trying to choke off marketing and suppress the legal market, policymakers need to pivot toward three core pillars:
Targeted interventions over blanket bans: rather than silencing entire brands or treating all players like addicts, resources should back friction-free technological safeguards. Behavioural tracking, open banking analytics and early intervention tools can catch genuine harm long before it spirals, protecting the vulnerable without alienating the majority.
Empowering the educators: give licensed operators and trusted comparison sites the room to lead high-visibility consumer education campaigns. Make it effortless for players to identify safe harbour. The House of Lords report rightly revisits the idea of bringing affiliates under a direct licensing regime. It’s a proposal the industry shouldn’t fear – in fact, many responsible affiliates support it, provided it is implemented sensibly without becoming a cost-prohibitive barrier to entry for independent players. When trusted, accountable platforms have a clear badge of compliance and a real voice, and they actively channel traffic away from the shadows.
Crushing the black market: shift regulatory and legislative teeth toward actively dismantling illegal offshore operators that flout every standard of consumer safety. Right now, excessive restrictions on the legal sector inadvertently act as the black market’s best marketing tool.
The bottom line?
True protection isn’t achieved by pushing the industry underground or wrapping consenting adults in cotton wool. It’s achieved through brilliant, collaborative education, robust digital guardrails and a thriving, transparent legal market that people can actually see, trust and enjoy safely.
Martyn Hannah is the co-founder and CEO of Comparasino, an online casino comparison site for players in the UK. He is a former EGR editor and has more than a decade of experience in the online casino sector.
The post Prohibition is a policy failure: why ad bans play right into the hands of the black market first appeared on EGR Intel.
Martyn Hannah, co-founder and CEO of online casino comparison site, Comparasino, argues blanket marketing restrictions and outdated paternalism won’t eliminate gambling harm – they’ll just blind consumers to safe alternatives and empower offshore operators
The post Prohibition is a policy failure: why ad bans play right into the hands of the black market first appeared on EGR Intel.