The key to white paper success? The industry pulling its weight

It’s easy to think the industry has a firm grasp on how it will be improved by the white paper’s proposals. For one, the 260-page government document was fairly detailed. And where it lacked in detail, it made up for in proposals few saw coming – like the appointment of a gambling ombudsman – which kept the conversation alight. 

It’s obvious that the Commission has a lot of work to do, to hold up its end of the bargain. But in order for the white paper to be delivered successfully, the industry also must be prepared to keep its nose to the grindstone, says Miller. 

“There’s a huge number of things that they’ll [the industry] need to deliver through the white paper,” he explains. “We talk a lot about what the Gambling Commission needs to deliver, and it’s a massive amount, but there’s an enormous list of things that the industry is going to have to deliver as well.” 

He says the Commission has tried to make this a smooth process where possible, being “very open” about what the industry can expect coming up. And this is paying off, he remarks.

“We try to share timetables as early as possible and it does feel now that lots of people are putting in the same direction, being really focused on delivering what government’s set out.” 

Beyond affordability checks 

But no amount of preparation and clarity can stave off the inevitable criticisms that come with a review of this breadth. Even before the white paper’s consultation process kicked off last July, rumblings emerged on its most controversial aspect – affordability checks, also known as financial risk checks. 

But the consultation topics aren’t the only important aspects of the white paper’s implementation process.

“Outside of the formal consultation responses themselves, we’ve had really good conversations with industry and other stakeholders,” explains Miller. “We’ve commissioned additional research around consumers to really understand their views and experiences of things. I think we’re in a really good place on consultations, but obviously there will be lots more work to come around.” 

So far, Miller says the Commission is “really pleased” with the engagement it has had from stakeholders. But with the regulator now knee-deep in the second tranche of consultations, when will these proposals be see the light of day?

Soon, says Miller – with a careful piloting stage in place, of course.

“We should be, over the coming weeks, getting more information about what the next steps are on a lot of those [consultation] issues, particularly around financial risk checks, and that we’ll be moving to pilot those to really understand what works well and what doesn’t.”

Omnipotent black market threat

Of course, white paper or no white paper, Great Britain’s black market thrums on. The Commission’s role in combatting the black market is complex, Miller poses, but comes down to three main aspects.

“The first is making use of our existing powers and approach,” says Miller. “So we continue, for example, to use cease and desist letters where we identify illegal websites and that’s had some success.”

The second strand relates to a Commission-specific white paper policy – the promise of additional powers to shut down illegal gambling offerings.

“The white paper gave a really clear commitment that we would be given additional powers to be able to seek to shut down illegal websites through the internet service providers,” Miller continues. 

“We were really pleased that, actually, space was found for those provisions in legislation that was already going through parliament. We hope that within a recent period of time we’ll be able to get those additional powers, which will strengthen what we can do.” 

Last but not least, strand three accounts for the bigger picture. Miller stipulates that the Commission has been working to bring European and North American regulators together, with a black market focus. But work has also been ongoing with some of the world’s largest technology companies, as part of a tactic to obliterate illegal gambling sites from all angles. 

“We’ve worked with the likes of Google and Facebook to try and reduce the visibility of illegal websites, to try and ensure that they don’t appear in people’s feeds and things like that.” 

Driving up standards

And this is only enhanced by the Commission’s work with international regulators. “When we’re trying to engage with those big technology companies that have a massive international presence, standing side by side with other regulators adds to our voice.” 

For Europe explicitly, Miller maintains that there is a positive working relationship between regulators on the continent, which is aided by centring the black market threat. 

“When I talk to European colleagues, everyone has the same focus on addressing the black market. I think this more collaborative, joined-up approach is going to really pay dividends because frankly it is one of those areas where we can more easily collaborate.”

And having one common enemy is a way to coalesce markets that, otherwise, have their own individual worries and concerns.

“There are other areas, say around safer gambling, where there are naturally different approaches in different countries,” Miller continues. “But when it comes to an illegal gambling black market, it feels like we’re pretty united on that.”

A mountainous year ahead 

Clearly, the Commission has a packed year ahead. Miller says the white paper – and its many proposals – will act as a channel for change throughout 2024. 

“The pace of delivering the white paper will continue to ramp up and that’s probably going to be the main vehicle in the UK where you’ll see continuous improvements to the way the consumers are protected.” 

“I think that the white paper provisions are so expansive that, actually, there’s not going to be much bandwidth for people to do much more than that,” Miller continues, re-emphasising a message he delivered days after the white paper’s release. 

But amid all this talk about the white paper, Miller has a critical message for the industry – do not forget yourself. 

“We constantly remind gambling companies that although the white paper is a huge piece of work, it can be quite distracting at times,” Miller concludes. “They shouldn’t lose sight of the existing regulatory requirements that are on them.

“We are continuing to hold them to account for meeting our regulatory expectations and our rules. If they don’t, we will continue to take action for that and I think that all continues to drive up standards in the industry.”