20 December 2023

Tackling Gambling Stigma’s Response to the Statutory Levy Consultation

Tackling Gambling Stigma’s Response to the Statutory Levy Consultation

Tackling Gambling Stigma’s Response to the Statutory Levy Consultation

In our submission to the DCMS levy consultation, we unpack the complexities facing the levy, outline our concerns and make recommendations for its structural refinement.

Our main concerns relate to the levy’s short-sighted focus, lack of overarching cross-departmental strategy, and neglect of a vital restructuring of the commercial dynamics of the gambling market.

Read the full report here: Response to the Statutory Levy Consultation 

Proposed Objectives: While agreeing with some of the proposed objectives, we argue that there are two key objectives missing from the consultation: (1) to use the levy as a lever for incentivising a socially responsible gambling industry and (2) developing infrastructure to address gambling harm.

Allocation of Levy Funding: We advocate for the allocation of levy funds to research, prevention, and treatment. However, we stress the need for an overarching cross-departmental strategy led by the DHSC, rooted in evidence, a theory of change, and high-level outcomes.

Levy Funding Distribution: We support allocating 10-20% for independent research but with caution. While welcoming the proposed Gambling Research Programme (GRP) led by the UK Research and Innovation (UKRI), we stress considerations for building excellence, diversity, and capacity as strategic objectives, including a diverse and thriving community and third sector.

Our key concerns and recommendations in our report are:

  • A Lever to Shift Gambling Company Behaviour: Gross Gambling Yield (GGY) is a starting point for calculating the levy but there should be a scale of GGY percentages against the degree of risk/harm for product categories.
  • Strategic Oversight: We advocate for a DHSC-led cross-departmental strategy to ensure systematic and coordinated action across the three commissioning groups.
  • Funding Allocation: Emphasises fair distribution in research funding, raising concerns about evaluation of the levy funding, and regulatory research not sitting within the regulator.
  • Community and Third-Sector Role: We highlight the need to strategically invest in the third sector to build it up, challenge existing perspectives, ensuring independent research and diverse community involvement.
  • Evaluation and Transparency: Advocates for transparency in the evaluation process, including independent researchers and stakeholders, and the sharing of accountability and evidence across the research.
  • Levy Board Role and Remit: We disagree with the proposed role and remit of the Levy Board. We advocate for a DHSC leadership and the inclusion of other relevant departments. We recommend limiting the Gambling Commission’s role to fund gathering, not distribution.
  • DCMS and HMT Approval of Levy Spending: Disagreement is expressed, echoing concerns from earlier points and emphasising the need for DHSC-led strategies and outcomes frameworks.
  • Robust Accountability Mechanisms: We stress the importance of health-led strategies accompanied by comprehensive outcomes frameworks, targets for various areas of harm, and the establishment of data and reporting systems to measure socio-economic costs.

For a deeper dive into these points, read our full consultation response here