A review by the Office for Statistics Regulation has exposed serious flaws in the Gambling Commission’s GSGB methodology and transparency, raising concerns that inflated gambling harm data may mislead policymakers and undermine evidence-based regulation – and many, analysts, Regulus Partners amongst them, do not believe the regulator’s response has been any better.
The Gambling Commission is under scrutiny from the UK’s statistics watchdog over concerns that its flagship reinvention effort, the Gambling Survey for Great Britain, may be overstating problem gambling rates and misleading policymakers. The Office for Statistics Regulation has published a thorough review of the GSGB after receiving complaints from stakeholders questioning the survey’s methodology and transparency – and it has sided very firmly with the complainants.
The OSR identified several areas requiring improvement and made four key recommendations to enhance the reliability of the survey. Concerns have been raised that the GSGB, which reports higher gambling participation rates than other official surveys, may be painting an inflated picture of gambling harm, potentially prompting misguided policy decisions.
Far from being shame-faced, the Commission played it cool. “We welcome the findings from OSR, both the public statement regarding casework they have received in relation to GSGB and their overall review of the GSGB,” said Ben Haden, the Commission’s director of research and statistics.
And in a somewhat remarkable response, the Commission, as is its custom, decided to spin the critical findings of the OSR, instead twisting its conclusions to present a picture of praise for the regulator’s work on the prevalence survey.
“We are pleased they recognise the huge amount of work that the team has put into developing and delivering the largest survey of its kind in the world. We also welcome OSR’s recommendations for further action, which closely align with work that we already have underway.”
A key concern is that the GSGB shows significantly higher levels of gambling participation and harm than the Health Survey for England. While the Commission attributes this to “social desirability bias”, critics argue that this claim lacks robust evidence.
Professor Patrick Sturgis, in a 2024 independent review, warned of a “non-negligible risk” that the GSGB “substantially over-states the true level of gambling and gambling harm in the population”, urging policymakers to treat its findings “with due caution”.
The OSR noted this caveat was buried in technical documents rather than featured in the main bulletins. It also raised transparency issues, including concerns about potential response bias and lack of coherence with other industry data. The Commission has begun implementing changes, including updated guidance and an experimental research project, with results due summer 2025 – but analysts Regulus Partners criticised its response.
“One would be hard-pressed to find any acceptance of [the] criticisms in the Gambling Commission’s statement on the review, which perceives nothing but praise for its endeavours,” they said “Instructed to remain open to challenge and feedback, the Commission ignores anything in the OSR’s analysis that smacks of censure.
“The OSR review is a golden opportunity for the Gambling Commission to do the right thing – to show that it has listened by acknowledging past missteps. Its initial response is not encouraging.”
So no chance there then; this is, after all, a regulator that acts with impunity.
So much so that this week, we have witnessed regulation in two of its most extreme forms: at its best, OSR regulation with an investigtive, analytical assessment, identifying flaws and delivering recommendations for revisions; at its worst, but audaciously funny – a response Gambling Commission style – a regulatory middle finger from one regulator to another.
At least now the Office for Statistics Regulation understands what the industry has to put up with.
