Peter Hannibal: Is driving National Lottery revenues compatible with protecting the vulnerable?

Peter Hannibal Gambling Business Group National Lottery revenues
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Peter Hannibal, chief executive of the cross-sector strategic body, the Gambling Business Group, is calling on the DCMS and the Gambling Commission to explain how they propose to balance the drive to maximise National Lottery revenues and deliver high returns at the same time as protecting the vulnerable.


Speaking in the week the Gambling Commission invited prospective bidders to formally register their interest in competing for what will be the fourth licence to run the lottery since its inception in 1994, Peter Hannibal stated: “In a world where responsible and safer gambling measures are central to all gambling product delivery, surely the Commission has the same balancing act to manage as all of their Licenced Operators – on the one hand protecting the vulnerable, and on the other the key objective for the new licence which is to maximise revenues and funds to good causes?

“The DCMS has gone on record stating that in its view it is key to secure what it describes as a ‘robust competition’ that draws interest from across the sector and, I quote, ‘sees bidders incentivised to develop ambitious proposals that focus on driving high returns’.

“The National Lottery is regarded by many – including some in Westminster – as a national asset and it is therefore treated and regulated differently. Yet what is irrefutable is that it’s products are gambling products.

“The Gambling Commission’s own consultation document on Games Design states: ‘Innovation that is designed to encourage consumers to gamble more intensively, frequently, or by increasing amounts without regard to the consumer’s circumstances, appear at odds with the very concept of responsible game design.’

“The logic of this hypothesis prevents the winner of the next licence from developing products that extract more revenues from its existing customer base, unless they develop methods to understand their ‘consumer’s circumstances’. How will they do this in the supermarket and high street retail environments.

“If they can’t, this same hypothesis restricts the new National Lottery licence holder’s ‘ambitious proposals’ to increasing revenues and driving high returns only through encouraging new people to gamble in their products.

“The Gambling Commission is now in the awkward position whereby it needs to ask itself the very straightforward question that it asks of the industry: namely, can you genuinely protect the consumer whilst simultaneously aiming to maximise revenues and returns and how will you demonstrate it? Perhaps the Gambling Commission will now start leading the way in this area by explaining the answers in its’ own Annual Assurance Statements?

“The opportunity to use the licence competition to undertake some important regulatory house-keeping and protect consumers should not be missed. Key items such as the requirement to offer the Gamstop self-exclusion service, which is mandatory to all UK Licenced online operators, currently has an exception for the National Lottery. Why, should their consumers not be equally protected?

“National Lottery retail outlets are the only place you can legally gamble with a credit card. Once again, why are gambling sales via credit cards okay simply because there is a link to ‘good causes’?

“It is not ethical to insist on the player protections that are the responsibility of all online gambling operators in order to minimise harm, and to then make exceptions when it comes to the National Lottery.”

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