Gambling Commission Research Says Available Information Is Not Informed Choice

The regulator asked players what "informed choice" means to them and found a gap between information being present and consumers feeling informed. The proposed definition puts rules, mechanics and risks on equal footing with promotions, and gives operators a duty that runs through play, not just before it.

• The Gambling Commission has published research by the Behavioural Insights Team, under its Consumer Voice Programme, on how consumers themselves understand "informed choice", according to the regulator's report as covered by NEXT.io and SBC News
• The study drew on a review of 53 sources, three deliberative focus groups and four in-depth interviews with players at higher risk of gambling harm
• Its central finding is that "availability alone does not create informed choice": information exists across licensed products but is hard to find, badly timed or obscured during fast-paced and in-venue play
• It proposes a consumer-led definition under which rules, odds, mechanics, costs and risks are presented "with the same prominence as promotions and rewards", and support adapts to a player's experience, capability and changing state
• The Commission says the work will inform a definition it is developing, and the report recommends behavioural mapping to turn informed choice into measurable indicators; it lands as the Commission phases in financial risk assessments and a Lords committee calls for an advertising ban

The Regulator Turns Its Own Definition Around

The Gambling Commission's regulatory framework defines informed choice through what operators must do: be transparent and fair. The new report, introduced by the Commission's strategy manager Donna Bateman and conducted by the Behavioural Insights Team as part of the regulator's Consumer Voice Programme under its 2024 to 2027 strategy, approaches it from the other side, asking what the concept means to the people expected to exercise it, according to SBC News and NEXT.io.

The method was a review of 53 sources, three deliberative focus groups and four in-depth interviews with players at higher risk of gambling harm. The finding that recurred across all of it, the Commission says, was a clear gap between information being available and consumers feeling informed. Information exists throughout a licensed offer, but participants said it was hard to find, presented unintuitively, or surfaced too early or too late. "Availability alone does not create informed choice," Bateman concluded, as SBC reports.

The report identifies four ways the current approach falls short. Information that is technically present becomes practically obscured during fast-paced or in-venue play. Operators take a static view of the consumer, not distinguishing beginners from experienced players, when respondents wanted onboarding and ongoing support treated separately. Products assume an odds literacy that many consumers lack. And respondents perceived operators as focused on administrative transparency rather than an active commitment to protecting higher-risk players.

"The concept of 'informed choice' is a key tenet of consumer protection and rights law, and at a basic level, it means giving the consumer the right information at the right time in a way they understand so they can make a genuine decision," Bateman said. "While many factors that support 'informed choice' are already understood, we wanted a deeper insight into what this means for gambling consumers, both as a concept and in practice."

Responsibility Moves With the Stage of Play

Participants described responsibility as shared, and as shifting. Before play, they were comfortable owning their decisions provided information was clear. During play, particularly in fast-paced products, they were more willing for operators to intervene. After play, some looked beyond the gambling sector altogether, to banks or other bodies with a view of total spend across platforms. The report's conclusion is that a consumer's capacity to hold responsibility depends on the stage of play, the product and their state at the time.

Personalisation was valued across the board, with generic messaging described as easy to ignore, but it came with a caveat: the same behavioural data that enables a tailored intervention also enables targeted marketing, and some respondents expressed "open distrust" of operators' motives in collecting it. Needs also varied by product. Sports bettors saw forced interruptions as a hindrance, casino players wanted active intervention during play, and land-based players reported that formal information was largely absent.

The report proposes a baseline definition in four parts: informed choice is the consumer's ongoing ability to understand and act on relevant information at each stage of play; it requires that rules, odds, mechanics, costs and risks are presented so consumers can genuinely understand and use them, with the same prominence as promotions and rewards; it requires that information and support adapt to the consumer's experience, capability and changing state, including an active commitment to those at greater risk; and it recognises that informed choice is shaped before play by the wider information environment and can be eroded during play by design, pace and emotional state. The Commission recommends further behavioural mapping to translate that into observable, measurable indicators.

"Same Prominence as Promotions" Is a Design Rule Waiting to Be Written

Most of the report is description. One line is a requirement in embryo: that the rules, costs and risks of a product be presented with the same prominence as its promotions and rewards. Every operator's acquisition funnel is built on the opposite asymmetry, and a regulator that adopts this as its definition of informed choice has a standard against which to measure a bonus banner next to a terms link. The Commission has not said it will write it into the Licence Conditions and Codes of Practice, and the report is careful to call the definition a proposal. But definitions are how this regulator starts, and the financial risk assessments now being phased in began the same way, as a principle looking for a mechanism.

The Research Concedes the Industry's Point on Personalisation, Then Turns It

Operators have argued for years that tailored messaging based on behavioural data is better protection than generic warnings, and the report agrees: generic messages are ignored, personal ones land. What it adds is the finding that consumers do not trust the data collection behind them, because the same signals feed the marketing. That is not an argument against personalised interventions; it is an argument that they will only be credible if the data is visibly used for protection first. An operator that wants credit for its behavioural tools now has a regulator's evidence that customers suspect the motive, and the fix is separation, not more messaging.

Land-Based Is the Sector This Report Names and the Commission Least Controls

The finding that land-based players reported formal information as "largely absent" arrives in the same fortnight as the machine games duty argument and a row over premises numbers. Online, the Commission can mandate a deposit limit prompt or a reality check; in a venue, information is a sign on a wall and a staff member's judgment. If informed choice is to be measured by whether the consumer can act on information at each stage of play, the sector with the least digital surface is the one with the furthest to go, and the one where the tools to close the gap are least developed.

The Commission has asked consumers to define the standard it will hold operators to. The industry should read the answer as a preview of the next set of requirements, not as a research note.