• Submissions to Consultations
  • Submissions to Consultations
  • Submissions to Consultations
  • Submissions to Consultations
  • Submissions to Consultations

Together: We are one voice for everyone operating and supporting prize-led fundraising through lotteries.

Gambling Commission consultation on remote customer interaction requirements and guidance

The Commission consulted on stronger requirements to help ensure remote gambling operators do more to identify consumers who may be harmed by gambling and to interact and take action sufficiently early and effectively to prevent harm. As part of these new requirements, they proposed that online gambling operators must act on information they have about a consumer’s vulnerability, and to introduce stronger requirements, including that operators must conduct defined affordability assessments at thresholds set by the Commission. The Council’s response can be found here.


Gambling Commission consultation on the information requirements in the licence conditions and codes of practice (LCCP), regulatory returns, official statistics and related matters

The Commission is proposing to change the regulatory data that licensees are required to provide and offers an opportunity for stakeholders to comment on the proposed changes. The proposals seek to:

  • improve data quality and the efficiency of regulation
  • reflect their continued focus on consumers and social responsibility
  • ensure requirements are reconciled against their current and future data needs
  • streamline their existing requirements and, where possible, reduce regulatory burden.

The Council supports the intent and the general thrust of the proposals but has a number of specific concerns about the wording. The full response can be found here.

Gambling Commission consultation on amendments to the display of licensed status requirements in LCCP

The Commission is seeking views on proposals to amend the Licence Conditions and Codes of Practice (LCCP) to improve the consistency of their requirements for the display of licensed status on websites and to expand the requirement to non-commercial societies and local authority websites offering access to lottery tickets. The Council’s response can be found here.

Gambling Commission consultation on society lottery reform

The Commission has been consulting on the changes to the LCCP which are required as a result of the Government’s response to the DCMS consultation on the same topic. This fell into 2 parts: first the changes to the individual draw and annual sales limits (and the consequent changes to the prize limits); and second some additional requirements on society lotteries designed to make them more transparent. Although the limits announced by the Government, and to be incorporated into the LCCP, did not go as far as the Council had wanted, we saw the limit changes as a good first step. The Commission proposed a new social responsibility code, with which the Council had no problem. However, the Commission also proposed some guidance to go along with the code and the Council had a number of objections to sections of this guidance. The full response can be found here.

ICO Consultation on Direct Marketing Code

The ICO recently consulted on new code of practice for direct marketing. Although the Council was supportive of the principle of the code, there were a number of points of detail, where the code affected lottery operations, about which we had some concern. The Council’s response can be found here

CAP/BCAP Consultation on featuring children in lottery advertising

The Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP) became aware of a potentially disproportionate impact of their rules on lottery advertising, which can prevent some lottery advertisers from featuring the beneficiaries of their lottery funds in their advertising to an extent that may be overly strict, particularly children’s hospice lotteries. They consulted on proposed amendments to the rules to address this consequence while maintaining a high level of protection for young people. The Council’s view was that the effect of the proposed changes actually made little impact on the problem. The full response can be found here

Gambling Commission consultation on gambling with credit cards

The Gambling Commission have consulted over whether to prohibit the use of credit cards for all forms of remote gambling, including lotteries, and non-remote betting, or to introduce controls and limits on the use of credit cards instead of a prohibition. They also included an option to extend any prohibition or controls to non-remote lotteries.

The Council took the view that there was little evidence to support a prohibition on the use of credit cards for lotteries, whether remote or non-remote and that there were already perfectly adequate controls and limits applies by operators. Our full response can be found here.

Department for Digital, Culture, Media and Sport consultation on the minimum age for playing the National Lottery

The Department has been consulting on raising the minimum age for playing the National Lottery from 16 to 18. They make it clear that any changes to this minimum age will also apply to society lotteries. Three options were proposed:

Option 1​ - Do nothing, retain the minimum age of 16 for all lottery games

Option 2​ - Raise the minimum age to 18 for instant win lottery games (i.e. scratchcards and online instant win games)

Option 3​ - Raise the minimum age to 18 for all lottery games

The Minister at the time the consultation was launched favoured option 2. Details of the consultation can be found here and the Council’s response (favouring option 1) can be found here.

House of Lords Select Committee on the Social and Economic Impact of the Gambling Industry

The Select Committee published a call for evidence in July and invited submissions from all interested individuals and organisations. On lotteries specifically, it asked the following questions:

  • The restrictions on society lotteries were relaxed by the Gambling Act 2005, and there is concern that some of them are effectively being taken over by larger commercial lotteries. Is this concern well founded? If so, what should be done?
  • Should changes be made to the statutory regime governing the National Lottery, to bring it into line with the regime governing operators of other lotteries?

Details about the inquiry can be found here

Submissions were required by 6 September 2019 and the Council’s can be found here.

The Committee has now published all submissions and they can be found here

Digital, Culture, Media and Sport Select Committee

The DCMS Select Committee announced an inquiry into the future of the National Lottery on 19 July. They sought written evidence on six questions:

  • What lessons should be learnt from the previous license periods in designing, awarding and managing the fourth National Lottery licence?
  • Is there need for greater flexibility to enable the licence to respond to changing consumer habits?
  • How should the next licence be structured to maximise returns for good causes?
  • What challenges will the next operator of the National Lottery face, and what can Government and the Gambling Commission do to mitigate against them?
  • What has been the impact of society lotteries, or other changes to the lottery market, on the main National Lottery draw?
  • How can lottery funding distributors be better supported to manage changing trends in receipts for good causes?

Full details can be found here

Submissions were requested by 31 August 2019 and the Council’s can be found here. The Committee has started to publish the evidence received and this can be found here

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