Join date: May 17, 2022


very few of our witnesses were prepared to say that the Gambling Commission does a good job, with a fair balance between permitting gambling and protecting the licensing objectives; but the criticisms were predictably different, depending on the witnesses. For example, the criticisms from BACTA260 included: “fails to understand business … pedantic, disproportionate and dismissive … tendency towards regulatory creep … bureaucratic, unreasonable (particularly on time scales) and lacking in industry knowledge …”

A particular complaint was that “the Commission now interprets the third licensing objective to protect children and vulnerable far more widely than intended

On a natural reading of the principle it would indicate that there is a particular onus on considering for the purposes of the legislation, those who are identifiably and specifically vulnerable. That would include for example not only children but vulnerable adults such as those with learning difficulties, mental illness or affected by substance misuse.

The Commission currently reflects a view that everyone is vulnerable to gambling-related harm and therefore the entire population is covered by this principle. As a result policy proposals from the Commission that have, as their intent, the putative protection of the vulnerable, are applicable to the population as a whole—most of whom gamble perfectly safely …


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