The UK Gambling Commission has flipped the consumer insights playbook around, publishing its first study on what players understand as ‘informed choice’.
Introduced by Commission Strategy Manager Donna Bateman, the Behavioural Insights Team report forms part of the UK regulator’s 2024-2027 strategy to nurture a better gambling landscape in the digital age, which includes the collection of wider data sets focusing on consumer voices.
Contrary to the Commission’s current regulatory framework, which defines informed choice in relation to the transparency and fairness of operators, Bateman and her team have instead looked through the opposite side of the lens to understand how consumers themselves interpret the ‘informed choice’ concept when gambling.
The study analysed 53 sources, three deliberative focus groups, and four in-depth interviews with players at higher risk of gambling harm. One detail that consistently popped up across the insights team’s work was that participants identified a clear gap between information being available and consumers feeling informed.
This was largely caused by the fact that while information was available across gambling platforms, it was either difficult to find, presented in an unintuitive manner, or kept surfacing too late or too early.
The final conclusion? Availability alone does not create informed choice, according to Bateman.
Not all players are the same
To drive this point even further across, the study – through participant responses – managed to identify four main limitations to how the Commission currently defines a good information overlay.
While gambling-related information is technically available everywhere throughout a licensed offer, players have noted that it gets practically obscured during fast-paced or in-venue play.
Furthermore, the findings pointed to operators in large adopting a static view of the consumer, not distinguishing between beginners and experienced players – something that respondents found necessary to change given that there needs to be a clear separation between onboarding and ongoing support.
This also feeds into the next identified limitation, which is a general assumption by gambling firms that all consumers have an odds literacy, creating unnecessary gaps in available support and product complexity.
Something else flagged in the study was the respondents’ conception that gambling operators are focusing more on administrative transparency than the active commitment towards protection of higher-risk players.
Preferences emerge for shared responsibility model
Part of the findings were also made up of respondents’ perception of where the responsibility falls for their gambling behaviour – which was ideally seen as a shared model throughout the responses.
Prior to gambling, players were comfortable with owning full responsibility for their actions, given that the necessary information is readily available and clear to understand.
During play, they were more willing for operators to intervene on their behalf, especially in fast-paced contexts.
Once their play comes to a stop, some respondents looked beyond the gambling sector entirely, such as banks or entities that have a complete view of their total spend across platforms.
All of this led to the conclusion that the consumers’ idea of behavioural responsibility is shaped by the stage of play, the product used, and their own capacity to hold responsibility at the moment.
Don’t mix marketing with intervention
As hinted earlier with the beginner vs experienced player distinction, interest in a more personalised approach by gambling companies was also consistently valued across the board. Generic messaging, according to participants, is simply easily ignored.
However, a conflict arose here, driven by the fact that the same behavioural data used to offer an individualised intervention can also be used for targeted marketing – leading to an “open distrust” by some respondents when it comes to the motives behind collecting this data.
If the Commission decides to explore better ways to implement personalised interventions in the future, it should be aware that needs vary between the product types.
Bateman found that sports bettors saw forced interruptions as a hindrance, casino players instead required active interventions during play, while land-based players reported that formal information was largely absent.
Redefining the baseline of ‘informed choice’
Assessing the findings, the report proposed a consumer-centered baseline in how the sector and the regulator define ‘informed choice’ when implementing it in future work, which states:
- informed choice in gambling is the consumer’s ongoing ability to understand and act on the information relevant to their decisions at each stage of play;
- it requires that the rules, odds, mechanics, costs, and risks of a product are presented so that consumers can genuinely understand and use them, with the same prominence as promotions and rewards;
- it requires that information and support adapt to a consumer’s experience, capability, and changing state, including an active commitment towards consumer protection and those at greater risk of harm;
- 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.
