Gambling Advertising

Lord Foster of Bath Excerpts

Thursday 25th April 2024 Lords Chamber

Asked by

[Lord Foster of Bath]

To ask His Majesty’s Government what assessment they have made of the impact of gambling advertising, marketing and sponsorship on problem gambling, and in particular the risk posed by the exposure of children to gambling advertising.

[Lord Foster of Bath (LD)]

My Lords, I thank all noble Lords, including the Minister, who are taking part in this debate. I declare my interest as chairman of Peers for Gambling Reform, which was set up to press for the implementation of the recommendations made by the Lords committee on gambling. I am delighted that very many of those recommendations, either in whole or in part, were included in the Government’s White Paper. However, except for the Gambling Commission taking a closer look at bonus offers such as free bets and spins, and the Premier League’s voluntary ban on front-of-shirt gambling logos, the White Paper proposes very little action in respect of gambling advertising.

The Gambling Act 2005 liberalised gambling advertising, and now on Twitter/X alone there are 1 million UK gambling ads a year. Gambling companies’ annual spend on marketing now exceeds £1.5 billion. As the Lords committee noted, companies would not spend so much if it did not work, leading to more gambling and greater risk of harm. Yet very little action is proposed. Surely any Government should have been worried to read just this weekend in the Observer, under the headline “UK children bombarded by gambling ads and images online”:

“Young people feel their internet activity is overwhelmed by betting promotions and similar content”.


If the Government are not worried, other people certainly are. Opinion polls show that the vast majority of the public want a clamp-down on gambling advertising, including Conservative supporters. A very recent opinion poll found that 77% of Conservative councillors agree that tighter restrictions on gambling advertising would reduce gambling-related harm. With the Government doing very little, others are taking action. In March, Sheffield City Council joined over 80 other English councils in restricting gambling advertising on land, buildings, vehicles and even bus stops, websites and newspapers they own. The Mayor of London says that he intends to end gambling ads across public transport in the city. I hope he gets on with it quickly, as one gambling operator is currently advertising that TfL tube and train carriages are now casinos, with bus-stop ads saying: “Your bus is now a casino”. In sport, the absence of government action has led 35 football clubs to decide to go it alone and join the Big Step’s campaign to end gambling advertising in football. Can the Minister explain why the Government are so out of step with all these voices and seemingly so in step with the gambling industry?

I suspect public concern is about to rise because, in July, the Gambling Commission will release new figures about gambling harm. The Gambling Minister in the other place has already indicated that they are likely to show that 1.3 million people will classify as “problem gamblers” and that a further 6 million are at risk. If confirmed, these figures are far higher than those used to inform the Government’s work on their White Paper. This is a real cause for concern, further strengthening the call for action.

If public opinion does not persuade the Government, there are many other justifications for action, including research evidence. When he responds, I suspect the Minister may be somewhat dismissive of the research and claim—as the White Paper does—that it does not show a causal link between advertising and gambling harm. I am prepared to accept that this is largely true, but it does not mean that the research evidence does not support the case for greater action. Academics are clear that, in social science research, causal links are rarely even possible, but they are equally clear that the research findings justify a much tougher stance against gambling advertising. Some 50 academics recently called for “badly needed” restrictions on the promotion of gambling products. They drew attention especially to the unprecedented numbers of young people being exposed to gambling ads via the internet and television, and concluded that

“it has become quite clear that the gambling products being offered and the ways in which they are promoted are harmful to individual and family health and damaging to national life”.

Reviewing the evidence, the Advertising Standards Authority accepted that some studies were robust enough to support a link between advertising and gambling behaviour. The Government’s White Paper itself points to research showing that gambling advertising and marketing leads to people starting to gamble, to gamble more and to recommence gambling. With all this evidence, it is bizarre that the Government are not taking more action.

Unlike us, other countries do not seem to struggle with the evidence, despite having far less of it. Ipsos and researcher Dr Rossi have identified 496 published research papers about gambling marketing here, which is more than the combined number of similar ones in Belgium, the Netherlands, Italy, and Spain. Yet on their evidence they have chosen almost full bans on gambling advertising and sponsorship. Can the Minister explain why the UK Government’s assessment of our evidence is so different from neighbouring countries with similar research findings? Does the Minister really believe that there would be 1.3 million people classified as problem gamblers in the absence of gambling advertising?

Frankly, our Government seem confused. In one breath, they say that action is not justified because there is little causal evidence linking advertising to harm but, in another, without causal evidence, they welcome the removal of gambling logos on the front of football shirts as a harm-reduction policy. The Government’s position simply does not make sense.

The Government have accepted that gambling-related harm should be treated as a public health issue, so they should be adopting the precautionary principle and, on the huge weight of evidence, taking greater action. Yet, the Minister in the Commons said, on advertising causing harm, that,

“if new evidence suggests that we need to go further, we will look at this again”.—[Official Report, Commons, 13/3/24; col. 142WH.]

Can the Minister explain what more the Government need before they will act?

I believe that a public health approach to gambling should lead to significant curbs on advertising and a ban on direct marketing, an end to inducements such as so-called free bets, and the removal of gambling sponsorship in sport.

Time does not permit me to detail all that I think should be done. Noting that estimates suggest that as many as 60,000 children suffer gambling harm, I will end with just one area where I believe urgent action is needed: so-called content marketing, which a Guardian headline recently described as “‘Sneaky’ social media ads … luring young into gambling”. Just one example will suffice. A social media post with the heading, “When the barman asks if you want another one”, is followed by a photo of Liverpool manager Jürgen Klopp giving a thumbs-up. That is all there is to it.

This simple, humorous post was by Paddy Power, but there are literally hundreds of them, using cartoons and famous people, posted online by gambling companies all the time. In just one weekend, online gambling ads received 34 million views. Over half were content marketing. Research shows that such posts are particularly appealing to young people and that followers of gambling companies’ online posts are, disproportionately, young people.

Yet the voluntary code governing advertising says that advertisements should be clearly seen as such. I have met with the ASA, which oversees the code, and shown it numerous examples of content marketing that clearly breach the code. So I hope the Minister will agree that the time has come for a complete review of the code and its enforcement, including deciding whether self-regulation really is the right approach.

It is worrying that so many young people know the names of gambling companies, follow them online, think that gambling is part of growing up and see it as part of the enjoyment of sport. Gambling advertising encourages more people to gamble and to develop gambling harms. The figures are alarming, as are the consequences to individuals and our society. The threat to our children should be enough on its own to compel the Government to act. No primary legislation is required, as the Gambling Act 2005 gives the Secretary of State all the powers she needs to regulate gambling advertising as she sees fit. So my simple question is: will the Government get on and do something?

--- Later in debate ---

[Lord Parkinson of Whitley Bay (Con)]

I am grateful to the noble Baroness, and I hope what I have said is none the less helpful in relation to the points she raised in her speech, which I welcome.

We recognise that there is good evidence to show that gambling advertising can have a disproportionate impact on those who are already experiencing problems with their gambling, and that some aggressive marketing practices are particularly associated with harm. The noble Lord, Lord Trevethin and Oaksey, mentioned a study which reflects that.

Evidence from the Gambling Commission shows that 35% of problem gamblers received incentives of offers to gamble daily, compared with 4% of non-problem gamblers. Furthermore, while 10% of gamblers with a “non-problem” or “low-risk” score—according to the problem gambling severity index—were influenced to gamble more by direct marketing, this rose to 41% among those with a “moderate risk” or “problem gambler” score.

We also recognise that content often used in gambling advertising can inappropriately appeal to children and young people—the right reverend Prelate the Bishop of Derby raised such an instance. That is why we have introduced a suite of measures to further prevent potentially harmful impacts of advertising, specifically for children. Since October 2022, advertising rules have been strengthened to prohibit content that downplays the risk or overstates the skill involved in betting. The rules also ban content that is likely to be of strong appeal to children. In that regard, I will raise with officials the frog-based example that the right reverend Prelate gave. As a result of this ban, top-flight footballers or celebrities popular with children are banned from being in gambling adverts. In line with existing gambling advertising rules, the Premier League’s decision to ban front-of-shirt sponsorship by gambling firms will commence by the end of the 2025-26 season, breaking the direct association between gambling brands and popular players.

The noble Lord, Lord Trevethin and Oaksey, suggested that there should be warnings to potential players on gambling adverts. Robust Advertising Standards Authority rules prevent content and adverts that, for instance, promote gambling as a route to financial success, and adverts on television must direct people to available support services. We are also working with the Department of Health and Social Care and the Gambling Commission to develop independent information campaigns about the risks of gambling—taking that out of the hands of the industry.

[Lord Foster of Bath (LD)]

I apologise for interrupting the Minister, but I find it difficult that he stands at the Dispatch Box and talks about all these rules, when I gave a specific example of a Paddy Power advertisement—although it is not called an advertisement—that simply had a large photograph of the Liverpool manager, Jürgen Klopp. Does he believe that was a correct thing for Paddy Power to do, or should it have been banned?

[Lord Parkinson of Whitley Bay (Con)]

Well, as with the case that the right reverend Prelate raised, I will take that up with officials. I was spelling out some of the actions—some of which are still to come in. As I said, the Premier League rules will come in by the end of the forthcoming season. I am sure the noble Lord will reflect that some of the work has been done and some is coming shortly, but I will raise the case he mentions with the team at the department.

As we set out in our White Paper, we are also working closely with the Gambling Commission to take targeted action on advertising to ban harmful practices and ensure that it remains socially responsible, wherever it appears. The commission has recently consulted on new rules to give consumers more control over the direct gambling marketing that they wish to receive, and on strengthened protections to ensure that free bets and bonuses are constructed in a way that does not encourage excessive or harmful gambling. The commission will set out its responses to these consultations soon. Together, these measures will empower customers and prohibit harmful marketing practices, to prevent the risk of gambling harms.

The noble Baroness, Lady Bennett of Manor Castle, referred to the powers available to local authorities. As she reflected, these vary from local authority to local authority, but, as we heard in the debate, the metro mayors in London and Manchester are using the powers that are available to them.

There is no single intervention that provides the answer to effectively preventing gambling-related harm. That is why we have taken a holistic approach that includes action on products and protections for players. We recently announced the introduction of stake limits for online slot games, where we have seen evidence of elevated levels of harmful gambling, and are pursuing broader protections, such as financial risk checks that will require online operators to identify and take action in relation to customers who are financially vulnerable. That will prevent runaway losses, which we are still seeing happen too often. The Government are clear that effective and innovative collaboration to get the right mixture of interventions for the population as a whole—as well as those with specific needs or vulnerabilities—is required to tackle gambling harm.

A key part of that approach is the Government’s decision to introduce a statutory levy, which I know has been a long-standing priority for the noble Lord, Lord Foster, and which the noble Lord, Lord Bassam, and others raised. In his opening remarks, the noble Lord, Lord Foster, dwelt on the importance of evidence. Perhaps I should end my remarks by acknowledging that further work is needed to build the evidence base to ensure that policy and regulation are able to deal with emerging issues.

In response to the contribution from the noble Lord, Lord Bassam, I make clear that developing quality evidence is a priority for our statutory levy. Through the levy, increased and ring-fenced funding will be directed towards high-quality, independent research into gambling and gambling-related harms, including in relation to advertising. We will continue to monitor the evidence base and, if new evidence suggests that we need to go further, we will look at this again. The Government will also respond to their bespoke consultation on the levy and will set out their final decisions very soon.

I thank the noble Lord, Lord Foster of Bath, for tabling today’s debate and all those who have spoken in it. I am certain that we will return to this topic again before long.

Media Bill

Lord Foster of Bath Excerpts

2nd reading
Wednesday 28th February 2024 Lords Chamber

[Lord Foster of Bath (LD)]

My Lords, this has been, as usual, an interesting and incredibly well-informed debate. But it has presented us with a significant problem. Many noble Lords have spoken about the urgent need to get on with the Bill as quickly as possible. At the same time, many suggestions have been made about areas in the Bill that require improvement, including the very important issue raised by the noble Lord, Lord Forsyth, about which we are very sympathetic, as my noble friend Lord Storey has already pointed out. I hope that the case for speed will not lead to justifiable concerns being brushed aside. After all, the previous Bill is 20 years old, and we may have to wait a further 20 years for another Bill. It is vital that we get this one right and ensure, as far as possible, that it is future-proof.

I echo the words of the noble Lords, Lord Birt, Lord Hall and Lord Vaizey, and, it would appear, Joni Mitchell. Nowhere is this more important than ensuring the long-term security of our public service broadcasters, from which we all benefit, and which help to drive our enormously successful creative industries. Our understanding of what was expected of a PSB was very clear in the 2003 Act. Unlike the noble Lord, Lord Bassam, and, I think, the noble Lord, Lord Vaizey, who appear to be welcoming the streamlining—as they put it—of the PSB remit, many other noble Lords, including my namesake, the noble Baroness, Lady Foster, and the noble Lords, Lord Hall and Lord Russell, the right reverend Prelate the Bishop of Leeds, and all of those on these Benches, have a different view.

We believe that the Bill is much less clear about what is expected from a PSB because changes to Section 264 of the 2003 Act will remove the Reithian values of inform, educate and entertain. They remove many of the genres expected to be covered, from music and the arts to science and religion. All we now have is, as the noble Viscount, Lord Colville, said, the vague requirement of a range of appropriate genres. In response in the other place to similar concerns, the Government argued that it is in the royal charter for the BBC and in the licences for the other PSBs that such expectations will be covered. But can the Minister confirm that Parliament has absolutely no say on those documents? If Parliament is to have a say on what it wants of PSBs, surely we should look again at this issue.

The Government have also argued that Ofcom will cover this by looking at the delivery of genres across all platforms. Can the Minister confirm that the Bill provides no statutory duty for Ofcom to do this, as I believe it should? Does he also agree that, without specifying genres, it would be very difficult for Ofcom to do the necessary monitoring?

A further example that many noble Lords have touched on where there is a need for future-proofing in the Bill is in respect of radio. I suggest one small addition that I believe we should consider: to keep pace with the change in listening habits, the legislation should be extended to cover those issues that have already been raised. These include: non-broadcast online content, such as catch-up radio; online-only radio stations; podcasts; and the issue raised by the noble Lord, Lord Hall, of in-car radio.

Many noble Lords have raised the vital importance of prominence across all platforms. At a later stage I will be asking questions about the implications of the proposals. I wonder, for example, whether TV remotes, such as my current one, will still be allowed to have a large Netflix button without a PSB one. Much more importantly, if Ofcom is to be the guardian of prominence, it needs a very clear steer from Parliament about what Parliament intends. We share the view that “appropriate” prominence will not help Ofcom. The right reverend Prelate may also be right that “significant” prominence is not the right word either. I hope that we will get together and find the appropriate language so that Ofcom knows what it is that your Lordships and Parliament want.

We also welcome the proposals to update the listed events regime, as my noble friend Lord Addington said, along with others, including the noble Lord, Lord Hall, and the noble Baroness, Lady Grey-Thompson. There is a need for the regime to be further extended so that audiences can view time-shifted content on PSB video on demand platforms.

A House of Commons Library briefing explained this very clearly back in February 2023. It said:

“If for example the Olympic 100 metre final was broadcast live in the middle of the night on the BBC, but all streaming and catch-up rights were sold to a different broadcaster and kept behind a paywall, then a culturally relevant event might not be available to a wide audience on a free-to-air basis”.


I hope the Minister will consider supporting amendments to cover this concern.

I was very taken with the speech by the noble Lord, Lord Bethell, on minimum standards for child protection. He made a very powerful case. He argued that we should not be relying on the good will of the numerous VOD platforms; nor should we rely on Ofcom. I noted his remarks. He said that it should be our job as legislators to set the rules of the game and the job of Ofcom to referee the match. I do not think any of us would disagree with that. We certainly believe in that, and we will work with him to ensure that some minimum standards are on the face of the Bill.

Many noble Lords referred to Ofcom. I confess that I am not quite as sanguine as the noble Lord, Lord Vaizey, about Ofcom’s ability to take on yet more responsibilities. After all, it has become something of a dumping ground for all the regulatory duties that have been incrementally imposed on it since it opened its doors back in 2003—all on top of its core functions around spectrum allocation and the monitoring of content. I certainly believe that we should be considering dividing this unwieldy behemoth into two regulatory bodies, one devoted to infrastructure and one devoted to content—but that is for another Bill at another time.

Given Ofcom’s huge responsibilities, and given that there is so much that it has to do, it is not surprising that even tonight concerns have been raised about, for example, its ability to cope in relation to its regulatory approach to the new breed of opinionated news channels, such as GB News. Does Ofcom have the resources and competence to carry out its additional responsibilities? What can the Minister tell us about additional resource allocations to Ofcom to fulfil these further responsibilities?

One other point that we will certainly press is that, however illustrious its current and previous chairs have been—and it is lovely to see the noble Lord in his place—there is a legitimate disquiet over Ofcom’s independence from government. Whether true or not, perception matters. We believe that the time has come to overhaul the appointment process to ensure that Ofcom is wholly independent and transparent, and we will move amendments to this effect.

It is well known that, on these Benches, we opposed the privatisation of Channel 4 and were incredibly pleased when the Government backed down. But we have some concern about the proposal which will enable Channel 4 to produce in-house programmes, as it could end up undermining the very basis of Channel 4 to support, especially, new and up-coming media companies—the indies—as it has so successfully done over many years. While Channel 4 has suggested that it will not immediately go ahead with in-house production, I hope the Minister will agree that, if and when it does, there should be a quota of minimum qualifying spend still going to SME indies.

On Part 4, several noble Lords have commented on the proposal to repeal Section 40 without any alternative proposal. On these Benches, we disagree with the noble Lords, Lord Hunt and Lord Black, and we agree with the noble Baroness, Lady Hollins, the noble Lord, Lord Watts, the right reverend Prelate, the noble Lord, Lord Lipsey, and others, who want Section 40 not only retained but implemented. Doing so would guarantee access to justice to the public and incentivise press membership of a truly independent regulator, thereby ensuring no backsliding into unlawful and unethical press practices of the past. Perhaps most importantly, it would protect newspapers from chilling and meritless litigation, otherwise known as SLAPPs. The case to retain and implement Section 40 is overwhelming, and we will pursue it in Committee.

This is a necessary and important Bill, but changes are needed, and we will seek to make such changes during a later stage—but we will commit to doing so as quickly as possible. Given, as my noble friend Lord Storey pointed out, we have a Minister who truly gets it, I am confident that we can quickly agree to such changes and rapidly get this much-needed Bill on to the statute book.

BBC: Royal Charter

Lord Foster of Bath Excerpts

Monday 15th January 2024 Lords Chamber

[Lord Parkinson of Whitley Bay (Con)]

The BBC is indeed a beacon that shines brightly around the world, reflecting British values and doing great credit to us as a nation. I pay tribute to the noble Lord for the work that he did at the corporation. However, since he left, we have seen the number of people paying the licence fee falling. It has fallen by 1.7 million people over the last five years. Therefore, as well as ensuring that there is a fair settlement that gives the BBC the money that it needs and is fair to the people who pay the licence fee, we are looking at the funding model to ensure that the BBC is able to continue to get the income and to shine brightly as a beacon in an increasingly competitive media landscape.

[Lord Foster of Bath (LD)]

As the noble Lord, Lord Dubs, has implied, the biggest threat to the BBC’s news and current affairs is from this Government. After the level of cuts that we have already heard about and last year’s two-year freeze on the licence fee, the Government did at least promise an inflationary increase in the licence fee for this year. Will the Minister now acknowledge that the Government have also broken that promise by giving an inflationary rise that is much lower than was anticipated, saving British households the equivalent of one egg per month while causing the BBC to have to have a further £90 million in cuts? How does that ensure that the BBC will continue to be the most trusted international provider of news across the world?

[Lord Parkinson of Whitley Bay (Con)]

The increase has been calculated based on the annual rate of CPI inflation in September. That is the same measure that we use for the increases to the pension and to those in receipt of benefits. It ensures that the BBC can get income from the licence fee while being fair to those who pay it at a time when household budgets are also hard pressed. That money delivers the BBC more than £3.8 billion per year. It is for the BBC to decide how it carries out its obligations as set out in the royal charter.

Loot Boxes in Video Games

Lord Foster of Bath Excerpts

Wednesday 13th December 2023 Lords Chamber

Asked by

[Lord Foster of Bath]

To ask His Majesty’s Government what measures they are planning to take to mitigate the risks caused by loot boxes in video games.

[Lord Foster of Bath (LD)]

My Lords, in begging leave to ask the Question standing in my name on the Order Paper, I declare an interest as chairman of Peers for Gambling Reform.

[The Parliamentary Under-Secretary of State, Department for Culture, Media and Sport (Lord Parkinson of Whitley Bay) (Con)]

We welcome new industry-led guidance to strengthen player protections in relation to loot boxes. We have agreed a 12-month implementation period, during which we expect the industry to work with players, parents, academics, consumer groups and government bodies to implement this guidance in full. We are working closely with academics to support independent scrutiny of these new measures, and we will provide further updates and keep under review our position on possible future legislative options.

[Lord Foster of Bath (LD)]

My Lords, I thank the Minister for his reply. There is a very long list of those calling for tougher action on loot boxes, which computer games players purchase to have a random chance of getting items to help them win—each an expensive gamble. The Government’s own research review showed a

“consistent association between loot box use and problem gambling”,

yet they still leave parents and the games industry itself to deal with these problems. The Select Committees in both Houses and many other people believe that loot boxes should be treated and regulated as gambling. Can the Minister explain why the Government rightly regulate the gambling industry but do not regulate loot boxes, which cause similar harms to individuals and society?

[Lord Parkinson of Whitley Bay (Con)]

Research has provided evidence that loot box purchases may be linked to a variety of harms. In particular, there is robust evidence of an association with problem gambling, as the noble Lord mentions, but research has not established whether a causal relationship exists. There are a range of plausible explanations. We have developed and published the video games research framework to support high-quality, independent research into video games, including into loot boxes. If new evidence becomes available, we will consider it.

BBC Funding

Lord Foster of Bath Excerpts

Tuesday 12th December 2023 Lords Chamber

[Lord Parkinson of Whitley Bay (Con)]

As we know from previous exchanges, there is the immediate decision about licence fee increases and the settlement that the Government reached with the BBC at the beginning of 2022—which saw the two-year freeze to help house- holds at the time—and the longer-term questions which are right to ask to make sure that we are funding the BBC in a sustainable way, so that it can continue to do important work in the decades to come, which are going to look very different from the BBC’s first century.

[Lord Foster of Bath (LD)]

My Lords, many of us despair at the way in which the Government praise the BBC and yet constantly undermine it. In terms of future funding, is the Minister aware that your Lordships’ Select Committee looked at this and rejected a straightforward advertising funding model on the grounds that it would not provide enough funding for the BBC and would damage other public service broadcasters. It also ruled out a sponsorship funding scheme as well. Will the Government rule out those two options and accept that guaranteeing the universality of the BBC will always require some form of public funding?

[Lord Parkinson of Whitley Bay (Con)]

I do not agree that providing the BBC with more than £3.8 billion is undermining it. That is a large amount of money for the BBC to do its important work. The noble Lord is right to draw attention to the work of your Lordships’ Communications and Digital Committee. I know that my noble friend Lady Stowell of Beeston would have liked to be here for this exchange, but the committee is on an external visit today. We will, of course, engage with her and the ideas and work of the committee. As I say, the future funding review will look at such matters as we weigh all that up and make decisions about the best way to provide the BBC with the sustainable income it needs.

Creative Industries (Communications and Digital Committee Report)

Lord Foster of Bath Excerpts

Friday 7th July 2023 Lords Chamber

[Lord Foster of Bath (LD)]

My Lords, I, too, serve on the Select Committee and pay tribute to the noble Baroness, Lady Stowell, for her chairmanship and her excellent speech. I will avoid making any comment on the allegations of her frugality. I join her in thanking our excellent staff and in paying tribute to my noble friend Lady Featherstone, because it was her debate in November 2021 on government policy, funding and attitudes towards the creative sector that was a catalyst for the committee’s inquiry. Many of us in that debate—and the noble Lords, Lord Lipsey and Lord Berkeley, and others today—concluded that while both past and present Governments talked up the importance of the creative industries, they failed to understand them and their specific needs.

The noble Lord, Lord Vaizey, rightly pointed to some important lifelines given to the sector during Covid. I have praised the Government for that on several occasions. However, even while trying to help, the Government’s limited understanding of the sector resulted in, for example, a furlough scheme that failed to address the needs of the high number of part-time and self-employed people in the sector. As a result, as we heard in a recent debate, 38,000 such people left the sector in 2020.

A similar lack of understanding has led to the ill-suited apprenticeship scheme we have heard about and a Brexit deal that has damaged touring musicians and many organisations which previously benefited from talent from other European countries coming here, as the noble Lord, Lord Berkeley, reminded us. Since the noble Earl, Lord Clancarty, referred to architecture, it is worth reminding ourselves of a very recent survey which showed that 90% of architectural firms believe that Brexit has harmed their practice.

The committee’s report also argues that the Government are overly complacent about the contribution that the creative industries make to our economy. It was, indeed, a wake-up call. As others have indicated, judging by the response, the Government have, at least in part, listened. Certainly, there is much to welcome in the sector vision. Like the noble Baroness, Lady Stowell, and others, I particularly welcome the decision to ensure the continuation, with further funding, of the creative industries clusters.

An important part of the report which many noble Lords have picked up on addressed the acute skills shortage in the sector, which, frankly, is the biggest inhibitor to growth. The sector vision does at least recognise the problem, and it contains some welcome proposals, including—as we recommended—improved careers advice and improvements to the apprenticeship scheme.

However, we know that evaluation of the flexi scheme concluded that it was not flexible enough and that employer costs were unsustainable. The sector vision promises to “improve creative apprenticeships” but, frankly, gives no detail. Like others, I ask the Minister to say more about this welcome commitment without throwing out the baby with the bathwater, as was raised in the debate.

There are other issues that need to be addressed. As I have mentioned, we have debated the sector’s reliance on part-timers and freelancers. Given that so many left during the pandemic, it makes sense to look at ways to resolve the issues that caused them to leave and so help future retention. In that debate, I raised two issues but got no response at the time, so I hope the Minister can respond when he winds up.

The first was the current benefit scheme, which, as many of us know, was not designed for the tax and employment status of freelancers. What are the plans to address this and ensure their entitlement to protections, such as parental leave and sick pay, that full-time employees already have? Secondly, on tax, following the decision to drop plans to reform IR35, what will be done to develop a tax system that can unlock the agility of freelance work?

The key solution to meeting the skills shortage lies in our schools, colleges and universities. Here I address what the noble Baroness, Lady Bull, called the Government’s “blind spot”. The sector vision promises:

“We will build a pipeline of talent into our creative industries, from primary school to post-16 education”.


It specifically, and critically, acknowledges:

“The sector increasingly relies on a fusion of creative and STEM … skills”.


Many of us have been saying that for years, not least my noble friend Lady Bonham-Carter, who, like many others, repeated that again today. The noble Baroness, Lady Rebuck, and the noble Lords, Lord Vaizey, Lord Berkeley and Lord Watson, my noble friend Lord Clement-Jones and the noble Earl, Lord Clancarty, all said that we need STEAM not STEM.

However, our report says that

“there are too few incentives for students to study a combination of creative and STEM subjects”.

As noble Lords have said, the main culprit is the failure of the schools’ EBacc to include art or design components, sending a message that creative knowledge and skills are not a route to jobs.

Numerous figures have been cited. The Select Committee, for example, notes that, since the introduction of the EBacc in 2010, there has been a 70% decline in GCSE entries in design and technology and a 40% decline in other creative subjects. This means that A-level entries have also declined, which hardly helps to meet the acknowledged need for a fusion of creative and STEM skills. However, as again we have heard, the Education Minister told the committee that there are no plans to change the EBacc. Surely the Minister acknowledges that the Government need to rethink this.

There is some hope with the advent of T-levels, but the situation in higher education is equally worrying. Echoing what was said by the noble Lord, Lord Watson, and the noble Earl, Lord Clancarty, one witness told us that there is

“worrying rhetoric about creative degrees being low value”.

It is hardly surprising, therefore, that courses have closed and that student numbers decline.

Our Select Committee believes, as my noble friend Lady Bonham-Carter mentioned, that the basis on which the Office for Students developed the measurement of low-value courses was badly flawed. Despite our recommendation that the measure be revisited, the Government’s response was a stonewall defence of the current arrangements. I hope the Minister will acknowledge that the skills gap is not helped if fewer and fewer students pursue creative courses at university. Frankly, I am at a loss to understand why this Government, as they acknowledge the need for a fusion of creative and STEM skills, seem determined to prevent it happening.

I agree with the noble Lord, Lord Berkeley, the noble Earl, Lord Clancarty, and other noble Lords who have argued that, if we are to have successful arts courses in our educational system, we need the arts themselves to flourish, yet many provider organisations are facing cuts and uncertainty, as we have heard. Frankly, it is likely to get worse. I will give just one example of why. Local councils are the biggest funders of arts and culture in England, yet just this week—two days ago—the LGA announced that councils are struggling to fill a £3 billion black hole caused by inflationary costs and soaring demands for their services. In such circumstances, councils will have less to spend on discretionary functions such as funding the arts. I hope the Minister’s department is making representations to secure a better funding deal for our councils.

Finally, I turn to another key issue in the report: the crucial importance of a robust intellectual property framework to underpin the creative industries, ensuring financial recompense for those working in them. As others have said, we have a world-renowned IP framework, but, as the report points out, there are many new challenges to it, and my noble friend Lord Clement-Jones described a number of them.

I pick up just one: the development of AI, which of course offers huge opportunities but also challenges. He referred to the IPO abandoning plans for the damaging exception to copyright for text and data mining purposes—again, something recommended in our report. I hope the Minister will agree that there should be no new copyright exceptions in relation to AI. The development of AI models means that a great deal of content has to be ingested. In many cases, the developers are seeking permission from the creators to use this content and pay for licences, and that is of course welcome. However, I understand that some of the larger AI developers, often household names, believe that they do not have to seek permission or licences, claiming exceptions to avoid paying for content. This is a very live issue, as illustrated by the recent application by Getty Images for a High Court injunction to prevent Stability AI selling Stable Diffusion in the UK, claiming copyright infringement in the training process of Stable Diffusion.

I hope the Minister, on behalf of the Government, will be prepared to agree that, on a point of principle, those large developers, which are likely to make many billions of pounds from their services in the next few years, should license the content that they are ingesting. Will he make sure that those businesses are told so in no uncertain terms, and at the same time ensure that they understand that they are going to be required to keep accurate, detailed and transparent records of all the data they ingest?

It has been a fascinating debate, with many important contributions. It is the time of year for the school report, and on the creative industries my report for the Government would read something like, “Gaining a better understanding, about which we are pleased. Making good progress but with many outstanding issues”—such as reforming the Ebacc, expanding eligibility for R&D tax credits, and increasing support for freelancers. There is still no room for complacency.

Arts and Creative Industries: Freelancers and Self-employed Workers

Lord Foster of Bath Excerpts

Thursday 15th June 2023 Lords Chamber

[Lord Foster of Bath (LD)]

My Lords, as we have heard, the creative industries have a particularly large number of freelancers and self-employed workers. Some patchy help was given during the pandemic, but 38,000 freelancers still left the sector in 2020. Those remaining have to cope with cost of living increases, fluctuating funding streams—often offering money to organisations and not individuals—and numerous challenges created by Brexit, often on low pay. For example, freelance visual artists earn £12,500 per annum on average, yet they get very little help.

Many of us argue that the apprenticeship levy scheme was inappropriate for the sector’s freelancers. Eventually, the Government piloted a flexi-scheme, but its evaluation concluded that it was not flexible enough and that employer costs were unsustainable. The sector vision, just published, states that the Government plan to improve creative apprenticeships. Can the Minister say more about this welcome commitment?

Just as the apprenticeship scheme is inappropriate for freelancers and the self-employed, so is the benefits system, which simply was not designed for their tax and employment status. Can the Minister outline what plans there are to address this and to ensure that the protections that full-time employees have, such as parental leave, sick pay and protections against discrimination and harassment, also apply to freelancers and the self-employed? Given the decision to drop plans to reform IR35, what will be done to develop a tax system that can unlock the agility of a freelance workforce?

AI will bring opportunities to the creative industries, but unless it is properly regulated it could put creative occupations at risk. Much work is being done. The IPO is considering a code of practice on how AI technology firms operate with copyright-dependent sectors such as music. But is the Minister aware that in the consultations and round tables developing such plans, very few organisations that represent freelancers and the self-employed are involved? Will he look at this imbalance in representation?

Other countries do more. The Irish have piloted a basic income scheme for artists. There is a French scheme offering income support and social protection to individuals who are between periods of employment. Our Government should also do more. I hope that the idea of a commissioner, who could look at the issues that I and many other noble Lords have raised, will be seriously considered.

Gambling Act Review White Paper

Lord Foster of Bath Excerpts

Wednesday 3rd May 2023 Lords Chamber

[Lord Bassam of Brighton (Lab)]

My Lords, colleagues will know that I hail from Brighton—for film noir buffs, the home of “Brighton Rock”, with its famous racecourse scenes. My city has excellent amusement arcades, two casinos, a Premier League football team—rather good this year—, a horserace track, a dog track and a variety of other activities and sports that have strong links to the gambling sector.

We all like a flutter, and a night at the bingo or a weekend at the races are traditional British pastimes. Clearly, none of us want to change that. However, the publication of this important White Paper comes in part because of the relentless efforts of those with personal experiences of problem gambling. As gambling has moved into the digital age, far too many people have suffered from outdated regulation which has left them or their loved ones, friends and family exposed to significant and sustained gambling-related risk. People will have lost many thousands of pounds because existing safer gambling initiatives were not properly implemented or enforced, sometimes over several years. Many will have fallen into desperate debt, not just for themselves but, of course, impacting on family life. Tragically, some have paid an even bigger price. We should reflect on the fact that lives have been lost completely and unnecessarily.

While this White Paper may not contain all that campaigners hoped for, I pay tribute to them today for their tenacity. We have waited a significant amount of time for this Statement. The Government launched their review of the Gambling Act 2005 back in December 2020. Yes, these matters are complex; yes, the department received a significant number of responses, and yes, there is a balance to be struck, as many people enjoy gambling in moderation. Of course, the sector itself supports in excess of 100,000 jobs. But why has it taken so long for the Government to bring these proposals forward? We have seen multiple Ministers with responsibility for the review; at my last count, six Gambling Ministers and four Secretaries of State for Culture, Media and Sport have promised this White Paper imminently. We have had only a marginally smaller number of Prime Ministers: three, possibly four. So, can the Minister blame those who feel that their suffering has not been a priority for the Government? Can he understand the concerns of some in the sector that uncertainty has been allowed to last for such a long time?

Despite the delays, we welcome the fact that various measures been announced, with many being things that we have long called for and campaigned for. We are glad that the White Paper recognises the significant difference between bricks-and-mortar bingo halls and low-risk gambling and gaming centres, and the unique dangers of the online world. We welcome proposals relating to how online gambling sites will operate, the introduction of a levy and the expansion in the remit of the Gambling Commission. If properly implemented, these changes can make a significant difference to the amount of gambling-related harm people encounter, and improve the services available to those who have been affected by it.

However, and as ever, we need to see some more detail. While it is important that some measures are subject to further consultation, we hope it will not take another three and a half years for further decisions to be made. In another place, the Minister said that many of the changes in the White Paper will be brought forward via statutory instruments to speed up implementation. That is welcome, but is the Minister able to comment on how many SIs will be required and when we are likely to see them?

For matters that require primary legislation, can we expect to see a Bill in the next Session? The White Paper contains no fewer than 30 references to “when parliamentary time allows”—hardly an indication that these matters are being prioritised.

While I am asking questions, could the Minister have a go at answering some which were not addressed by his Commons colleague last week? Will the Gambling Commission be given additional resources? The National Audit Office previously raised concerns about the body’s capacity. If its remit is being extended without appropriate resourcing, that problem can only get worse. Who will set rules in relation to new affordability checks? Will they be set independently of the sector or will it be up to providers? What other initiatives, if any, are the Government looking at for under-18s who encounter loot boxes and other in-game features, which may not qualify as gambling but exhibit or promote similar qualities and behaviours?

Once again, we welcome this important White Paper. Reducing the harm caused by gambling is vital. We are glad that this will seemingly be done in a way that does not disadvantage the lower-risk premises that sustain communities across the country, especially in rural and coastal towns. Far too much time has already been wasted, so we hope that the Government and the Gambling Commission will now move quickly to implement the key reforms and consult smartly on the rest.

[Lord Foster of Bath (LD)]

My Lords, I declare my interest as chairman of Peers for Gambling Reform. We have known since the advent of the smartphone, giving everyone a casino in their pocket, that gambling legislation and regulation were out of date. Online gambling and wall-to-wall TV and radio advertising, coupled with online marketing—not least inducements such as a free bets and VIP offers—have led to thousands of lives being ruined.

For too long the Government have failed to hold big gambling companies to account—companies that, as we saw from the recent William Hill case, prioritise their annual £14 billion profits over customer care and that get the majority of those profits from problem gamblers. We have at least 350,000 such problem gamblers, including almost 60,000 children. This has, in turn, ruined the lives of around 2 million other people. Tragically, over 400 people a year take their own life because of gambling. Of course, it has also cost the nation billions of pounds.

The Government promised reforms back in 2019, but this White Paper has been constantly delayed by chaos, infighting and—as we have just heard—six gambling Ministers since the review was launched. So hundreds of people in that time have tragically taken their own life and thousands more have seen theirs devastated. None the less, the proposals in the White Paper are important and welcome steps in the right direction. At last, they are based on the recognition that gambling should be treated as a public health issue.

They respond directly to the key measures proposed by Peers for Gambling Reform and other campaign groups. Measures recommended by your Lordships’ Select Committee on gambling some three years ago included light-touch affordability checks, stake limits online, a statutory levy—so that all gambling companies contribute fairly and adequately to research, education and treatment—more effective redress mechanisms for individual gamblers and further limits on advertising and marketing. Online gambling products are designed to be addictive, with features such as high stakes and prizes, fast speed of play and the illusion of player control. We strongly welcome proposals to address these issues.

Does the Minister agree there should be parity online with, for instance, stakes in land-based venues, so that casino slot limits are set at £2? It has already taken too long, as we have heard. We should be implementing these and other proposals. What is the timeframe for consultation on these measures and when will they actually be in place?

In relation to affordability checks, given that the average household disposable income is £500 a month and the industry itself classifies gambling more than £75 a month as high spend, can the Minister explain why the White Paper’s proposed unsustainable loss trigger is 10 times that amount?

Given that the White Paper acknowledges that online gamblers use accounts with several different companies, why do the proposals consider only the “possibility” of a single, cross-company approach? Should there not be a single, independently run system of affordability checks?

We strongly welcome the proposals for a statutory levy. However, the White Paper is silent on the detail. Does the Minister at least agree that it should be a smart levy, based on the polluter pays principle, so that those that cause the most harm pay the most? How much money do the Government want to see raised?

We understand that primary legislation is needed to introduce a fully-fledged ombudsman, so we welcome the proposals for interim improved player redress. Will the Minister commit to introducing the necessary legislation to go even further as soon as possible?

We also welcome proposals to address some of the gambling companies’ marketing activities, such as free spins, free bets and bonuses. However, we are extremely disappointed that very little is being done to reduce the way in which we are all bombarded by gambling advertising. The Premier League’s voluntary decision to phase out gambling logos on shirt fronts is surely an acknowledgement that advertising is harmful—although, of course, you will still see gambling advertisements around the grounds, in matchday programmes and even on players’ shirtsleeves. There is clear research showing that advertising leads to people starting to gamble, leads existing gamblers to gamble more and leads those who have stopped to start again. Why would the industry spent £1.5 billion a year on marketing if it was not to boost its profits? Other countries are taking action to ban or restrict gambling advertising. The majority of the British public want us to do the same. Why is more not being proposed in this country?

Like the noble Lord, Lord Bassam, I say that my biggest concern is the delay in implementation. Can the Minister confirm that there are to be at least 12 separate consultations requiring the Gambling Commission to have no fewer than 30 workstreams? How long must we wait for the outcome of all this work? The review of the Gambling Commission’s funding is not planned until next year: will this not further delay the commission recruiting extra staff to do the necessary work, causing further delay?

Overall, while there are some welcome proposals, it is absurd that so many are subject to further consultation, given that there is already a wealth of information and research evidence and there has been plenty of time to look at the details of these measures. Further delay will lead to more lives, families and communities being ruined. Surely the Government should stop dithering and implement.

Arts and Creative Industries Strategy

Lord Foster of Bath Excerpts

Thursday 8th December 2022 Lords Chamber

[Lord Foster of Bath (LD)]

My Lords, I too congratulate the noble Viscount on securing this debate and share very much his view on the importance to our national life and economy of the arts and the creative industries, on which I will concentrate. After all, their economic contribution alone is bigger than the oil, gas, aerospace, life sciences and automotive sectors combined.

I believe that any strategy to ensure that we sustain and build on successes to date must encompass many issues, from digital infrastructure and finance to intellectual property and skills. Your Lordships’ Communications and Digital Committee, on which I serve, is considering all these issues and will report early in the new year.

My fear is that there is complacency within the Government at the present time. In the Chancellor’s 17 November Statement, the creative industries were not one of the five areas for growth that he listed. Publication of the Government’s “sector vision” has been delayed, and there appears to be limited cross-departmental working to address the cross-cutting challenges faced by the sector. The DCMS alone cannot address all the challenges faced by the creative industries. For example, BEIS has oversight of the apprenticeship scheme, yet it is poorly designed for SMEs, which make up the majority of the creative sector; the DfE oversees careers advice in schools, which currently does little to promote the sector as offering exciting job opportunities; and the Home Office oversees an immigration process that hinders international collaboration and stopped the flow of talent from the EU previously used to help the sector.

Yet another department is responsible for local government. The LGA has just published its Cornerstones of Culture report, pointing out that councils are the biggest funders of culture nationally. They spend £2.4 billion a year in England alone on culture and related services, with benefits such as creating jobs, underpinning local economies, contributing to levelling up and supporting the creative industries. But local government funding is once more under threat.

The Treasury too has a crucial role. Current tax incentives for film, high-end TV, children’s TV and video games are of course welcome, supporting some parts of the creative industries, but no such fiscal incentive exists for the music industry—an omission that I hope will be rectified. The Treasury could do more. The creative industries rely heavily on freelancers, so the Treasury should amend the tax and benefit system to support them and widen the definition of R&D to include the sector.

Any sector vision or strategy must be the product of cross-departmental working. Can the Minister tell us what exactly is being done to improve cross-departmental working? How much discussion, for example, is his department having with the DfE about skills shortages within the sector and the way in which the school system is exacerbating those shortages? The 40% decline in GCSE entries in creative subjects over the past decade certainly does not help. That decline can be attributed to the way in which the Government undervalue such subjects, as demonstrated by their absence from the EBacc.

Last year, one of your Lordships’ committees concluded that the national curriculum, and the EBacc in particular, was

“too narrowly focused to ensure that it prepares all young people for the modern labour market and the essential, technical and creative skills it requires”.

Mr Robert Halfon is the new Minister of State in the DfE. In his previous role as chair of the Education Committee, he said that

“New Ministers have inherited an education system that is at odds with the demands of our modern economy.”


Now, as poacher turned gamekeeper, he says that there are no plans to change the EBacc. Will the Minister seek to change his mind?

The Minister’s own department also has many ways to support the creative industries. For example, it has responsibility for our public service broadcasters. Recent reports show just how important the PSBs are to the creative industries and to the levelling-up agenda, not least through the Creative Industries Clusters Programme. I hope that, in the light of the damage that it would do to all that, the Government will drop their plans to privatise Channel 4 and call off the dogs in their seeming desire to cut the BBC down to size. I certainly agree with Tim Davie, the BBC’s director-general, who said only yesterday that

“The BBC is one of the most powerful and well recognised brands on the planet and we should be backing it.”


The lifeblood of the creative industries is intellectual property, and here too DCMS has responsibilities. The UK is rightly seen internationally as having a gold standard IP framework, which has enabled the UK’s creative industries to thrive. We weaken our IP laws at our peril—but we are in danger of taking just such a step. Following Brexit, the Government consulted on the future of the so-called IP exhaustion regime. Many of our creative industry exporters, fearing significant losses in income, expressed deep concern about making changes to the current arrangements. They breathed a sigh of relief when the Government concluded that there was insufficient data to make a decision and determined to maintain the status quo, at least for the time being. The resulting uncertainty does not help. Does the Minister agree that any final decision must deliver stability, and that the best way to achieve that is to make the interim decision permanent?

The Government also reviewed the text and data mining copyright exception and made an initial decision to widen it significantly. That would mean that businesses could scrape text and content created by others, repurpose it commercially without payment to the original creator, and, ironically, receive copyright protection for that new work. The creative industries reacted with universal dismay and the Government agreed to reconsider. During a recent Select Committee hearing, I asked the DCMS Minister Julia Lopez whether that reconsideration would lead to dropping the proposed change. She replied:

“I am fairly confident, in so far as I can say publicly, that this is not going to proceed.”


Will the Minister go one step further and give categorical assurance that no changes will be made to the exception?

During the pandemic, the then Government did much to support the creative industries and should be congratulated on that. My fear is that there is now a real danger that complacency is setting in and there will be a loss of focus on supporting a critical part of our economy, with different government departments leaving it to others to address the needs of the creative industries. I hope that I am proved wrong.

Horseracing Industry

Lord Foster of Bath Excerpts

Thursday 17th November 2022 Grand Committee

[Lord Foster of Bath (LD)]

My Lords, I declare my interest as the chairman of Peers for Gambling Reform. I congratulate the noble Lord, Lord Risby, on securing this debate. I have only had the odd flutter on the Grand National and occasional visits to the wonderful racecourse in my former constituency of Bath, so I am conscious that some noble Lords are far better qualified to speak on this issue than me. Nevertheless, I have raised a couple of concerns in your Lordships’ House on a number of occasions relating to the sector and the industry on the issue of drones and gambling, and on wider gambling reform. I will concentrate on just those two, and I apologise for not picking up other issues raised by noble Lords.

One of the ongoing challenges for the racing industry is the use of drones to film races without the permission of the course. This is being undertaken by some in the betting community to beat the slight time lag from official TV feeds. This is very worrying for the integrity of betting markets. I believe that this desperately needs to be addressed, so I would very much welcome comments from the Minister on what the Government propose to do about it. In particular, I hope he would be willing to consider looking at broader sports rights to protect sporting events from the use of drones and to enable the organisers of sports, including horseracing of course, to have much greater control over the events that they are responsible for.

More generally on wider gambling reforms, some in the horseracing sector have argued that the proposals for reform advocated by me and other members of Peers for Gambling Reform will do great harm to the industry. Indeed, articles in the specialist media accuse me of being ignorant, economically daft and, on one occasion, even delusional. So, since I very much hope that the Government will adopt the proposals that we recommend, which stem from the proposals of your Lordships’ Select Committee on gambling, I hope I can reassure the Minister and the Committee that they will not have the impact that some believe they will.

We have to remember that well over one-third of a million people are deemed to be gambling addicts, including as many as 60,000 11 to 16 year-old children, impacting the lives of well over 2 million people in this country. Most tragically, we have hundreds of gambling-related suicides every single year, so reform of gambling is urgently needed. Since horseracing and gambling are inextricably intertwined, such reforms will clearly have an impact but, I argue, not to the degree that some have suggested. Despite what media reports have claimed, I am not a gambling prohibitionist and I do not want to ban the entire sport. Indeed, the opposite is the case: I hope it will flourish.

I cannot help but note in passing that while the amount of support for the horseracing industry that comes through the statutory horseracing betting levy has gone down, as the noble Lord, Lord Risby, has pointed out, it is still something like three times the amount of money that comes in from the voluntary levy to help research, education and treatment for gambling addiction. That is why I would like to see a statutory levy that brings in more money.

I turn briefly to the other recommendations and their relationship with the industry and, first, our recommendations to limit the links between sport and gambling advertising. I make it absolutely clear, as the Select Committee does, that we believe those proposals should exclude horseracing and greyhound racing. That is not an issue.

Secondly, we are calling for the introduction of affordability checks. Surely it is important that consumers can afford to bet in the way they do, yet some in the industry have argued that such checks will deter the vast majority of punters and even cause a huge surge in the use of black market gambling, with dire consequences for the horseracing industry. Of course, this ignores that fact that some checks involving the sharing of financial data are already required in relation to money laundering and the existing and recent requirements of the Gambling Commission.

The impact of our proposals on horseracing will be limited because, first, they are targeted at online gambling. No checks would take place at a racecourse under the proposals, so traditional gambling at the racetrack would not be affected. Secondly, for online gambling, where horseracing now also resides, we want them to be triggered at a level of £100 a month. Even one of the gambling industry’s own reports, authored for it by PwC, determined that high-spend gamblers are defined as anyone losing more than £75 a month. So a level of £100 as the trigger really will not affect any but the smallest proportion of online customers, those who are likely to be suffering or at risk of suffering a gambling disorder. Thirdly, it is perfectly possible to do the checks in an unintrusive manner. After all, the gambling industry already shares data with credit agencies so should not need to ask for additional evidence from customers in all but a few cases. Affordability checks should not be a threat to the industry.

There is one area where I acknowledge potential issues that need to be addressed. Traditional, on-course betting is very different from what takes place online. At a racetrack there is a long time gap between races and punters have time to reflect on their financial position before making the next bet. Online there are very few of the limits, whether on stakes and prizes or on speed of play, that apply to land-based gambling. I acknowledge that there may well be impacts there, but I think they could be limited.

The noble Lord, Lord Risby, agreed that the horseracing industry wants to protect people from gambling-related harm but without disproportionate measures. I genuinely believe that the proposals we are recommending achieve both the things he wants.