UKGC: No System to Monitor Equality Impact of New Rules

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A Freedom of Information (FOI) disclosure has revealed that the UK Gambling Commission (UKGC) has no formal system or recorded information for monitoring the real-world impact of its regulations on people with protected characteristics.

The response, dated 8 December 2025, addresses how the regulator satisfies its Public Sector Equality Duty (PSED), a legal requirement for public bodies to consider how their decisions affect different groups in society.

Context: Why Equality Monitoring Matters

The Public Sector Equality Duty, part of the Equality Act 2010, requires organisations like the UKGC to actively consider the need to eliminate discrimination and advance equality of opportunity. For gambling regulation, this means ensuring that new rules—such as affordability checks or marketing restrictions—do not have an unforeseen negative impact on individuals based on their age, disability, race, or other protected characteristics. Without post-implementation monitoring, it is difficult to know if a policy's predicted benefits are being realised or if it is causing unintended harm to specific groups.

Key Findings from the FOI Response

The request asked the UKGC five key questions about its PSED compliance during the 2024/25 financial year. The responses revealed a mixed picture of the regulator's processes.

Monitoring Gap: The most significant finding was the UKGC's admission that it holds "no recorded information" when asked for evidence of how it monitors the actual versus predicted impact of its decisions on protected groups. This indicates a lack of a formal, documented process for evaluating whether a rule is working as intended from an equality perspective after it has been introduced.

However, the Commission stated it has "made a commitment to improve its capacity to evaluate new requirements and policies" and is working with the Department for Culture, Media and Sport (DCMS) to evaluate recent major changes.

No Central Register, But Assessments Are Conducted: The UKGC confirmed it does not maintain a single central register of all its Equality Impact Assessments (EIAs). It argued that equality considerations are "embedded throughout the policy development process." The regulator provided a list of recent major policy changes for which full EIAs were conducted, including:

• Financial vulnerability checks for remote gambling (effective 30 August 2024)
• Strengthened rules to prevent underage gambling, including a move to a 'Think 25' approach
• New Remote Games Design rules, including a minimum 5-second spin speed and restrictions on features like 'turbo' play (effective 17 January 2025)
• Changes to Personal Management Licence (PML) requirements

Positive Procedural Points: On a more positive note, the disclosure confirmed two key points:

• Legal Costs: The UKGC has incurred £0 in external legal costs defending challenges related to its own compliance with the Equality Act 2010 in the last three financial years.
• Consultation Time: All EIAs completed in the period involved a public consultation of more than six weeks, meeting good practice guidelines.

All EIAs were quality-assured by a "Director or above" before final Board approval, indicating senior oversight.

Significance for Consumers

While the UKGC's upfront assessment process and lack of legal challenges are reassuring, the absence of a formal monitoring system is a significant transparency and accountability gap. It means that neither the regulator nor the public can be certain about the real-world consequences of major regulatory changes on all segments of the population.

The Commission's new commitment to evaluate recent measures, such as financial vulnerability checks and game design changes, will be a critical test of its ability to close this loop. For consumers, effective monitoring is essential to ensure that measures designed for protection do not inadvertently create barriers or negative outcomes for vulnerable groups.