UKGC Hides Legal Advice on Football Index
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UKGC Withholds Key Football Index Legal Advice

The UK Gambling Commission (UKGC) has refused to release the legal advice it received regarding the regulatory classification of Football Index, the betting platform whose collapse left customers with an estimated £90 million in trapped stakes.

A Freedom of Information (FOI) response published by the regulator confirms it is withholding the King's Counsel (KC) opinion that informed its oversight of the product, citing legal professional privilege and data protection concerns.

Context: A £90 Million Collapse

The collapse of BetIndex Ltd, trading as Football Index, in March 2021 was one of the most significant consumer protection failures in recent UK gambling history. The platform, which was licenced by the UKGC and marketed as a 'football stock market', went into administration, leaving thousands of customers unable to access their funds.

The incident triggered parliamentary scrutiny and an independent investigation by Malcolm Sheehan KC, which highlighted regulatory failings. The legal advice sought by the UKGC in the year before the collapse is seen as a critical piece of evidence in understanding how the regulator classified and supervised the complex betting product.

Details of the Refusal

The FOI request, dated 19 August 2025, asked for three key pieces of information:

  1. The identity of the KC who provided the legal advice.
  2. The dates the advice was sought and received.
  3. The full text of the written opinion.

In its response, which was upheld after an internal review, the UKGC refused the core requests.

  • KC's Identity: The Commission withheld the name and chambers of the legal expert under Section 40 of the FOIA, arguing it constitutes personal data. The UKGC's review concluded that the individual's right to privacy and protection from potential abuse outweighed the public's legitimate interest in the matter.

  • Legal Opinion: The full text of the advice was withheld under Section 42 (Legal Professional Privilege). The UKGC argued that disclosing the advice would damage its ability to seek "full and frank" legal counsel in the future and undermine the confidentiality required for third parties to share information. The Commission concluded that the public interest was better served by withholding the information to safeguard its internal processes.

  • Dates Confirmed: The UKGC did confirm the timeline, pointing to the previously published Sheehan Report. The regulator instructed Counsel on 10 March 2020 and received the draft legal advice on 19 March 2020, a year before the platform's licence was ultimately suspended.

Significance for Consumers

The Commission's refusal to disclose the legal reasoning behind its approach to Football Index leaves consumers and campaigners in the dark. While the UKGC acknowledges the public interest in the case, its decision prioritises internal confidentiality and legal privilege over public transparency.

This lack of disclosure means crucial questions about the regulatory journey of Football Index remain unanswered. It is still not publicly known what legal rationale was used to classify the product, and whether the UKGC's actions were consistent with the advice it received. For consumers affected by the collapse and those concerned about the regulation of future 'innovative' gambling products, the decision reinforces concerns about accountability at the heart of the UK's gambling regulator.

D

Written by

Research & Data Lead

PhD in Public Policy, London School of Economics. Member of the Royal Statistical Society. Published in the Journal of Gambling Studies and Addiction Research & Theory.

Dr. Chen holds a PhD in Public Policy from the LSE and has 8 years of experience in quantitative research, including 3 years as a Research Fellow at the Responsible Gambling Trust analysing operator self-exclusion data.

Tags

UKGC Football Index FOI Freedom of Information Regulation Consumer Protection BetIndex

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