The government will consult on raising the National Lottery age limit

When contemplating the activities which are most popular amongst children, gambling may not be one of the first that springs to mind.

However, studies have shown that children are more engaged in gambling than they are in certain physical activities. In June 2018 the Responsible Gambling Strategy Board found that 12% of 11-15 year olds gambled, whilst data from the Department for Digital Culture Media and Sport showed that only 4.9% went skateboarding, roller skating or roller blading. Additionally, results from the Active Lives Children and Young People Survey 2017/2018 by Sport England revealed that 32.9% of children do fewer than 30 minutes of activity per day.

Half of the children that gambled did so illegally, with 13% gambling online, and 43% of them using their parents' accounts without permission.

Worryingly, the study also revealed that 91% of 11-15 year olds had seen betting adverts on TV or social media and that 31,000 children are classed as "problem gamblers", with a further 45,000 at risk of becoming one.

"There is a strong case for further action to reduce both the visibility of gambling marketing and advertising to children and young people and its impact," the report says. "The increased volume of exposure online, including through social media, should be a priority." The report comes as it was announced that fines against gambling operators in the UK have risen from £1.6 million to £18 million in a year as the Gambling Commission cracks down on money laundering and unfair practices.

A Particular Appeal

In addition to these developments, last year betting giant Coral came under fire when a viewer complained to the Advertising Standards Authority (ASA) about three of its online slot machine game adverts called Rainbow Riches, Fishin' Frenzy and Lucky Wizard.

The complainant challenged whether the content of the adverts was likely to be of particular appeal to children.

The ASA banned the Coral adverts noting that Rainbow Riches "included an animated leprechaun whose face was highly stylised with a large nose, intensely flushed cheeks, big pointy ears and had a big smile showing his large teeth" as well as a colourful background showing "a bright yellow road, which was an iconic fictional element in a famous children's novel; bright green grass; and a vibrant rainbow".

They found that Fishin' Frenzy showed an animated, stylised image of fish swimming in the ocean which "had large eyes and innocent looking smiles, which we considered depicted them in a cute child-like manner", whilst Lucky Wizard was found to feature an animated wizard "with a large podgy nose, exaggerated cheekbones and had a thick colourful ginger beard with a long moustache with slightly curled tips".

Adverts must comply with the Gambling Act 2005 and, under Section 16 of the Committee of Advertising Practice (CAP) Code, marketers should not exploit the young or vulnerable nor imply gambling can solve financial or personal problems or is indispensable, a rite of passage or linked with sexual success".

Guidance on the ASA website states that: "One way in which the Code seeks to protect children and young people is through stating that betting and gaming ads should not appeal to them in particular, especially by reflecting or being associated with youth culture".

The ASA ruled that the adverts breached the CAP Code as they were found to be of "particular appeal to under-18s and were marketing gambling products".

They stated that the adverts should not appear in their current form again.

Unusual Standards

The appeal of gambling to children is becoming increasingly troublesome and appears to be a problem for Great Britain in particular where under-18s can legally buy lottery tickets and scratchcards. The Responsible Gambling Strategy Board stated that the "legal availability of some forms of commercial gambling to under-18s in Great Britain is unusual by international standards".
However, this may be about to change. On 16th July 2019, culture minister Mims Davies announced a consultation on the issue in the House of Commons where the government will look at whether the current age limit for playing the National Lottery should be raised from 16 to 18.

Davies described how the consultation, which runs until October this year, would explore three options: retaining the current minimum age of 16; raising the minimum age to 18 for National Lottery scratchcards and online instant win games; or raising the minimum age to 18 for all National Lottery games.

"The age of 18 is widely recognised as an age one becomes an adult, gaining full citizenship rights and the responsibilities. At present, all lotteries can be played from 16 - one of the very few age limits for gambling under-18 products" she said. "My initial view is based on the evidence reviewed so far, so it is that such a split could be the best approach.

"This takes into account the risk of harm associated with playing the National Lottery is at the lowest of any form of gambling. But we do know the risk of harm is slightly higher for instant win games than it is for draw-based games such as Lotto" she continued.

The debate surrounding gambling age restrictions looks set to substantially evolve over the next few months, with Davies alluding to the fact that the government may favour action on scratchcards and instant win games instead of the Lotto.

If any considerable change is to be made, a wide range of observations on the matter needs to be taken into account from the various parties involved. However the safety and protection of under-18s need to remain at the forefront of the debate.

A Gambling Commission spokesperson said: "We would encourage people to take part and provide their views on this consultation".

After all, you have to be in it to win it. 

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