On 2 November 2021, the Gambling Commission published its interim report on the ban on the use of credit cards in UK consumer gambling. This interim report reviews the effectiveness of the ban during the ‘monitoring phase' since the ban was introduced in April 2020, and assesses whether it has met its initial objectives.


Key date(s)

  • 1 January 2020  – The Department for Culture, Media and Sport (“DCMS”) and the Gambling Commission (the “Commission”) announced the ban on the use of credit cards in consumer gambling.
  • 14 April 2020  – The ban came into force, preventing individuals in the UK using credit cards to gamble.
  • June 2021  – NatCen Social Research began their evaluation of the impact of the credit card ban.
  • 2 November 2021 – The report on the prohibition of gambling on credit cards (The “Report”) is published.
  • February 2023  – NatCen's evaluation is scheduled to conclude and the final evaluation report published.


  • In response to growing concerns surrounding the use of borrowed money in online gambling as expressed in the Commission's March 2018 Review of Online Gambling and the DCMS response to the consultation on proposals for changes to Gaming Machines and Social Responsibility Measures, the DCMS announced in January 2020 that a ban on using credit cards for gambling payments was to be introduced (the “Ban”).
  • The Ban extended to any form of consumer gambling, including online gambling, and specifically included gambling through e-wallets. Although support for a similar ban had been growing for some time as the reports outlined above demonstrate, the April 2020 introduction of the Ban was ultimately very timely as Neil McArthur, the Commission's former chief executive, explained in his comments at the Ban's launch. Specifically, McArthur noted that the Commission's “online search analysis show[ed] an increase in UK consumer interest in gambling products since the lockdown began” and that consequently the Ban would enable gambling operators to increase their ability to keep people safe during the first stages of the Covid-19 pandemic.
  • The publication of the Report is designed to provide an overview of the ‘monitoring phase' of the Ban and evaluate its initial impact. Looking further ahead, NatCen Social Research (“NatCen”) have been appointed to produce a full evaluation of the Ban's performance. NatCen's initial research began in June 2021 and the final evaluation is expected to be published in February 2023.

 What it hopes to achieve 

  • The Ban's central aim is to protect consumers. Specifically, it is designed to prevent individuals who are vulnerable to gambling-related harms from getting into high-levels of gambling debt by using credit cards to gamble with money that they do not actually possess.
  • Commission research confirms that, prior to the Ban, approximately 800,000 out of 10.5 million online gambling consumers used credit cards to gamble. Within that bracket, approximately 22% of those consumers were classified as ‘problem gamblers' and vulnerable to suffering related harms.
  • Whilst the Ban has seemingly been initially successful in reducing the risk of these harms, the Report recognises that the ongoing monitoring of behaviours over the coming months and years is integral to achieving the long term goal of the Ban. Such monitoring is especially crucial in the context of the ongoing impact of Covid-19, as the easing of lockdown restrictions has brought with it an increase in more harmful forms of funding gambling activity.

Who does it impact? 

  • Most notably, the Ban impacts consumers of online gambling services who, prior to the Ban, used credit cards for payment. Accordingly, the Ban has also affected digital operators and financial services providers.
  • As the Ban's evaluation continues, financial service bodies are set to play a greater role in the process as the Report notes that certain metrics used in the evaluation can only be informed by data held by financial institutions. Accordingly, the Report concludes with a request for greater support from financial bodies representative of British consumers to complete the evaluation and ultimately support the Ban.

Key points 

  1. Positive reception
    • The reaction to the Ban has generally been positive. Qualitative consumer data gathered during this monitoring phase confirms that the Ban has generally assisted individuals to gamble within their means and retain control of their spending
  1. Appreciable reduction in credit card transactions
    • Data gathered from a major high street bank has confirmed that the volume and value of gambling transactions using credit cards has also dropped to a very low level in comparison to pre-Ban levels. There has also been no evidence to suggest that large credit card deposits or ATM withdrawals were made immediately prior to the Ban's introduction.
  1. No reported illegal money lending
    • Since the Ban came into force, there have not been any reported increases of gambling-related illegal money lending. Likewise, the proportion of consumers who have reported gambling with other forms of borrowed money has also remained stable.
  1. Industry cooperation
    • Gambling operators introduced the Ban in a timely and effective way and have been supported by major e-wallet and electronic money providers such as PayPal, Skrill and Revolut who have blocked gambling transactions where funding is found to have originated from credit cards.
  2. No displacement to black market sites
    • The Report has not identified any increased displacement of consumers to unlicensed and black market gambling sites as a result of the Ban. The rate of reports have remained stable throughout the monitoring phase, however the report does question the reliability of its data here as it notes that consumers are unlikely to report occasions where they have knowingly sought out an unlicensed site.
Hayley Brady
Herbert Smith Freehills
James Balfour
Herbert Smith Freehills
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