Expected reading time 6 minutes
Last Updated: July 31, 2025
Written by Jon Bryan
SlotsHawk writer Jon Bryan took part in the UK government’s consultation on remote gambling taxes. Here, we reproduce that submission.
Tax Treatment of Remote Gambling
Consultation by HM Treasury
“This consultation invites views on a new single remote gambling duty”
Submission from Jon Bryan, July 2025
INTRODUCTION
I am a gambling writer and recreational poker player: a short biography can be found here.
Although I write about gambling, play poker, and gamble on sports and politics, I am not a professional gambler – far from it. Gambling is a pastime for me, and an un-profitable one. I make this point because my livelihood is not at risk with any changes that might take place in gambling regulation – my full-time job is unconnected with the industry.
Nevertheless, I have a keen interest in what happens to the regulation of gambling, including changes to taxation. If the gambling industry has to react to what has been described as potentially ‘catastrophic’ changes to the taxation system, how will this impact on gambling consumers and the population in general?
MY SUBMISSION TO THE CONSULTATION
I make this submission as I believe those who gamble for recreation should have more say in the current debate on gambling regulation than they do at present. Their voices are rarely heard. I suspect only a small number of responses to this consultation are from those who you could categorise as a gambling consumer. I make a recommendation at the end of this submission on this issue.
I have chosen to respond to this consultation via email, making some general comments and observations. A significant number of the questions do not apply to an individual like me who is responding to this consultation.
THE GAMBLING INDSUTRY AND THE GAMBLING CONSUMER
I do not intend to make the case for the gambling industry or for any individual company. Those can be made by the companies themselves, or those that represent them, e.g. the Betting and Gaming Council (BGC).
This modest submission is concerned with the impact of these changes on the gambling consumer.
THE CURRENT CONTEXT – RETURN TO PLAYER (RTP) FIGURES DROPPING
Last year, Andrew Rhodes, CEO of the Gambling Commission, said to the industry:
“We see that Return to Player figures have dropped for a number of your businesses and products. Plenty of businesses across plenty of sectors have taken steps to keep profits up in challenging times. It is not our job as the gambling regulator to necessarily take a view on this at present. But it is something we are aware of.”
In other words, the Gambling Commission had observed that the industry was looking for ways to keep on top of rising costs, and that it appeared to be the customer who was suffering as a result, in terms of a lower RTP.
It follows that should changes in taxation impact on the gambling sector (or on specific companies or products) it would not just be the industry that would be hit. The gambling consumer would also be affected. An industry faced with rising costs and a squeeze on profits will consider how it reacts. A lower RTP would be one obvious area for the industry, or specific companies, to consider.
In short, increases in taxation for the gambling industry, or for specific businesses and/or products, is likely to impact on the gambling consumer in a negative way.
TAXATION – LEVELLING THE PLAYING FIELD?
The argument for equalising remote gambling duties appears to be one solely concerned with equity. That would perhaps make sense, but we are talking about taxation, which is not just a simple and un-complicated economic activity. Who you tax, and how much, is very political. It always has been, and it always will be.
The different rates of taxation that currently exist for remote gambling are essentially a fudge, brought about by the loss in taxation that resulted from the government cutting the maximum stake on Fixed-Odds Betting Terminals (FOBTs) in 2018. At the time, The Guardian described the rationale:
‘It will make up for the shortfall by increasing the tax on online casino games from 15% to 21%, raising an estimated £1.25bn over the same period.’
CHANGES IN TAXATION HAVE CONSEQUENCES
When I first reviewed the changes that the government were considering, I wrote the following:
‘What is certain is that a decline in money for the gambling sector, with the sole beneficiary being the government, is something that no-one in the gambling sector will benefit from. Not companies, or their staff, or the gamblers they serve.’
I still consider this to be an accurate summary of the situation.
The government should not pretend that any overall rise in taxation of gambling companies will not have an impact. It will. It is no surprise that many of those currently campaigning for a rise in taxation are also those who have a dislike of the gambling industry and, often, a dislike of gambling per se.
A SECTOR THAT WILL HAVE TO ADAPT – BUT THERE WILL BE CONSEQUENCES
The gambling sector has already seen a huge amount of change. Some stability would not go amiss. Earlier this year, the industry considered that we were ‘on the cusp of a period of regulatory stability’, as the changes that followed the government White Paper began to be implemented and bed in. How wrong that prediction was.
Should there be significant changes to the taxation of gambling, the sector will no doubt adapt, as they always have done, but there should be no pretence about the consequences. Another detrimental impact on the gambling sector is not what is needed, for the industry and for gamblers alike. For those of us who just want to have a bet every now and again, and who want the odds to be worthwhile and the experience a decent one, the changes in taxation that are being proposed will impact on us all. I would urge that keeping the status quo is given serious consideration.
Recommendations
Recommendation One
Categorise and count the number of submissions to this consultation from gambling consumers.
Recommendation Two
Consider the effect on consumers of any changes to taxation and undertake an impact assessment.
Recommendation Three
Consider additional ways to seek views from consumers, e.g. through focus groups or in-depth interviews.
Recommendation Four
Unless there are specific reasons for changing the taxation of gambling, leave it as it is. The whole of the sector (consumers included) could do with some stability. The gambling consumer is bound to lose out.
With kind regards,
Jon Bryan
Gambling Writer and Poker Player
July 2025
Sent by email to: [email protected]
