‘Industry still has too loud a voice’: expert views on government policy consultations about gambling marketing

Abstract

Marketing is part of the suite of tactics used by the gambling industry and its allies to promote and normalize gambling. While there have been increased public calls for restrictions on gambling marketing, few governments have developed comprehensive policy responses to counter this public health threat. Consultation processes are widely seen as an important part of public decision-making and policy formation. However, there has been limited focus on these processes in gambling policy development. Using an online qualitative survey this study gathered opinions from 33 experts from Australia, the UK, and the USA (including from local governments, academia, not for profits, and lived experience organizations) about the consultation processes related to gambling marketing policy, and how current processes could be improved. A reflexive approach to thematic analysis was used to construct three themes from the data. First, participants perceived that current consultation processes were inconsistent with public health values and approaches with limited meaningful opportunities for community actors to shape and strengthen policy responses to gambling marketing. Second, participants stated that consultation practices prioritized industry views and concerns, with industry actors (and their allies) having disproportionate access to policymakers and decision-makers. Finally, participants commented that there were few mechanisms to ensure that policy developments related to gambling marketing are protected from vested interests. This paper provides new information about the factors that influence policy decisions about gambling marketing. Mechanisms to protect policy from vested interests are essential in developing comprehensive public health responses to gambling marketing.

Contribution to Health Promotion.

• Contemporary gambling marketing strategies are a threat to public health.

• Government policy responses have been inadequate to respond to gambling marketing.

• This study examined how experts are consulted about gambling marketing policy development.

• The study showed that there are limited mechanisms to engage independent experts (including those with lived experience), and the broader community in policy development and decision-making on gambling marketing. Instead, industry opinions and concerns are platformed and prioritized.

• The study shows that structural reforms are urgently needed to protect policies related to gambling marketing from the vested interests of the gambling industry and its allies.

INTRODUCTION

The gambling industry, its products, and its practices pose a significant threat to public health (Thomas et al. 2023a). Researchers have demonstrated that the gambling industry employs similar strategies documented with other health harming industries—such as alcohol and tobacco—to normalize and increase the consumption of products, shape public narratives about gambling, and prevent regulatory reforms that would jeopardize profits (Cowlishaw and Thomas 2018, van Schalkwyk et al. 2025). Technological innovations and sophisticated marketing strategies now mean that gambling products and promotions are transcending geographic boundaries to reach a new generation of customers and cause harm across the globe (Sichali et al. 2023, Thomas et al. 2023a, 2023b).

Despite evidence that clearly demonstrates the health and social harms associated with gambling (Marionneau et al. 2023), government policies and regulations have failed to keep up with a rapidly transforming gambling industry (Badu et al. 2025). There are few coordinated policy efforts which address the preventable risks posed by the gambling industry and ensure that regulatory structures keep the community safe from harm to the greatest extent possible (Van Schalkwyk et al. 2021, Thomas et al. 2023b). Instead, policy responses largely promote self-regulation and industry-policy maker/regulator partnerships, as well as a focus on personal responsibility through ‘safer’ gambling paradigms (van Schalkwyk et al. 2021). Weak regulatory responses have enabled the gambling industry (and those who profit from gambling such as broadcasters and sporting codes) to flourish at the expense of population health and equity.

Marketing enables the gambling industry to thrive, and plays a fundamental role in influencing and normalizing gambling attitudes and practices, thus attracting the next generation of customers (Thomas et al. 2023b). While compelling evidence shows that restrictions on gambling marketing are needed as part of a comprehensive policy response to preventing gambling industry harms (Standing Committee on Social Policy and Legal Affairs 2023), most governments and political leaders have been lenient towards the promotion of gambling products. Some argue that powerful vested interests have prevented the adoption of sensible and proportional public health policies that prioritize community health and well-being over the wealth of those who financially benefit from gambling (Marionneau and Nikkinen 2020, Thomas et al. 2024a). Researchers have demonstrated that the gambling industry (and those who profit from gambling) have infiltrated policy spaces through political donations and lobbying (Johnson and and Livingstone 2021, Chung et al. 2024). By contrast, the gambling industry claims in policy consultations that they act responsibly, reinforcing individual choice for gambling harms (Hancock et al. 2018).

Expert views of the influence of health harming industries over policy formation in the United Kingdom identified five highly interconnected elements of influence including: ‘dominance of market mechanisms’, ‘perception of partnership as good governance principle’, ‘industry involvement lending perceived legitimacy to the policy formulation process’, ‘industry is seen as part of the solution’, and ‘industry ties to policy-makers’ (van den Akker et al. 2024). There has been much less focus in the academic literature on how governments consult with a range of different actors to inform gambling policy deliberations and decision-making. This study aimed to provide a starting point for exploring the levels of influence that different actors may have over the policy decisions that are made in relation to gambling marketing. Two questions were used to guide the research:

1. How are different actors engaged in government consultations about policies to respond to gambling marketing?

2. What strategies are needed to improve government consultation processes and protect the development of gambling policy from vested interests?

METHODS

Approach

Online qualitative surveys are increasingly used in public health to gather insights about contemporary health and social issues (Thomas et al. 2024b). This particular survey took a ‘Big Q’ and interpretivist approach to knowledge which encompasses qualitative values and centres participants’ subjective experiences and sense-making (for discussion, see Braun and Clarke 2025), and focuses on situating attitudes and opinions towards important health policy issues (Arnot et al. 2023, McCarthy et al. 2024, Ogueji et al. 2024). The broader survey asked participants a range of questions about gambling marketing. The study received ethical approval from Deakin University (HEAG-H 127_2024).

Sample and recruitment

We sought key informants with knowledge of gambling policy making processes. The recruitment criteria were broad to include those working in research, policy, or practice, those engaged in advocacy, and lived experience experts (LEX). Purposive and snowballing sampling strategies were used to identify and send email invitations to individuals and organizations that had participated in gambling reform activities, who were encouraged to share the invitation with others in their networks (with no geographic boundaries on participation). A link to the survey was provided, and individuals participated anonymously.

Data collection

Data were collected from July 2024–September 2024 using the Qualtrics survey platform. We ceased data collection when there were no new responses in a 2-weeks period from the mid to end of September. The data presented in this paper included responses to questions about how government currently consults with different actors about gambling marketing policies, whether some are consulted with more than others, and how policy could be protected from those with vested interests.

Data analysis

Data were analysed using a six-phase approach to Reflexive Thematic Analysis (Braun and Clarke 2021, Braun and Clarke 2024). Data were coded to the study research questions, and themes were developed through a process of reflexive discussion which challenged our assumptions and interpretations of the data.

RESULTS

A total of n = 33 individuals completed the survey. Most participants (n = 23, 69.7%) were based in Australia, followed by the United Kingdom (UK) (n = 8, 24.2%), the United States of America (USA) (n = 1, 3.0%), and one participant who did not disclose their country of residence. Participants had a range of roles in local/state/national governments, treatment services, not for profits, universities, and as lived experience experts (LEX). Ten participants stated they had experienced some form of gambling harm (30.3%).

Table 1 outlines the themes and subthemes, with illustrative quotes from participants.

Table 1.

Expert views on government consultation processes to develop policies related to gambling marketing.

Theme One: Gambling policy consultation processes are misaligned with public health values and objectives
Subtheme	Quote
Tokenistic consultation processes result in poorly informed public health policies	The aims of consultation are largely influenced by economic interests rather than protecting the public from avoidable harm. With this framing, it is easy to dismiss voices which call for reform. More could be done to include public opinion and ask the right questions.—Local government, UK For a start, better methods of consultation to directly target the general community. This means better sampling of the community and methods that allow for collaborative decision making.—Local government, Australia This approach is concerning because it may prioritise industry perspectives over public health, potentially leading to policies that are less effective in addressing the broader harms associated with gambling. To develop more balanced and effective policies, greater input from independent public health specialists and clinical experts is essential.—Local government, UK From my perspective governments tend to consult most with gambling and gambling related industries, because the regulatory system in my State has, until recently, been tilted in favour of enabling the industry to function. That seems cynical, but take this comment together with my previous answer on my perception that government consultations are conducted with industry, government, and advocacy organisations, rather than with methods that would more directly/effectively seek the views of members of the general public.—Local government, Australia
Policy inertia contributes barriers to communities engaging with government	There is a lot of inertia in the policy space, where public servants are used to only consulting the industry, and politicians are clearly conflicted via donations and other mechanisms, while lobbyists have vastly more access to decision makers.—NGO, Australia It is seen as off the table by government (industry influence? political capital needed? too hard?). Thus there is relatively little focus on this by governments. Despite this, it is one of the top priorities for reform advocates, for good reason. We significantly restrict tobacco advertising, what is the difference between this and gambling.—Local government, UK The journey from listening to action seems long and sometimes community outrage is hard to sustain. Greater transparency, timelines and support is needed if consultation is to be considered genuine and meaningful.—University, Australia
Concern about the lack of LEX voices compared to more ‘credible’ experts	Obviously, their key stakeholders should be people with lived experience, researchers (particularly those who focus just on gambling, and don't take money from the industry), harm prevention advocates and community and public health bodies. They should also listen to their own productivity commission and multi-partisan inquiries.—NGO, Australia Industry still has too loud a voice, but in addition treatment specialists—re: individual addiction/neurobiological risks etc—are also given a lot of influence. There is a real need to widen the disciplinary base of expertise.—University, Australia Lived experience harm is not given enough voice.—Local government, Australia

Theme Two: Policy development and decision-making prioritizes gambling industry interests and voices
Subtheme	Quote
Government aims to create an appearance of genuine community consultation, but ultimately prioritizes industry voices	Currently, some governments seem to consult the industry more than any other group and I say this because of the lack of serious, meaningful reforms that would protect people. The balance is shifting, but needs to be moved a lot more.—LEX, Australia Governments may consult widely enough and with a broad range of stakeholders, but it's not necessarily about the volume or breadth of consultation. To me, it's the depth of influence that various stakeholders have. The recent federal government's claim that television stations won't make enough revenue from advertising if gambling advertising is banned, shows that the government is placing more importance on promotion of gambling than listening to the issues raised by those negatively affected by gambling.—Local government, Australia I would say that governments discuss this with representatives of the gambling industry and the advertising industry. I would also guess that government discuss this issue with advertising and gambling industry regulators. The revolving door between both those industries and the regulator obviously becomes a critical issue then. I can’t for a moment think that government is blind to this, it simply chooses to ignore this inconvenient truth. Thus in public and in private, govt/industry/regulator can downplay the need for any intervention on advertising.—Local government, UK There is no doubt that industry representatives still have prioritised access to decision makers. Even when special oversight has been put in place (e.g. Crown), there is extremely limited to zero non-industry/non-venue consultation. I'm not sure about the level of consultation with the union which might be somewhere between industry and harm minimization advocates.—NGO, Australia It would appear that they consult most/prioritise the views of the gambling industry.—Local government, Australia
Entrenched financial relationships between government, industry and vested interests compromise the integrity of consultation	I don't think government is really interested about holding the gambling industry to account. They have too much to lose, through the tax collection and profits made that ends up with government. The watering down of the gambling ad bans is a perfect example.—Local government, Australia They are likely to consult with enough stakeholders—the issue is that those with a vested interest in causing gambling harm are influencing policy and should not be allowed to due to their conflict of interest.—Local government, Australia The gambling industry simply due to the levels of financial clout the industry has either in generating profit or the perceived level of taxation going into the government coffers. I think this is both immoral and short sighted policy development. it is not based on any evidence based information/research.—Local government, UK The gambling industry are consulted with the most and hold too much power and influence—they should not be allowed to provide input given they have a vested interest in continuing to perpetrate harm.—Local government, Australia

Theme Three: There are few structural mechanisms to protect policy from vested interests
Subtheme	Quote
Limited transparency and mechanisms to protect gambling policy from vested interests	Policymakers need to maintain transparency and accountability and engage with all stakeholders to ensure that the wellbeing of society as a whole comes first. Make sure those developing policy don’t have a conflict of interest. Have advisory panels that include people with lived experience.—LEX, Australia Ideally a new Gambling Act would be a good starting point so that there is recognition of harm and protection of all individuals from addictive products, this would set the context for other types of policy. Beyond that (or failing that), I'd like to see… an avenue for feeding into policy to be more robust and transparent.—Local government, UK Transparency in donations and lobbying. Prevent industry bodies from political donations, increase the powers of regulators, ensure no self-regulatory models.—University, Australia
Recommendations to reduce the gambling industry’s influence over policymaking	One effective measure would be to establish an equivalent framework to the Framework Convention on Tobacco Control (FCTC) specifically for gambling. This would help restrict industry influence, including prohibiting political donations from gambling companies and ensuring that policy development is free from conflicts of interest.—Local government, UK Ban all donations, declaration of industry funded research, ban gambling lobbyists. Decision makers be required to declare if they have been talking to gambling lobbyists and media interests with an interest in gambling advertising.—NGO, Australia First, develop good pathways to involve lived experience advocates in numerous roles from regulator consultation through to accountability panels and a permanent voice in each Ministers’ office. Second, remove anyone making a profit, including NFPs relying on gambling income, from involvement in policy decision making, outside consultation on practical operational matters—in which case, they can be consulted like the community is to date—after the important decisions are made.—NGO, Australia
The need for government to take a public health approach to harm prevention	Independent regulation and policy development with a public health lens only.—Local government, Australia Governments currently seem to consult most frequently with industry-linked organizations such as the Gambling Commission, industry-funded charities like GambleAware, and regulatory bodies like the Department for Culture, Media and Sport (DCMS) when developing policies about gambling marketing. Consultation with NHS or clinical treatment specialists and public health experts is often limited. This approach is concerning because it may prioritise industry perspectives over public health, potentially leading to policies that are less effective in addressing the broader harms associated with gambling. To develop more balanced and effective policies, greater input from independent public health specialists and clinical experts is essential.—Local government, UK

Theme One: Gambling policy consultation processes are misaligned with public health values and objectives

There was broad concern that consultation and policy development related to gambling marketing were largely inconsistent with the robust public health approaches that had been applied to other health harming industries such as tobacco. Across all countries, participants stated that current government consultation processes were often limited, inaccessible, and lacked transparency. Some questioned the integrity of policy consultation processes. For example, some stated that governments’ own ‘conflicts of interest’ in revenue raising from gambling mean that any discussions were only held with health actors and advocates to create an appearance of consultation, or that those who supported gambling reform were excluded from discussions. They argued that consultation processes were more about ticking boxes than engaging in meaningful consultation. As a result, experts perceived that policy decisions were poorly informed and misaligned with the goals of public health to protect the health and well-being of the public over economic interests.

In the US, the answer is they do almost NO consulting with stakeholders and the little they do is merely done for appearance's sake. The reason is the more restrictions on gambling marketing, the less money the state extracts from its citizens.—Non-government organisation, USA.

Some stated that there was limited consultation because of policy ‘inertia’ and a lack of ‘political will’ to act in the face of powerful industry influence. There were significant barriers to accessing and engaging with government. Participants commented that rather than seeking diverse views, governments conducted consultations with individuals and organizations who were ‘handpicked’ to be involved in consultations. Some stated that public health experts and reform advocates were often excluded or consulted minimally in favour of actors who were seen as more politically friendly. Some participants specifically stated that governments intentionally limited the involvement of actors who advocated for stronger consumer protections. This was seen as a means of avoiding uncomfortable truths about gambling harm and preventing the introduction of regulatory reforms that might disrupt industry profits. Rather than actively talking to independent experts, ‘half hearted’ consultations were restricted to written responses to policy proposals. Some commented that governments made limited efforts to connect with those most at risk of industry marketing tactics, including young people and those with lived experience. This meant some voices were automatically excluded from consultation.

A lot of consultation is carried out or heavily based on, online processes accessible from government websites. Unless stakeholders are aware the consultation is coming or are part of a network that advises where to find the online consultation materials, those stakeholders will not be reached.—Local government, Australia.

Many participants were concerned about the lack of meaningful consultation with gambling reform advocates and LEX. There was a concern that LEX voices were often ‘outweighed’ by those who were considered to be more ‘credible’ experts, with few appropriate processes to consult and engage LEX. LEX participants commented that when they were engaged in consultation they were often isolated on panels and had limited power or say in agenda setting or decision-making:

They particularly do not have good process to engage with a range of people with lived experiences of different types of gambling harm.—Non-government organisation, Australia.

Theme Two: Policy development and decision-making prioritizes gambling industry interests and voices

The majority of participants stated that the government mostly consulted with the gambling industry who had a key objective of ‘protecting profits’. Some participants also stated that those who profited from gambling such as broadcasters, advertisers, and sporting codes, as well as individuals and groups funded by the gambling industry such as charities and industry-funded researchers, were regularly engaged by the government in discussions about gambling marketing. Participants described the industry actors as having ‘power’, ‘influence’, and ‘the loudest voice’ over the decisions that were made about gambling.

It seems the government still consults ‘stakeholders’ with vested interests more than they should. The groups making a lot of money from gambling and advertising of gambling have deep pockets and loud voices.—LEX, Australia.

Participants consistently commented that consultation processes were disproportionately shaped by input from industry actors, often to the exclusion of community groups, LEX, and public health advocates. They stated that while governments aimed to give the appearance of genuine consultation, the dominance of industry actors meant that consultations were primarily based on political motivations rather than genuine attempts at gambling policy reform.

Some participants attributed the dominance of industry voices to entrenched financial relationships between governments and the gambling sector. Participants emphasized that access to policymakers was partly determined by the resources of the gambling industry and those with vested interests, and their ability to access politicians and policymakers through ‘lobbying’ and ‘donations’ to government. One participant commented that the gambling industry had ‘financial clout’ because of the significant profits that industry generated, and the amount of taxation that was directed to government. Some participants stated that not only did government consult industry actors the most, but that they also prioritized their views the most. One described industry involvement in policy consultation as ‘putting Dracula in charge of the blood bank’. Industry/government policy relationships were seen as compromising the integrity of consultation processes and undermining the development of evidence-based, health-promoting policy.

…I think this is both immoral and short-sighted policy development. It is not based on any evidence based information/research.—Local government, UK.

Theme Three: There are few structural mechanisms to protect policy from vested interests

Participants overwhelmingly commented that there were few if any mechanisms to protect the development of gambling policy from the influence of vested interests. Many participants commented on the inconsistency between policy approaches to vested interests in gambling, compared to robust processes in tobacco control which sought to protect policy from the influence of the tobacco industry. Some participants stated that vested interests and conflicts of interest were rarely acknowledged by policymakers, and there was limited transparency about the degree to which different stakeholder groups had influenced decision-making.

The best thing would be to acknowledge the vested interests and take a proper public health approach and have governments not engage with them at all, as they did with tobacco.—LEX, Australia.

Participants offered a range of opinions about reforms to limit the gambling industry’s influence over policymaking. Many viewed these changes as important for rebuilding public trust, making sure policies serve the public, and stopping reforms from being weakened by industry pressure. These included restricting or banning political donations from gambling companies, increasing transparency around lobbying, and strengthening conflict of interest policies. Others stated that there needed to be more transparency related to conflicts of interest, including from industry-funded academics. Many recommended legislated reforms to restrict industry actors’ disproportionate access to decision-makers. For example, one participant in Australia stated they needed to ‘block the gambling lobbyists from having access to the Federal Parliament House’. Others stated that financial influences over policy needed to be addressed through a complete separation between political parties and industry actors including a ban on political donations from the gambling industry.

Ban political donations from the gambling industry. Reform the political donation regime completely.—NGO, Australia.

Some participants stated that the influence of vested interests would only be addressed when governments changed how gambling policy was developed and governed, including governments taking ‘a proper public health approach’ to harm prevention. These participants suggested relocating responsibility for gambling policy away from departments focused on communications and media, sport, or economic development and placing it under a health portfolio.

DISCUSSION

This study aimed to explore experts’ attitudes towards government consultation processes related to gambling marketing policy development. A summary of the key findings and practical recommendations is provided in Fig. 1. This study is limited to individuals mostly in Australia and the UK. However, it provides an important step forward in understanding experiences of the systems and structures that influence gambling policy consultations and decision-making processes.

Figure 1.

Summary of study key findings and recommendations.

There are significant concerns about the consultation processes used to inform policy development related to gambling marketing. Participants perceived that industry actors not only had more access to government actors and policy processes and were consulted more regularly, but also had their views prioritized in decision-making processes. While researchers studying the Commercial Determinants of Health often focus on the tactics that health harming industries use to influence policy decision-making (McCambridge et al. 2018), similar attention needs to be given to the political determinants that continue to legitimize industry actors (van den Akker et al. 2024), and exclude meaningful contributions from those advocating for gambling marketing reform.

Participants perceived that those with views that could challenge existing policy approaches were sidelined for those with views that were more politically palatable. Current consultation mechanisms appeared largely tokenistic or difficult to access for those who were directly impacted by gambling marketing strategies—including youth, and those with lived experiences. Strengthening consultation processes must therefore begin with the premise that those most affected by gambling marketing have a right to involvement in shaping the policies designed to protect them (Arnstein 1969). However, it is also important to note that even when there are full and transparent consultation processes, industry actors may continue to use informal consultations with government actors largely behind closed doors (Butler 2024), and governments may use lengthy consultation to delay policy action.

There were few adequate mechanisms noted by participants to protect gambling policy development from vested interests. Participants argued that major structural reforms were needed to reduce the influence of industry actors. Government has the ability and responsibility for setting the rules of engagement with the gambling industry and those who have vested interests in gambling. Industry can only engage in tactics such as political donations and lobbying activities because governments allow this to occur. The WHO Framework Convention on Tobacco Control (FCTC) has demonstrated that it is possible to restrict industry influence if governments are prepared to prioritize public health over private wealth, and has played a key role in preventing the tobacco industry from undermining government policy (Puska and Daube 2019).

CONCLUSION

At present, it appears that some governments are more willing to legitimize industry engagement in gambling, than create a firewall between those with vested interests and policy in the best interests of public health. A similar approach to Article 5.3 of the FCTC (which protects policy formation from industry interference) could be implemented as a policy governance tool to shift these problematic norms in relation to gambling marketing, and to ensure that policy serves the public interest over corporate profits.

Conflict of interest

S.T. holds the position of Editor-in-Chief for Health Promotion International and was involved neither in the review process nor in any decision-making on the manuscript. She has received funding for gambling research from the Australian Research Council, ACT Gambling and Racing Commission, Department of Social Services, VicHealth, Victorian Responsible Gambling Foundation, Healthway, NSW Office of Responsible Gambling, Deakin University. S.M. is the Social Media Coordinator for Health Promotion International was involved neither in the review process nor in any decision-making on the manuscript. She has received funding for gambling research from the Australian Research Council, Victorian Responsible Gambling Foundation, VicHealth, Department of Social Services, ACT Gambling and Racing Commission, and Deakin University. H.P. holds the position of Editorial Board Member for Health Promotion International and was involved neither in the review process nor in any decision-making on the manuscript. She has received funding for gambling research from the Australian Research Council, Victorian Responsible Gambling Foundation, VicHealth, NSW Office of Responsible Gambling, Department of Social Services, ACT Gambling and Racing Commission, and Deakin University. She has received funding for a gambling related advisory committee from the Alcohol, Tobacco and Other Drug Association ACT. G.A. is the Social Media Coordinator for Health Promotion International was involved neither in the review process nor in any decision-making on the manuscript. She has received funding for gambling research from the ACT Gambling and Racing Commission. M.R. has received funding for gambling research from the Australian Research Council, Victorian Responsible Gambling Foundation, and the ACT Gambling and Racing Commission. M.D. is Chair of the Boards of Health Promotion International and was involved neither in the review process nor any decision-making on the manuscript. He has received funding for gambling research from the Australian Research Council, Victorian Responsible Gambling Foundation, Healthway, ACT Gambling and Racing Commission.

Funding

This study was part of an Australian Research Council Discovery Grant DP210101983.

Data availability

The data from this study are not available due to ethical issues related to confidentiality.