Highly regarded analyst Dan Waugh’s explosive claims that the Gambling Commission overstated its own GSGB problem gambling stats during the final stages of the Budget preparation has fuelled a war of words – and they’re all waged against the regulator. Did it or did it not deliberately elevate an assessment of higher gambling harm levels to encourage higher taxes on the industry? Many analysts believe so: but the Commission is keeping schtum. But that silence may cause bigger problems: could the dodgy data scandal drag HM Treasury’s integrity into the arena too?
Industry expert Dan Waugh has had no problem standing up and calling out the Gambling Commission for its regulatory missteps, and his latest attack, reported in Coinslot last month, could possibly be a make or break allegation on GamCom’s credibility.
Waugh’s recent article published on Substack claimed that the Commission overstated problem gambling statistics during the period when the Treasury was finalising its tax changes for the 2026 Budget.
He gathered compelling evidence from public documents and FOI requests that ultimately led the industry commentator to the conclusion of deliberate misrepresentation by the regulator, and he submitted his findings to the Commission.
Code breaker?
It’s a damning proposition – the Commission acting in breach of the Civil Service Code – but it’s one the regulator seems quite happy to wait out…for the moment.
In a brazen act of both defiance and dismissal, it leaves us, currently, with just half a stand-off.
Waugh has assembled his army of facts on the one side; the Commission deliberately in absentia from the other, clearly relying on the charge to dissipate.
In normal circumstances it most likely would; it is, after all, a Commission tactic of first resort. The regulator has a few long grass issues on the go where it’s playing the same game – the most notable being the OSR’s savage attack on the GSGB Survey and a timeframe in which the Commission must – and already hasn’t – responded in full to the statistics regulator’s multitude of criticisms.
A case of coercion?
But Waugh’s detail of the Commission’s behaviour goes far deeper than dodgy data dealings – it points to a more sinister intervention by the regulator: an attempt to shape Treasury policy.
And that image of overreach and overstep is gaining traction; from Waugh’s words to a war of words – the criticisms are beginning to draw blood.
‘Selects its evidence to fit its conclusions’
Waugh has allies, and plenty of them.
Among those is consultant Andrew Tottenham who delivered another brutal stab to the heart of the Commission’s GSGB.
He wrote on Linked In: “The Commission’s own guidance had previously urged caution about using the survey to extrapolate population-level estimates of problem gamblers. That guidance was then quietly relaxed at a particularly convenient moment: just ahead of the Autumn Budget, which delivered large-scale tax increases for the gambling sector. The timing alone raises an eyebrow. What Regulus Partners has now uncovered through FOI requests raises rather more than that.”
He cited the Waugh findings and a remarkable exchange between the Commission and an LSE researcher and two internal Commission reviewers, stating that the GC should not loosen its guidance of caution in assessing the stats.
But loosen them they did amidst the Budget discussions and Tottenham is incensed.
“This is not a catalogue of errors. Errors happen and good organisations acknowledge and correct them promptly. What the FOI disclosures appear to reveal is something more troubling: a regulator that seems to have consistently published, amplified, and relied on data that supported a predetermined policy direction, whilst suppressing or ignoring evidence that did not.”
And what spurs Tottenham on is something much bigger: it’s possibly existential and not in a good way for the regulator.
“Whether that constitutes deliberate manipulation or a more insidious form of institutional confirmation bias is almost beside the point. The effect is the same and it is wholly unacceptable.
“A regulator that selects its evidence to fit its conclusions has forfeited the right to claim it is acting in the public interest. It is acting in its own.”
‘Bias, intent and reckless distortion’
Lawyer Carlton Marcyan was equally enraged, with a post that set the scope directly on the Commission’s frontal lobe – he was targeting the regulatory psyche. “Confirmation bias, selection bias and outcome bias all rolled into one revealing intentional or reckless distortion,” he fired.
Graham White OBE responded: “Well said. Spot on. It’s as though the GC had made its mind up and then wrote the appreciation to suit its strategy. Not very bright and lacks transparency.”
Rule number 1: ignore them
And Geoff Banks, joyously never one to hold back, went all chips in: “I have submitted a complaint. Although I confidently expect the GC to treat it like a consultation they conduct. Then ignore.”
It’s an uncomfortable position for the Commission, but it’s one, as usual, they have created all on their own.
And yet the bigger picture here cannot be overlooked: whether they did or didn’t deliberately change the criteria for assessing their GSGB stats is actually no shock to the industry – they’ve come to expect it, such is the lack of trust in the regulator.
GamCom are serial misinterpreters of ‘facts’ – they originally denied the size of the black market; they have consistently overstated the level of problem gambling; and they have put together a 30 percent annual fee increase proposal to the DCMS that would blow the mind of independent auditors if anyone in authority had the courage to investigate them.
Whatcha gonna do about it?
The most important thing in this case is whether the Government is listening to all the noise.
The tenor of the critics goes deep: for them, the question is how many criticisms will it take for the DCMS to actually grab this issue by the throat and hold the Commission to account?
If Dan Waugh’s findings aren’t enough to persuade the Government to look into the Commission machinery, then maybe the voters did get it right at the local council elections last month. This Government has failed to deliver on its key promises – two of which were less regulation not more, and growth not contraction.
People are not calling the regulator the ‘Anti-Gambling Commission’ without good reason.
And the growing number now calling themselves Anti-the Gambling Commission have very good reason too.
Has the Commission dragged HM Treasury into Dodgy Data-gate?
The Woodstock singer Melanie observed: “In love and war, deception’s still deception.”
And so it seems with regulation and Waugh: deception is still deception.
In this instance, and in the absence of any meaningful Commission response, is it time for an independent investigation into the behaviour of the Gambling Commission and the accusation of dodgy data dealing?
Because as it stands, the Commission may not give a damn whether it’s innocent or guilty, but everyone else does.
And most importantly, this Government should too. Because the Gambling Commission’s actions have put HM Treasury’s integrity on the line as well.
The question needs an answer: did the Gambling Commission’s data influence taxation policy on gambling?
Originally published on Coinslot on June 22, 2026. Republished with permission.