5. Gambling advertising
   1. This chapter considers whether Australia’s current restrictions on gambling advertising are meeting community expectations and are adequately protecting children, young people and Australians who are experiencing gambling harm. It examines:

• the links between the normalisation of gambling through advertising and sport, and gambling harm
• the limitations of the current legislative and regulatory framework for gambling advertising
• the concerns of those who have a financial interest in the advertising of online gambling products, such as media and sporting organisations, and online wagering service providers (WSPs), about further restrictions on gambling advertising.

Community expectations

5.2Many Australians are intensely frustrated and annoyed by current levels of gambling advertising and are concerned about the harm caused by exposure to gambling advertising, especially to young people.[1] TheAustralian Institute of Family Studies’ Australian Gambling Research Centre (AGRC) recently found that 69 per cent of Australians believe there are too many betting advertisements.[2]

5.3Members of the public are voicing these concerns with their local representatives and government,[3] and both the Australian Communications and Media Authority (ACMA) and the Department of Infrastructure, Transport, Regional Development, Communications and the Arts (DITRDCA) reported an increase in the complaints they receive about gambling advertising.[4]

5.4There is public support for significant restrictions on gambling advertising.[5] Asurvey conducted by The Australia Institute found that seven in 10 Australians agree that gambling advertisements on television should be banned.[6] Similarly, AGRC reported that more Australians support rather than oppose outright bans on all forms of sports and race betting advertising.[7]

5.5There is also community concern about the behaviours gambling advertising encourages. AGRC reported that most Australians believed that gambling advertising encourages people to bet for the first time, bet more than usual, and engage in riskier betting.[8]

5.6Parents are concerned about their children’s vulnerability to gambling advertising. Research conducted by ACMA found that while most parents ‘were bothered by gambling advertising’, more were concerned about their children’s exposure to it.[9] ACMA reported that parents were especially concerned that advertisements broadcast during prime time and during non-sports related programming were inappropriate for children.[10]

5.7The New South Wales, Queensland, South Australia, Tasmania, and AustralianCapital Territory governments agreed that there is currently too much gambling advertising, noted community concerns about its impact on gambling harm and said that current restrictions are insufficient.[11]

5.8Queensland, South Australia and Tasmania were open to further gambling advertising restrictions,[12] and the Australian Capital Territory called for ‘far greater restriction, if not an outright ban, on a range of gambling advertising, particularly at times when younger people are watching, but across the board.’[13]

5.9State and territory governments were supportive of a national, consistent, and collective approach in addressing the risks of gambling advertising.[14] For example, the Queensland Government said:

Advertisements are carried via broadcasting and the internet – matters that the Commonwealth is best equipped to legislate for…As existing (but inadequate) restrictions on wagering advertising demonstrate, the Commonwealth has the ability to impose general restrictions on the broadcast advertising of wagering, including by providing for matters such as when sports wagering services may be advertised.[15]

The normalisation of gambling through advertising and sport

5.10Concerns were raised that the volume of gambling advertisements and the way in which gambling is marketed with sport makes gambling seem like a normal, sociable, and risk-free activity that is intrinsic to enjoying sport. Australians are being saturated with gambling messages[16] and it is nearly impossible for anyone who is interested in sport, regardless of their age, to avoid advertising for gambling on any media.[17]

5.11Gambling marketing includes a range of activities, including direct and indirect advertising, promotion, sponsorship and incentives.[18] It can include broadcast advertising on television and radio, pop-ups on websites, inducements, celebrity brand ambassadors, direct and third party email and messages, loyalty programs, sponsorship and promotions.[19] According to AGRC, the key objective of gambling marketing is ‘to recruit new consumers and, by way of achieving this, normalise consumption of the product and associate it with enjoyable and desirable activities’, such as sport.[20]

5.12The Committee heard that gambling advertising and sponsorship, and their association with culturally valued activities, like sport, are some of the main drivers of gambling harm.[18] Advertising builds brand loyalty among potential and current customers and softens perceptions of harm associated with its products.[19] The more gambling advertising adults are exposed to, the more likely they are to gamble.[20]

5.13The AGRC reported that young people aged 18 to 34 years were more likely to be exposed to wagering advertising online and via social media, while people aged 55 and above were more likely to be exposed in traditional media, such as television, radio and print media.[21]

Celebrity endorsements

5.14It is common for influential people, such as celebrities and sports stars, to be paid or sponsored to endorse or advertise gambling.[22] Celebrity endorsements can be an effective way of marketing gambling because people are less likely to view something as risky if they trust the person promoting the product. This strategy is particularly effective when the person being marketed to is young.[23]

5.15Concerns were also raised about the rise of social media and influencer culture.[24] Professor Samantha Thomas, Dr Hannah Pitt and Dr Simone McCarthy said that social media influencer endorsement of gambling products ‘may be even more influential to young people as they are considered to be more authentic and credible than traditional celebrities.’[25]

Social media and online platforms

5.16Gambling advertising is becoming increasingly common on social media platforms and digital streaming platforms such as YouTube to recruit young people to gamble.[26] These services provide a dynamic and accessible platform for influencers and are typically accessed by younger demographics.[27] Gambling advertising on online platforms also provides easier access to gambling products for potential customers through a smartphone or computer with a single click.[28]

5.17Young people are frequently exposed to gambling advertising through their everyday social media activities.[32] Teenagers report being exposed to a high volume of gambling advertising online while using social media or video-sharing platforms, particularly on Facebook and YouTube.[33] The Committee heard an example of gambling advertisements being shown to a child while they watched Bluey on YouTube, despite parental controls being activated.[34]

The ‘gamblification’ of sport

5.18Gambling is heavily marketed through popular live sport[29] because it is effective for WSPs to do so.[30] The ‘gamblification’ of sport creates an association between the enjoyment of sport and gambling, as if gambling and sport are both healthy and harmless activities that are reliant on skill.[31] It makes gambling seem like a normal activity that increases a person’s enjoyment of sport, and as if gambling is part of an Australian culture that values sport and mateship.[32] Studies conducted in Australia and the United Kingdom found that 75 per cent of young people consider gambling a normal or common part of sport.[33]

5.19According to Professor Samantha Thomas, sponsorship is a particularly influential marketing tool, as it ‘creates a perception for young people that the company is doing something good for their sporting club or team’ and is not easily recognised by young people as a form of marketing.[34]

5.20Children are exposed to advertising at sporting events and at home during sporting games, through television and in-stadia advertisements, sponsorship logos on uniforms, and social media.[35] According to the Australian Medical Association, the close links and associations created between gambling and sport do not align with public health principles.[36]

5.21A recent study of Victorian sports fans by La Trobe University, which received almost 50,000 responses, found:

• 78 per cent of respondents felt they should be able to watch sport on television free from gambling advertisements
• 87 per cent agreed that young people (12 to 17 years) are exposed to too much gambling advertising, and 63 per cent said betting should not be a part of sport.[37]
  22. The AFL Fans Association’s 2022 survey found that gambling ads are now the most common concern of AFL fans:
• 79 per cent agreed that gambling should be banned from AFL grounds
• 76 per cent agreed that gambling advertising should be banned from broadcasting, including television and radio
• 67 per cent agreed that AFL clubs should not receive money from pokies revenue or gambling advertising
• 62 per cent agreed that AFL should not receive any revenue from gambling advertising.[38]
  23. AFL fans were also concerned aboutthe normalisation and grooming of children as future gamblers due to prevalence of these advertisements.[39]
  24. Market research conducted in 2021 suggests that Australians view sports betting ‘as one of the least suitable types of sponsorship for a sports club’ and that associations with gambling can damage a team’s public image.[40] The research found that three in five sports fans believe betting brands logos should not be allowed on team uniforms, and four in five sports fans want stronger regulation for sports betting advertising in Australian sport.[41]

The risks to young Australians

5.25Many young Australians are gambling and experiencing gambling harm.[42] While it is illegal for Australians under 18 years to gamble, it is not illegal to market gambling to young people and there are few restrictions to protect young people from gambling advertising. Since most gambling-related attitudes and behaviours are developed during the teenage years, the marketing of gambling to young people has the most potential for harm.[43]

5.26Concerns were raised that young people are increasingly being targeted by and exposed to online gambling advertisements through social media and other platforms that they frequently visit.[44] While exposure to television gambling advertisements leads to young people taking more risks with gambling, exposure to advertising on interactive or online platforms encourages even more risky behaviour.[45]

5.27Professor Shalini Arunogiri described the level of advertising that young people are exposed to through sports as unprecedented, stating:

This is a generation that is growing up with this being normal. The level of exposure, when you're watching live sport, for instance, with the volume of advertising that people are exposed to, is unprecedented; there's not been a generation that's had this before.[46]

5.28As a market, young people have very high recall of gambling brands, particularly if they are fans of sport.[47] Young men are the principal target of gambling advertising, although it is increasingly targeting young women as well.[48] This exposure has an important influence on how young people form attitudes about gambling, and the messages that children and young people are receiving are positive.[49]

5.29Exposure to gambling advertising can lead to early initiation of online gambling.[50] Gambling advertising influences young people to think more positively about gambling,[51] and many children are ‘keen to gamble’ because of how gambling is marketed with sport.[52] Gambling advertising may be more effective on young people than adults because young people may have less awareness of the ‘persuasive intent’ of advertising.[53]

5.30Gambling advertising is teaching children how to gamble. ProfessorThomas reported that children now have a ‘huge depth of understanding of these products’, including the functionality of gambling apps and how to set up a bet.[54]

5.31Gambling advertising is creating a new generation of Australians who experience harm from gambling. Young people are exposed to the marketing tactics that WSPs use to retain and expand their customer base and replace those who no longer frequently gamble. ProfessorThomas said ‘we need to understand that today's14-year-old is a potential customer for the gambling industry when they turn 18.’[55]

The risks to those experiencing gambling harm

5.32For some Australians, the risk of being exposed to gambling advertising means they can’t watch sport. Mr Jeremy Ryan, for example, explained that, ‘I don't really watch any sport anymore, just for the sheer fact that I don't want to see the gambling ads.’[56]

5.33The Committee heard that gambling advertising and other marketing tactics can undermine people’s attempts to gamble safely.[57] It may be unrealistic to expect that people who struggle to self-regulate their online gambling can do so effectively given the prevalence of online gambling advertising, prolific inducements and accessibility.[58] Gambling advertising has been shown to have a greater influence on people already experiencing gambling harm than other people who gamble, in terms of influencing them to believe they can win and to spend more than they initially intended.[59]

5.34Banyule Community Health reported that the exposure to gambling advertisements forces people with lived experience of gambling harm ‘to relive the trauma and…feelings of guilt, shame and depression.’[60] Banyule Community Health described how saturation advertising has deeply affected the day-to-day lives of those experiencing gambling harm:

I've certainly got plenty of clients who have basically had watching sports, a healthy pastime, been taken away from them due to the bombardment of the advertising, because they simply can't manage an urge involving a release of dopamine and rise of high anxiety when these ads come on.…If they're trying to recover…they certainly can't manage to do that whilst watching a game of sport. Even the nightly news, even just watching TV—this is the saturation point that it's at.[61]

Current regulatory framework for gambling advertising

5.35This report has shown that the regulatory framework for online gambling is complex and fragmented. The regulatory framework for gambling advertising is similarly complex,involving the intersection of Australian Government, state and territory law, regulation and industry codes of practice,[62] and includes:

• national legislation such as the Broadcasting Services Act 1992 (BSA) and the Interactive Gambling Act 2001 (IGA)
• the Australian Association of National Advertisers’ (AANA) Code of Ethics and Wagering Code
• a range of state and territory legislation, legislation and codes. The regulation of in-stadia advertising and logos on jerseys is the responsibility of the states and territories.[63]
  36. Television gambling advertising rules are more restrictive in some jurisdictions than others. For example, South Australia’s gambling advertising restrictions go further than national rules and include a requirement that gambling advertising cannot be broadcast between 4.00pm and 7.30pm, Monday to Friday.[64]

The Broadcasting Services Act

5.37The BSA regulates the television and radio broadcasting industry in Australia, as well containing provisions for regulating some online content.[65] It enables radio and television broadcasters to develop codes of practice, in consultation with ACMA, that are relevant to the operations for the specified sector. The codes are periodically reviewed to ensure that they reflect community standards and include rules regarding the amount, scheduling and placement of advertising, respective to the broadcasting sector.[66]

5.38The BSA empowers ACMA to enforce compliance with gambling advertising rules prescribed in industry codes of practice. Schedule 8 of the BSA also allows ACMA to create online content service provider rules about gambling advertising provided on an online content service in conjunction with the live coverage of a sporting event.

5.39In general, ACMA’s responsibility does not include the content of gambling advertisements, with the exception that advertisements that are permitted during live sport must be socially responsible and include a responsible gambling message.[67]

Gambling advertisements during live sport events

5.40In May 2017, the Commonwealth Government announced a package of media reforms that included restrictions on gambling advertising during live sporting events[68] in ‘acknowledgement of community concerns that regular exposure to gambling advertisements during live sport could normalise gambling in the eyes of children.’[69] These rules were implemented through amendments to the respective broadcasting codes of practice.[70] The codes were updated with these amendments in March 2018.[71]

5.41The rules for gambling advertising during live sport vary depending on when it is being broadcast. Between 5.00 am and 8.30 pm:

• gambling advertising is prohibited from five minutes before the scheduled start of play until five minutes after conclusion of live coverage of play
• the promotion of betting odds is prohibited from five minutes before play until five minutes after play (referred to as the ‘five minute rule’)
• the promotion of betting odds by commentators is prohibited from 30minutes before play until 30 minutes after play.
  42. Between 8.30 pm and 5.00 am:
• gambling advertising and the promotion of odds is not permitted during play
• gambling advertising is permitted before and after play and during scheduled and unscheduled breaks
• the promotion of betting odds is permitted only before and after play, not in scheduled breaks.[72]
  43. For long-form live sporting events such as golf or the Commonwealth Games, broadcasters must not show gambling advertising from five minutes before the start of the first event of the day until 8.30 pm. After 8.30 pm, gambling advertisements are permitted in accordance with rules applicable to the long-form event and not more than once every two hours as part of a distinct break of at least 90 seconds.[73]
  44. Regardless of the time slot, all gambling advertisements and promotion of betting odds must be accompanied by a responsible gambling message. Furthermore, all gambling advertisements must be socially responsible and must not:
• mislead the audience
• be directed to children
• portray children as participating in betting or gambling
• portray betting or gambling as a family activity
• make exaggerated claims
• promote betting or gambling as a way to success or achievement
• associate betting or gambling with alcohol.[74]
  45. ACMA is empowered by Schedule 8 of the BSA to make online content service provider rules.[75] The Broadcasting Services (Online Content Service Provider Rules) 2018 apply to any online content service that provides live coverage of sporting events. These rules replicate the restrictions on gambling advertising during live sport in the broadcasting codes.[76]
  46. The live sport event restrictions do not apply to incidental advertising such as logos on players’ uniforms or in-stadia advertising. Broadcasts, or online streams, of live horse racing, harness racing or greyhound racing are also not subject to the restrictions.[77] Furthermore, these prohibitions only apply to the broadcast or streaming of live sport events; non-live sports, such as replays, are exempt from the current restrictions.[78]

Broadcast industry codes of practice

5.47Commercial television broadcasters are regulated under the Commercial Television Industry Code of Practice (the Free TV Code), which sets out restrictions on gambling advertising on broadcast television.[79] Gambling advertising and the promotion of betting odds must not be directed to children, portray children as participating in gambling, or portray gambling as a family activity.[80]

5.48Clause 6.5.1 states that a commercial relating to betting or gambling must not be broadcast:

• in any program classified G or lower between 6.00am and 8.30am; and, between 4.00 pm and 7.00 pm
• during any program that is broadcast between 5.00 am and 8.30 pm and principally directed to children.
  49. Clause 6.5.1 therefore allows gambling advertising to be broadcast between 8.30 am and 4.00 pm, during any program that is not principally directed to children. Further, this clause also allows gambling advertising between 8.30 pm and 5.00 am.
  50. Clause 6.5.2 states that the restrictions in clause 6.5.1 do not apply during news, current affairs or sports programs (not sports events).[81]
  51. Other clauses in the Free TV Code allow a primetime news broadcast to cross to a reporter on the sporting ground or in a nearby studio before a live match to promote the odds.[82]
  52. In accordance with the 2017 Media Reforms, Free TV Australia (Free TV) introduced the appendix ‘Restrictions on Promotion of Odds and Commercials relating to Betting and Gambling which are broadcast during a Live Sporting Event’ into their code in 2018.[83] This appendix implemented the restrictions on gambling advertisements during live sport events.[84]
  53. Similarly, section 9 of the Commercial Radio Code of Practice (Commercial Radio Code) covers the promotion of gambling and betting odds in live sports coverage. This section generally mirrors the prohibitions in the FreeTV Code, with slight variations to reflect radio’s different operating environment.[85]
  54. Regarding betting and gambling promotion during a live sporting event, the SBS Code of Practice follows the provisions in the Free TV Code for its television broadcasting services and the Commercial Radio Code for its radio broadcasting services.[86] These restrictions are applied to SBS TV and Radio, and SBS on Demand.[87] As a national broadcaster, the SBS is not required to register its code of practice with ACMA. Rather, it notifies its amended code to ACMA.[88] For commercials relating to betting and gambling on SBS television generally, SBSmirrors the provisions in clauses 6.5.1 and 6.5.2 of the Free TV Code.[89]

Interactive Gambling Act 2001

5.55As noted in earlier chapters, the IGA prohibits the advertising of unlicenced online gambling services such as online casinos, slots and poker, and sports betting or wagering services offered by entities that do not hold a licence issued by an Australian state or territory.[90]

5.56According to ACMA, a significant limitation within the IGA is Section 61EA, in Part 7A, which provides that the advertising of unlicensed interactive gambling services on a website accessible by Australians is prohibited if, and only if, ACMA is satisfied that the majority of persons who access the content are physically present in Australia. This limits the IGA’s application of advertising prohibitions, as it excludes some websites accessible by Australians, like those with a global audience such as Facebook and YouTube. ACMA said that removing this requirement would allow ACMA ‘to take action to address harms from the advertising content targeted at Australians.’[91]

5.57The Digital Industry group Inc. (DIGI) said that, at a minimum, Section 61EA should also include a requirement that advertisements be specifically targeted at and accessible to Australians – as in persons ordinarily resident in this jurisdiction. DIGI said that clarifying this in the IGA would be ‘consistent with the policy aim of protecting Australians’ from illegal and unlicensed interactive online gambling.[92]

5.58The Committee notes that it would not be necessary to make these amendments if all online gambling advertising on online platforms and social media were prohibited.

Australian Association of National Advertisers Codes

5.59The content of wagering advertisements is largely regulated by the Wagering Code and the Code of Ethics.[93] These self-regulatory codes are developed by the AANA,[94] and are administered by Ad Standards,[95]who manage the complaint process of the advertising self-regulation system through an independent Community Panel.[96]

5.60These codes are platform neutral,[97] and do not make a distinction between traditional media advertising and digital advertising.[98] Unlike the broadcasting codes, the AANA Codes are not enforceable under legislation[99] and it is the responsibility of wagering advertisers to comply with the AANA codes.[100]

5.61The Wagering Code applies to all advertising for products and services provided by WSPs in Australia, including online advertising. According to AANA, the Wagering Code enables the industry to ‘ensure that the content of advertising and marketing activities is delivered in a responsible manner with particular consideration given to the potential impact on young people and those Australians who may find it difficult to gamble responsibly.’[101] The Wagering Code requires that wagering advertising must not:

• be directed primarily to minors;
• portray people under the age of 25, unless in an incidental role;
• portray or encourage the consumption of alcohol in combination with wagering;
• state or imply a promise of winning;
• state or imply a link between wagering and sexual success or enhanced attractiveness;
• portray or encourage wagering as a means of relieving financial difficulties;
• portray or encourage excessive participation; or
• portray or encourage peer pressure to wager or disparage abstention.[102]
  62. The Code of Ethics applies to all advertising regardless of the product or service being promoted and includes restrictions on a suite of issues including discrimination, sexual appeal, and offensive language.[103] According to AANA, this code is the cornerstone of the advertising self-regulatory system,[104] and is supplemented by the Wagering Code.

Limitations of the existing regulatory framework

5.63The Committee heard that current gambling advertising restrictions are not sufficiently reducing harm.[111] The regulation is limited, and the scope and wording of the various codes allows circumvention and rely on industry self-regulation.[112]

5.64There are too many loopholes that allow gambling to be marketed to children and young people.[105] For example, the 2017 restrictions on gambling advertising during sport did not reduce in-stadia advertising, such as signage on the grounds or logos on players’ jerseys, which are viewed on television.[106] Submitters argued that it is naïve to assume that children are not influenced by gambling sponsorship on their favourite players’ jerseys, and that they do not see advertising that occurs during breaks in play.[107]

5.65It is unrealistic to expect parents to supervise everything a child watches and be able to interpret the various gambling advertising rules, particularly when gambling advertisements are broadcast at times when it can be reasonably expected that children will be watching.[108] It is also unrealistic to expect children to go to bed at 8.30pm in the middle of a sporting match.[109]

5.66Professor Samantha Thomas, Dr Hannah Pitt and Dr Simone McCarthy reported there is little evidence that 8.30 pm is late enough to ensure that children and young people are not exposed to gambling advertising and referred to the current rules as ‘arbitrary’.[110] Similarly, Children and Media Australia said:

We seem to assume that children just toddle off nicely to bed as soon as the clock strikes a certain hour, even if they're in the middle of an exciting sports game. If regulations are to be serious about protecting children, they should be more realistic about family life.[111]

5.67The Committee heard that the five-minute rule is similarly arbitrary and insufficient, given that children will often watch the pre-match build up or post-match review of a sporting event.[112]

5.68Concerns were raised that the exemption for news, current affairs and sports programs does not protect children from gambling advertising because children do not solely watch children’s television programs. Rather, many families watch television together across current affairs and news programs, as well as sporting games, which are often viewed during dinner time.[113] Furthermore, many children watch shows that have higher ratings than G under the Australian Classification System[114] such as TheSimpsons, which is classified PG.[115]

5.69Turning Point and the Monash Addiction Research Centre also noted that children can be exposed to gambling advertising on television during school hours when they are at home due to illness, during school holidays or because they are simply not yet of school age.[116]

5.70The Victorian Arabic Social Services noted that international sports, such as European soccer or the English Premier League, are not necessarily captured by the current time-based restrictions because they do not always air during primetime. This means that families who get up to watch sporting events together at night are being exposed to gambling advertisements.[117] During the World Cup final in 2022, 18percent of the audience at 5am were children under the age of 18, and 9.2percent were children aged under 12years. In Sydney, this means about 21,000children aged under 18, or 11,000 children aged under 13 were exposed to gambling advertisements.[118]

Self-regulation

5.71Industry self-regulation of the AANA codes was criticised as being a weak approach because it relies on the gambling and advertising industries to decide what is and isn’t permissible, and on consumers raising complaints.[119]

5.72Ad Standards adjudicate and consider complaints against the provisions set out in the AANA codes. If a code breach is identified, advertisers are required to remove or amend the relevant marketing material, irrespective of the platform.[120] Ad Standards do not monitor advertisements, so the onus is on consumers to raise complaints.[121]

5.73While Ad Standards claimed there was a strong compliance rate with the AANA codes,[122] it is difficult to assess the accuracy of these claims. It is possible that many advertising breaches are not flagged, investigated, and captured in these compliance estimates because people are not aware they can register complaints with AdStandards, or may not have time to do so.

5.74Ad Standards claimed that industry self-regulation is faster and more effective than government regulation and comes at no financial cost to the community.[123]

Online platforms

5.75Advertising that takes place on social media and online platforms in Australia is subject to the AANA codes and the IGA’s prohibition on the advertising of illegal gambling services. This means that most advertising by WSPs online and through social media is largely self-regulated by digital platforms.[124] While some digital platforms do not show gambling advertisements, many others do. This inconsistency[125] offers little protection for vulnerable Australians.[126]

5.76Some platforms show gambling advertising, subject to certain restrictions. TheOfficeof the Australian Information Commissioner (OAIC) reported that ‘Twitteris the only platform which appears to prohibit rather than restrict gambling-related advertising. Facebook, Google and Snapchat impose some safeguards by requiring advertisers to gain pre-approval for gambling-related ads’.[127] Conversely, TikTok prohibits all forms of gambling advertising, and yet is piloting sports betting advertising in Australia.[128]

5.77On social media platforms, the more a user engages with certain content, the more the platform learns and provides them with content in line with those interests, resulting in increased exposure to potentially harmful content such as gambling-related material.[129] OAIC reported that children can be particularly at risk online as companies ‘may share children’s data for advertising purposes, or engage in harmful tracking, profiling of, or targeted marketing to children.’[130]

5.78OAIC observed that many of the privacy risks and harms online have emerged due to the ‘increase in the amount of data and personal information collected, used and shared to support the ads-based revenue model of the internet.’[131] This allows platforms to generate detailed user profiles, which in turn ‘enables them to sell highly targeted advertising units.’[132]

5.79The Australian Government is currently considering the Attorney-General’s Department’s Privacy Act ReviewReport 2022, which was released for consultation in February 2023.[133] The Review proposed 116 reforms that seek to provide Australians with more protections, transparency and control over their personal information.[134] It includes proposed reforms to direct marketing, targeted advertising, the trading of personal information, and providing individuals with an unqualified right to opt out of their personal information being used or disclosed for direct marketing purposes.[135]

5.80OAIC said that several of the proposed reforms will provide greater protections to Australians from gambling advertising on digital platforms, including:

• express prohibitions on direct marketing to a child
• requiring a privacy impact assessment to be conducted for activities with high privacy risks such as direct marketing through online targeted advertising, and the handling of children’s personal information on a large scale[136]
• introducing a positive obligation to collect, use and disclose personal information ‘fairly and reasonably’.[137]
  81. The positive obligation would require online platforms to take more ‘proactive steps to actively consider the foreseeable risks to individuals and take reasonable steps to mitigate these potential impacts’.[138] This requirement would apply regardless of whether consent has been obtained, therefore preventing ‘consent from being used to legitimise activities that are inherently unfair and unreasonable.’[139]

Support for further restrictions

5.82There was support for a comprehensive ban on all forms of gambling advertising across all media, including inducements and sponsorship,[140] and for meaningful penalties for non-compliance.[141]

5.83Recent history shows that Australia's limited approach to protecting children from gambling advertising means that the adoption of restrictions in one place or time results in an increase in advertising elsewhere.[142]

5.84Following the 2017 rule changes, the total volume of gambling advertising in prime-time spots on metro television increased by 40percent.[143] There was a 131per cent increase of gambling advertisements broadcast during breaks in play and pre- and post-game coverage, after the 8.30 pm watershed was introduced between the 2017and 2018 AFL home and away seasons. Similarly, during the 2018 NationalRugby League (NRL) home and away season, gambling advertisements broadcast after 8.30 pm increased by 25 per cent.[144] Gambling advertising during non-sports content on television and radio also increased by 50 per cent during this period, mainly between 6.00 pm and 10.30 pm.[145] On radio, gambling advertisements increased substantially following the rule changes, particularly during peak times, where the Monday to Friday ‘breakfast’ shift (5.30–9.00 am) and ‘drive’ shift(4.00–7.00 pm) both increased 94 per cent.[146]

5.85This experience bolsters the suggestion from Responsible Wagering Australia (RWA) that if inducement marketing were banned, ‘then those dollars would go to brand advertising.’[151]

5.86In calling for a comprehensive ban on gambling advertising, FCA warned that if bans are only applied to broadcasters, ‘then the advertising will just move to online and social media. Marketing will move to the gaps.’[147] Similarly, Professor Thomas said restrictions on gambling advertising in particular time slots are unlikely to have a much impact in minimising children’s exposure.[148]

5.87Professor Thomas challenged Free TV’s idea that the risks of children’s exposure to gambling advertising on television were less when children are being supervised by an adult, stating a parent is not necessarily ‘equipped to have a robust discussion about the tactics of the gambling industry’.[149]

5.88The Committee heard that a comprehensive ban on gambling advertising should be phased in to allow sports and broadcasters time to adapt.[150] For example, AssociateProfessor Charles Livingstone remarked:

Many sporting codes, as well as their broadcast ‘partners’, rely on gambling advertising and/or sponsorship for a proportion of revenue…Accordingly, progressive reductions in the times and the mediums when and where such advertising is possible should be implemented. The goal should be to provide all interested parties with notice of the point at which advertising will be prohibited. A three year time frame to achieve this would enable alternative arrangements to be made.[151]

5.89To ‘wean the sporting codes off that revenue,’ Associate Professor Livingstone suggested there should be a ‘modest level of support for those codes’, which provides both a buffer and an incentive. Furthermore, there would be other advertisers who would be ‘prepared to pay quite high premiums for the audience which is delivered by AFL or NRL games, cricket matches and so on.’[152] He suggested the long term impacts on media revenue would likely be minimal.[153] This idea was strongly contested by AFL and NRL, who warned that a loss of gambling revenue would affect their operations.[154] This is because AFL and NRL make money from every bet that is placed on their games in addition to sponsorship and advertising revenue.

Lessons from tobacco advertising reforms

5.90The Committee heard that Australia’s tobacco reforms provide a model for dealing with the harms of gambling advertising.[155] For example, EmeritusProfessorMike Daube noted that, in the case of both tobacco and online gambling, ‘young people are an important target, as both current and potential consumers, and in the case of addictive products, there are added benefits to “getting them hooked” early’.[156] In both cases, advertising is part of a much bigger marketing ecosystem, where industry leverages their sponsorship of sports as a reason why their marketing should continue.[157]

5.91Emeritus Professor Daube argued that to make comprehensive marketing bans on harmful products work, the bans ‘can be phased in with strong community support and…recipients of gambling funding can continue to thrive with other sources of funding.’[158] He said that ‘partial bans on marketing are only partially effective, as the industries involved will work assiduously to find means of circumventing them.’[159] For example, the volume of cigarette advertising in print media increased significantly following the ban on direct cigarette advertising on radio and television, which was phased in between 1973 and 1976.[160]

5.92Emeritus Professor Daube described the arguments in favour of tobacco and gambling advertising as ‘strikingly similar’.[161] For example, when the Western Australian Government attempted to ban tobacco advertising in 1983, the tobacco industry and sporting bodies that received tobacco sponsorship launched a campaign[162] claiming that without tobacco advertising and sponsorship:

• ‘the game [Australian cricket] would suffer…and it would most suffer at grass-roots level’[163]
• ‘sport as we know it in Western Australia could be facing the axe’[164]
• ‘anyone whose job is linked to tobacco promotion could get the chop’.[165]
  93. Western Australia’s major sporting bodies argued that tobacco sponsorship was ‘an essential source of funds because spectators do not meet all the costs of major sports’ and that ‘there are great benefits in being able to rely on long-term income from the tobacco companies.’[166]
  94. Following the ban on tobacco sponsorship, major sporting events secured new sponsorships from both government and the commercial sector.[167] For example, in Victoria, the Victorian Health Promotion Foundation imposed an excise on tobacco sales to buy out some tobacco sponsorships, which gave sporting codes time to find alternative sponsors.[168]
  95. According to Associate Professor Livingstone, these restrictions on advertising deprived the tobacco industry of ‘its path to normalisation via marketing and sponsorship.’[169] This was a major contributor to the success of the tobacco control movement because it made it ‘less likely that such products are casually accepted and seen as socially desirable.’[170]

International practice

5.96Other countries, where there are lower rates of gambling harm than Australia’s world-leading per capita losses, have strong restrictions on gambling advertising. For example:

• Italy prohibits all gambling advertising and sports sponsorships[171]
• Finland prohibits gambling advertising on all radio, television and cinema platforms[172]
• Belgium prohibits all forms of gambling marketing[173]
• Spain prohibits gambling advertising on radio, television and video exchange platforms from 5.00 am to 1.00 am,[174] in-stadia advertising and sponsorship, and ensures that customers who are assessed as at-risk cannot receive inducements or other gambling marketing.[175]
  97. The Spanish gambling regulator noted that the predictions of those reliant on gambling advertising have not been borne out:

The gambling industry and the TV and advertising sectors lobbied against the reforms. None of the dire predictions have occurred…The TV stations said that they would go broke without gambling revenue and this has not happened…Spanish sports teams said that they wouldn’t be competitive if they were the only ones not allowed sponsorship, and this hasn’t happened either…The threat of gamblers migrating to illegal operators had not occurred either.[176]

5.98France’s Loi Evin law, which regulates and prohibits alcohol and tobacco advertising, was suggested as a potentially useful model for regulating gambling advertising. According to the Queensland University of Technology, Loi Evin works under a simple premise: ‘it prescribes which forms of marketing are permitted, meaning that anything other than what is prescribed is not permitted.’[177] This means that regulators ‘do not always need to consider how to amend and update regulations when new forms and tactics of marketing are employed to promote potentially harmful products.’[178]

Concerns about further restrictions on gambling advertising

5.99Organisations that have a financial interest in the advertising of online gambling products, such as media and sporting organisations, and some online WSPs, raised concerns about further restrictions on gambling advertising.

Broadcasters

5.100Gambling advertising is a significant revenue stream for Australian commercial television and radio, however neither Free TV nor Commercial Radio and Audio (CRA) were willing to provide figures publicly to support their claims. Both Free TV and CRA provided evidence that was contrary to concerns about the frequency of gambling advertisements on commercial broadcasts and the likely exposure of children to gambling advertising.[179]

Commercial television

5.101Television broadcasters were concerned that any loss of advertising revenue would affect their ability to make and provide content.[180] For example, FreeTV Australia said:

Any further restrictions would have significant revenue implications for Australian TV networks…Further restrictions above and beyond the measures that are already in place would threaten Australians jobs and the television services that Australians rely on…Provision of sports for free would become increasingly difficult should gambling advertising be removed from revenue streams of commercial broadcasters.[181]

5.102Television broadcasters claimed the existing regulatory framework is effective in minimising children’s exposure,[182] and that children make up a small proportion of the audience for live sport.[183] Free TV claimed the audience for news and current affairs programs are predominantly adults[184] and that when children are watching sporting events, the majority are watching with their parents.[185] Free TV noted there is a perception in the community that gambling advertisements are on television all the time, but said ‘perception is not reality.’[186] Free TV stated, ‘you can't just impose regulations based on a vibe. You have to look at the evidence, you have to look at the data.’[187]

5.103Free TV and SBS both reported they receive few complaints or code breaches about gambling advertising[188] and said this shows that current restrictions are effective[189] and meeting community expectations.[190] They promoted the need for a ‘balance’ in rules that both protect the community and allow a legal product to be advertised.[191]

5.104Free TV referred to sports betting companies as significant advertising partners and outlined a range of financial pressure points for Australian free-to-air television broadcasters in justifying why it opposed further restrictions on gambling advertising.[192] Free TV claimed its members are ‘operating in a declining market with increasing competition’,[193] and that Australian content (which they are required to show)[194] and live sport is expensive to produce.[195]

5.105Free TV warned that broadcasters’ capacity to show live sport on free-to-air television would be compromised if they lost gambling advertising revenue, stating ‘…we're going to end up with rich people who can afford to watch important sporting events and poor people who can't’.[196]

5.106Free TV rejected the parallels drawn between restrictions on tobacco and gambling advertising, stating that the tobacco advertising bans ‘occurred at a time where television revenue was growing…where there was very limited competition for commercial television broadcasters; in fact, there was no competition because there were no streaming services or pay TV.’[197]

Commercial radio

5.107Similarly, the commercial radio industry is funded entirely by advertising, and although CRA expressed support for the reduction of gambling harm in Australia, it is concerned that any restrictions imposed ‘will erode the industry’s revenue base’ and impact services.[198] CRA warned that further restrictions could damage the viability of the commercial radio industry and result in unintended negative consequences for Australian communities, particularly in regional and remote areas.[199] CRA said that regional radio stations were especially vulnerable, noting ‘even a relatively small drop in revenue can be really significant for a small station, or even a network of small stations’[200] and that ‘there is a finite pool of advertising revenue’.[201] CRA also said it was important to ensure ‘free and universally accessible’ radio that provides local content including information during emergencies.[202]

5.108CRA argued for commercial radio to be treated differently than other platforms because there are no commercial radio programs targeted at children, and that when children listen to commercial radio it is normally in the car when they are being supervised by an adult.[203] CRA claimed there was also a ‘lack of radio specific evidence’ that demonstrates advertising contributes to gambling harm.[204]

5.109CRA argued that any further gambling advertising restrictions should exempt horse, harness and dog racing broadcasts because ‘listeners understand that gambling is a core part of the broadcast’ and these ‘broadcasts do not have the general appeal of other commercial radio broadcasts but instead provide specialised racing content’.[205] CRA also called for a publisher’s exemption, so broadcasters ‘are not expected to ascertain the compliance of third-party advertising’.[206]

Sporting codes

5.110The Coalition of Major Professional and Participation Sports (COMPPS)[207] said that, while they are supportive of appropriate regulation of gambling advertising, ‘legitimate and regulated gambling and the revenue derived from it (and associated advertising) form an important part of the business model of the sports.’[208] COMPPS reported that revenue from sports betting, media rights deals and gambling sponsorship funds sport in Australia, both at elite and grassroots level:

Sport receives a significant benefit from advertising on sport as it drives rights fees for television, radio and other media agreements. If advertising revenue is diminished, the value of sports media rights will diminish. Revenue from media rights is the principal source of income for the major professional sports in Australia…Sponsorship is a major source of income for sporting organisations at all levels, with sports betting operators having emerged in recent years as viable sponsors of teams and events.[209]

5.111COMPPS claimed the restrictions in the BSA were ‘reasonable and responsible’,[210] and struck a balance between:

• the public interest in watching sport without excessive references to gambling and live odds, or undue exposure of viewers to gambling promotion
• the right of Australia’s licenced online WSPs to advertise their products in a socially responsible manner.[211]
  112. COMPPS made similar arguments in 2017 when the Government was pursuing the ban on gambling advertising during live sporting events. In its submission to the Senate Environment and Communications Legislation Committee, COMPPS claimed the existing regulatory framework was effective and any changes would adversely affect ‘…the capacity of our sports to reinvest revenue in our integrity departments as well as grassroots and development programs, community programs, and the broader communities in which our sports are played.’[212]
  113. The Committee was interested in whether all COMPPS members agreed with COMPPS’ submission to this inquiry and if members had further comments to make to justify their support for the status quo in gambling advertising restrictions. AFL and NRL appeared before the Committee at a public hearing on 4 April 2023. Other COMPPS members provided near-identical letters supporting COMPPS submission.[213]

TheAFL and NRL

5.114Both AFL and NRL acknowledged concerns about the harms of gambling advertising but did not support any changes to current restrictions that would significantly affect their bottom lines. Both called for regulation that balanced protecting the community with the interests of those who deliver gambling advertising.[214]

5.115While both AFL and NRL were reluctant to provide estimates of their dependence on online gambling revenue, the Committee heard that both sports are significantly leveraged by gambling interests and that a loss of gambling revenue would affect their operations.[215] It would seem this is in large part because the codes do not just receive sponsorship payments from online WSPs, but also receive a percentage of income from bets placed on their matches.

5.116In a radio interview, AFL appeared to concede there was too much gambling advertising in AFL,[216] but subsequently moderated these comments, claiming that the issue of inducements is ‘actually what our supporters and our fans are talking to.’[217] Despite evidence to this inquiry demonstrating that young people have high brand recall from gambling advertisements, AFL claimed that current levels of brand advertising is acceptable.[218] This echoed the position taken by Sportsbet, who is AFL’s sponsor and key advertising partner.[219]

5.117NRL was similarly open to exploring further restrictions on the type of advertising that is allowed, but argued restrictions need to be data-led and should not involve blanket bans.[220]

5.118AFL suggested that attention should be focussed on addressing gambling advertising on social media, rather than broadcast television, ‘because that is where the kids are.’[221]

5.119As previously noted, in addition to receiving gambling advertising revenue, major sports like the AFL and NRL have a direct financial interest in licenced online gambling through the product fees they receive from every bet placed on their sport. The sports assert that product fees are part of ‘integrity agreements' in place between the sports and licenced WSPs. AFL and NRL claim that this revenue is reinvested into sports integrity measures and support for grassroots sports.[222]

5.120AFL suggested that integrity agreements enable it to enforce ‘binding obligations on companies to report illegal or suspicious gambling activity on our competitions.’[223] AFL said ‘we like to also have relationships with the wagering partners so we can influence bet types, get access to information and protect the integrity of our competition.’[224] AFL said that ‘it would go on without us and therefore the money that we receive, we reinvest. We're a not-for-profit, so we actually think that's a community benefit.’[225]

5.121AFL and NRL both warned of unintended consequences that may arise from further restrictions on licenced WSPs and their advertisements, in particular an increase in Australians gambling with illegal offshore operators.[226] AFL said this would ‘increase integrity risks’ and noted that illegal operators may continue to provide online in-play betting and be able to advertise their products on online platforms.[227] AFL said ‘this potentially poses a real danger to all Australian sport.’[228]

Licenced online WSPs

5.122The licenced online WSPs represented by RWA acknowledged community concerns about gambling advertising,[229] while arguing that any further restrictions must be sensible,[230] evidence-based,[231] practical[232] and pragmatic.[233] For example, Entain conceded that the volume of gambling advertising is no longer meeting community expectations[234] and that children were being exposed to gambling advertising.[235]

5.123Sportsbet said that regulation should be ‘balanced against the economic and commercial legitimacy of advertising as a legally regulated product.’[236] According to Sportsbet, gambling marketing enables WSPs to ‘identify themselves, and to provide product information and choice’.[237]

5.124Licenced online WSPs emphasised the importance of gambling advertising revenue for their sports and broadcasting partners and the integrity of sports,[238] and warned further restrictions on gambling advertising risked an increase in illegal online gambling.[239] For example, Sportsbet claimed the ability for Australians to watch sport on free-to-air television may be at risk if gambling advertising was restricted.[240]

Tabcorp

5.125Tabcorp supported a ban on gambling advertising between 6.30 am and 8.30 pm on free-to-air television, noting that ‘Australian families and children should be able to watch live sport and television without being bombarded by gambling advertising.’[241] Tabcorp said it would implement this voluntarily ‘if an agreement cannot be reached in a reasonable timeframe.’[242]

5.126Tabcorp also said they would support a ban on in-stadia advertising and sponsorship. Tabcorp said that team sponsorship is a competitive space for advertisers and there are ‘other, broader industry sponsors and advertisers who are prepared to sponsor sporting teams.’[243]

5.127Tabcorp denied it was seeking a competitive advantage[244] in its support for further restrictions, which it said should apply to sports broadcasts but not racing.[245] Tabcorp argued that gambling advertisements during racing broadcasts were a lower risk to children because ‘whoever’s watching that program is there to watch racing’, which is primarily a betting sport.[246]

Lotteries

5.128The Lottery Corporation and the Australian Lottery and Newsagents Association both argued that lotteries should be excluded from gambling advertising restrictions.[247] They argued that people spend less money on lotteries and that lotteries are less harmful than other forms of gambling.[248] Restrictions on the advertising of lotteries could hurt newsagents, which are mostly small businesses.[249]

Committee comment

5.129Australians demand an end to saturation advertising of gambling products. Claims from broadcasters that this clear community sentiment is based on a ‘vibe’ seeks to diminish Australians’ lived experience and frustration, and the findings of independent research.

5.130While online gambling is a legal product that some adult Australians can enjoy safely, online gambling and gambling advertising is harming Australians, particularly children, young people and those experiencing gambling addictions. The current rules allowing gambling’s widespread advertising do not appropriately reflect its potential for harm and are clearly not meeting community expectations.

5.131Gambling advertising influences children and young people’s intentions to gamble, grooming them to be future customers, and encourages riskier betting. It is manipulating an impressionable and vulnerable audience, who are being exposed to gambling material across all media. It is inescapable.

5.132While it is true that parents should be having discussions with their children about the risks of gambling, they can’t do it all on their own. Parents cannot always police their children’s media use and should not be expected to interpret the complex and confusing rules to figure out when it is safe for their children to watch television.

5.133Online gambling has been deliberately and strategically marketed alongside sport, which has normalised it as a fun, harmless, and sociable activity that is part of a beloved pastime. Australians have been taught to believe they are a culture of gamblers, but never hear about addiction, gambling disorder, the lives that are cut short to suicide, the broken families and ruined relationships, the debt, bankruptcy and poverty, the shame and stigma or the prison sentences.

5.134Major sporting codes pride themselves on their links with community and social responsibility. Yet, they have a direct financial interest in Australians’ gambling losses and the interests of their wagering partners through product fees. The sporting codes earn much of their revenue through sports rights deals with broadcasters, who in turn make money from advertising spots placed by the gambling industry.

5.135Australia’s sporting codes and broadcast media werelargely in lockstep with their advertising and sponsorship partners in the gambling industry during this inquiry to oppose further restrictions. The inquiry would have benefited from evidence on the public record, particularly from broadcasters clarifying just how heavily dependent they are on gambling revenue, given their dire warnings of what would happen if further restrictions on advertising were introduced. This lack of transparency is regrettable. The Committee notes that the sporting codes which appeared at the inquiry did not provide any specifics of how their operations would be changed or cut back if their gambling revenue was restricted.

5.136Free TV attempted to spin both ways during this inquiry. They were happy to provide figures that downplayed children’s exposure to gambling advertising and minimised the total volume of advertising on television screens. However, Free TV also claimed commercial television was so dependent on gambling advertising revenue that the broadcast of free-to-air sport was at risk if further restrictions were introduced, without providing revenue figures that would allow transparent debate.

5.137The strategies and language used by those with an interest in gambling advertising revenue to argue against further restrictions are nearly identical to what sports and broadcasters used in their campaigns against tobacco advertising reforms. It is a shame that harmful industries appear to gain so much leverage over sports and media organisations.

5.138Sporting organisations and the media should not be blamed for their part in Australia’s gambling ecosystem because the regulatory framework has allowed this to occur. However, the Committee considers that not-for-profit organisations that promote healthy activities should not be propped up by harmful industries that can and do have devastating impacts on the lives of their fans, their families, and communities. Sports should not be viewed as a ‘gambling product’. Australians are already demanding their games be reclaimed from gambling interests. These demands are only going to grow louder.

5.139A phased, comprehensive ban on all gambling advertising on all media, that leaves no room for circumvention, is needed. Partial bans on gambling advertising do not work. The 2017 media reforms resulted in gambling advertising on television increasing. Harmful industries have shown they will identify and capitalise on any gaps in marketing restrictions and that they are taking advantage of the less regulated online environment.

5.140The prohibition on all forms of online gambling advertising should be enforced sequentially, with advertising that has the highest risk of harm addressed immediately. Toenable sporting bodies and broadcasters adequate time to locate alternative sources of advertising revenue and to comply with current contractual obligations, the comprehensive ban should be phased in over a three-year period. The Committee’s view is that this should commence in December 2023, resulting in the prohibition of all online gambling advertising by December2026. Phased restrictions on broadcasters should similarly apply to streaming services. The need for reform is immediate and urgent, and reform should not be delayed without exceptional reasons (for example, the consequences of breaching contractual obligations which extend beyond proposed implementation times). Consideration should be given to appropriate support or compensatory arrangements over the implementation period.

5.141Phase One - inducements and inducement advertising, and advertising on online platforms have the highest risk of harm and influence on children and should be banned immediately. Gambling advertisements during news and current affairs broadcasts should also be immediately prohibited, as well as on commercial radio between 8.30-9.00am and 3.30-4.00pm (school drop off and pick up).

5.142Phase Two - major sports and broadcasters should be given appropriate time to begin making alternative sponsorship deals and find replacements for the revenue they receive from gambling advertising. However, from the beginning of 2025, Australians should no longer be exposed to online gambling advertising from an hour before to an hour after the broadcast of live sport. There should be no in-stadia gambling advertising and no logos on player uniforms.

5.143Phase Three - by the end of 2025, there should be no online gambling advertising broadcast between the hours of 6.00am and 10.00pm. The Committee is aware that this will not protect children watching outside of these hours, however it will provide broadcasters time to develop alternative advertising revenue streams.

5.144Phase Four - by the end of 2026, sporting organisations will have had more than three years to make alternative sponsorship arrangements. At this point, all online gambling advertising should cease.

5.145The states and territories have indicated a preference for a collective and uniform response to gambling advertising reform, led by the Australian Government. The Committee agrees, and the Australian Government should implement the reforms through national legislation. ACMA should be resourced to take on a larger regulatory role and requires stronger administrative powers and meaningful penalties to enforce these changes.

5.146The Committee recognises that the audiences of dedicated racing channels are there for the purpose of gambling. These channels should be exempt from further restrictions. Similarly, lotteries have a lower risk of gambling harm than other forms of online gambling and should also be exempt from further restrictions.

5.147Small community radio broadcasters, particularly those in regional and rural Australia, should be exempt from further restrictions until December 2025, in recognition that restrictions will have a more significant impact on smaller broadcasters. Consideration should be given to compensatory arrangements.

5.148The Committee recommends the Australian Government, with the cooperation of the states and territories, implement a comprehensive ban on all forms of advertising for online gambling, to be introduced in four phases, over three years, commencing immediately:

• Phase One: prohibition of all online gambling inducements and inducement advertising, and all advertising of online gambling on social media and online platforms. Removal of the exemption for advertising online gambling during news and current affairs broadcasts. Prohibition of advertising online gambling on commercial radio between 8.30-9.00am and 3.30-4.00pm (school drop off and pick up).
• Phase Two: prohibition of all online gambling advertising and commentary on odds, during and an hour either side of a sports broadcast. Prohibition on all in-stadia advertising, including logos on players’ uniforms.
• Phase Three: prohibition of all broadcast online gambling advertising between the hours of 6.00am and 10.00pm.
• Phase Four: by the end of year three, prohibition on all online gambling advertising and sponsorship.
  149. Gambling advertising on dedicated racing channels and programming should be exempt from the ban.
  150. Small community radio broadcasters should be exempt from further restrictions until December 2025.

Footnotes

[1]Mr Frank Fedrick, Submission 4, page 1; Stephen Brown, Submission 5, page 1;Name Withheld, Submission 8, page 1;Name Withheld, Submission 9, page 2;Ms Carole Flood, Margaret Bourke, SusanChessell et al, Submission 11, pages 2-3;Name Withheld, Submission13, page 2;Shannon Hall, Submission 14, page 1;Name Withheld, Submission 16, page 1;Mr Ric Bierbaum, Submission 19, page 1;Mr Jeremy Ryan, Submission 22, page 2;Mrs Annie Boehm, Submission 25, pages 3 and 5-6;MrMarkKempster, Submission 26, pages 1 and 4;Mr Walter Yeates, Submission 32, page 1; MrDavidThurley, Submission 33, page 1;Name Withheld, Submission 34, page 1; Name Withheld, Submission 35, page 1; Name Withheld, Submission 40, page 1; Name Withheld, Submission52, page 2; Carol Anderson, Submission 55, page 1;Name Withheld, Submission 63, page 1;Name Withheld, Submission 73, pages 1-2;. Lynda Genser, Submission 80, page 2; Name Withheld, Submission112, pages2-4; L. Barry Wollmer, Submission 120, page 1;Name Withheld, Submission 122, page 1;AnnaBardsley, Submission 128, pages 1-3;Name Withheld, Submission 131, page 2;Name Withheld, Submission 132, page 1;Ian Robinson, Submission 133, page 1;Paul Flemming, Submission 149, page 1; Gordon Gillam, Submission 155, page 1. See also, ACMA, Gambling advertising in Australia – Consumer and advertising placement research, November 2019, p. 39.

[2]Australian Institute of Family Studies’ Australian Gambling Research Centre (AGRC), Exhibit 21b, ‘Community attitudes towards sports and race betting advertising in Australia’, March 2023, page 2.

[3]Parliamentary Friends of Gambling Harm Reduction, Submission 58, page 1; Shane Rattenbury MLA, Submission 82, page 5; Government of South Australia, Liquor and Gambling Commissioner, Submission121, pages 5-6; NSW Government, Submission 114, page 11; Tasmanian Liquor and Gaming Commission, Submission 67, page 1; Dr Sophie Scamps MP, Submission 100, page 3.

[4]Australian Communications and Media Authority (ACMA), Submission 96, page 5; Mr Adam Carlon, Assistant Secretary, Media Industry and Sustainability, Department of Infrastructure, Transport, Regional Development, Communications and the Arts (DITRDCA), Committee Hansard, 30November2022, page 2.

[5]Associate Professor Charles Livingstone, Submission 113, page 7.

[6]The Australia Institute, Submission 10, Attachment B, page 1.

[7]AGRC, Exhibit 21b, ‘Community attitudes towards sports and race betting advertising in Australia’, March2023, page 4.

[8]AGRC, Exhibit 21b, ‘Community attitudes towards sports and race betting advertising in Australia’, March2023, page 3.

[9]ACMA, Gambling advertising in Australia – Consumer and advertising placement research, November2019, p. 2.

[10]ACMA, Gambling advertising in Australia – Consumer and advertising placement research, November2019, p. 40.

[11]Shane Rattenbury MLA, Submission 82, page 5-6, 11-12;Government of South Australia, Liquor and Gambling Commissioner, Submission 121, pages 3, 5-6; Tasmanian Liquor and Gaming Commission, Submission 67, page 1-2; Queensland Government, Submission 140, page 2; NSW Government, Submission 114, page 11.

[12]Queensland Government, Submission 140, page 2; Government of South Australia, Liquor and Gambling Commissioner, Submission 121, page 3; Tasmanian Liquor and Gaming Commission, Submission 67, pages1-2.

[13]Shane Rattenbury MLA, Attorney-General and Minister for Gaming, Australian Capital Territory, CommitteeHansard, 28 February 2023, page 33.

[14]Government of South Australia, Liquor and Gambling Commissioner, Submission 121, page 8; ShaneRattenbury MLA, Submission 82, page 5; Queensland Government, Submission 140, page 1. Tasmanian Liquor and Gaming Commission, Submission 67, page 2.

[15]Queensland Government, Submission 140, page 1.

[16]Alliance for Gambling Reform (AGR), Submission 48,page 8.

[17]Emeritus Professor Mike Daube, Faculty of Health Sciences, Curtin University, Committee Hansard, 10February 2023, page 60.

[18]Professor Samantha Thomas, Private Capacity, Committee Hansard, 10 February 2023, page 45.

[19]Australian Institute of Family Studies (AIFS), Sports betting and advertising, November 2014, page 3.

[20]AGRC, Submission 76, page 10.

[18]Australian Health Promotion Association (AHPA), Submission 54, page 2; Department of Social Services, Submission 87, page 10.

[19]Professor Samantha Thomas, Dr Hannah Pitt and Dr Simone McCarthy, Submission 126, page 5.

[20]Government of South Australia, Liquor and Gambling Commissioner, Submission 121,page 5.

[21]AGRC, Exhibit 21d, ‘Exposure and impact of sports and race betting advertising in Australia’, March 2023, page 1.

[22]AGR, Submission 48,page 7.

[23]AGR, Submission 48,page 8; Professor Samantha Thomas, Dr Hannah Pitt and Dr Simone McCarthy, Submission 126, page 7.

[24]AGR, Submission 48,page 7.

[25]Professor Samantha Thomas, Dr Hannah Pitt and Dr Simone McCarthy, Submission 126, page 7.

[26]Government of South Australia, Liquor and Gambling Commissioner, Submission 121,page 5.

[27]ACMA, Submission 96, page 6.

[28]Turning Point and the Monash Addiction Research Centre, Submission 68, page 20.

[32]New South Wales Government, Submission 114, page 12.

[33]ACMA, Gambling advertising in Australia – Consumer and advertising placement research, November 2019, page 32.

[34]Mr Mark Kempster, Committee Hansard, 10 February 2023, page 12.

[29]Government of South Australia, Liquor and Gambling Commissioner, Submission 121,page 2.

[30]ACMA, Gambling advertising in Australia – Consumer and advertising placement research, November 2019, page 30.

[31]AIFS, Sports betting and advertising, November 2014, page 5.

[32]AHPA, Submission 54, page 2; Government of South Australia, Liquor and Gambling Commissioner, Submission 121,page 2; Australian Psychological Society, Submission 109, page 6.

[33]Professor Samantha Thomas, Dr Hannah Pitt and Dr Simone McCarthy, Submission 126, page 5.

[34]Professor Samantha Thomas, Committee Hansard, 10 February 2023, page 45.

[35]AHPA, Submission 54, page 3; Professor Samantha Thomas, Dr Hannah Pitt and Dr Simone McCarthy, Submission 126, page 6.

[36]Australian Medical Association (AMA), Submission 83, page 5.

[37]Victorian Responsible Gambling Foundation (VRGF), Exhibit 12, ‘Gambling Harm and the Online Gambling Environment’, February 2023, page 2

[38]AFL Fans Association, AFLFA 2022 Fans Survey, March 2023, page 14.

[39]AFL Fans Association, AFLFA 2022 Fans Survey, March 2023, page 5.

[40]NSW Government, Submission 114, page 12.

[41]NSW Government, Submission 114, page 12.

[42]AGR, Submission 48, page 7-8; AMA, Submission 83, page 4; See also, Chapter one.

[43]Gambling Treatment and Research Clinic, University of Sydney (GTRC), Submission 65, page 19.

[44]Miss Nidhi Rao, Submission 57, page 6.

[45]Dr Rebecca Jenkinson, Executive Manager, AGRC, Committee Hansard, 5 April 2023, page 7.

[46]Professor Shalini Arunogiri, Chair, Faculty of Addiction Psychiatry, Royal Australian and New Zealand College of Psychiatrists, Committee Hansard, 7 March 2023, page 7.

[47]Professor Samantha Thomas, Dr Hannah Pitt and Dr Simone McCarthy, Submission 126, pages 6-7. Government of South Australia, Liquor and Gambling Commissioner, Submission 121,page 8.

[48]Dr Marisa Paterson MLA, Submission 69, page 4; AGR, Submission 48, page 20.

[49]Professor Samantha Thomas, Dr Hannah Pitt and Dr Simone McCarthy, Submission 126, page 6; DrChristopher Hunt, Senior Clinical Supervisor, GTRC, Committee Hansard, 1 March 2023, page40.

[50]AGRC, Submission 76, page 10.

[51]Royal Australian and New Zealand College of Psychiatrists and Royal Australasian College of Physicians, Submission 110, page 8.

[52]Deakin University, Study shows betting ads influencing children's attitudes to gambling, www.deakin.edu.au/about-deakin/news-and-media-releases/articles/study-shows-betting-ads-influencing-childrens-attitudes-to-gambling, viewed 29 March 2023.

[53]AIFS, Sports betting and advertising, November 2014, page 5.

[54]Professor Samantha Thomas, Committee Hansard, 10 February 2023, page 48.

[55]Professor Samantha Thomas, Committee Hansard, 10 February 2023, page 45.

[56]Mr Jeremy Ryan, Committee Hansard, 14 February 2023, page 3.

[57]GTRC, Submission 65, page 20; Suicide Prevention Australia, Submission 41, page 9; ProfessorSallyGainsbury, Director, GTRC, Committee Hansard, 1 March 2023, page 37.

[58]Central Queensland University, Submission 24, page 7.

[59]AIFS, ‘Sports betting and advertising’, November 2014, p. 8, www.aifs.gov.au/resources/policy-and-practice-papers/sports-betting-and-advertising, viewed 7 March 2023.

[60]Banyule Community Health, Submission 75, page 5.

[61]Ms Trina Fazio, Gambler's Help Therapeutic Counsellor, Banyule Community Health, Committee Hansard, 1March 2023, page 57.

[62]DITRDCA, Submission 104.1, pages 5-6.

[63]DITRDCA, Submission 104.1, page 6.

[64]Government of South Australia, Liquor and Gambling Commissioner, Submission 121, page 1.

[65]Parliament of Australia, ‘Media and broadcasting in the digital age’, www.aph.gov.au/About_Parliament/Parliamentary_Departments/Parliamentary_Library/pubs/BriefingBook46p/MediaBroadcasting, viewed 16 January 2023.

[66]DITRDCA, Submission 104, page 10.

[67]ACMA, Submission 96, page 13.

[68]ACMA, ‘Gambling advertising in Australia – Consumer and advertising placement research’, November2019, p. 1, www.acma.gov.au/publications/2019-11/report/gambling-advertising-research, viewed3 February 2023.

[69]DITRDCA, Submission 104, page 11.

[70]Communications Legislation Amendment (Online Content Services and Other Measures) Bill 2017.

[71]ACMA, ‘Gambling advertising in Australia – Consumer and advertising placement research’, November2019, page 1, www.acma.gov.au/publications/2019-11/report/gambling-advertising-research, viewed 3 February 2023.

[72]DITRDCA, Submission 104, page 12-13.

[73]ACMA, Submission 96, page 14-15.

[74]DITRDCA, Submission 104, page 13.

[75]ACMA, ‘Gambling advertising in Australia – Consumer and advertising placement research’, November2019, page 44, www.acma.gov.au/publications/2019-11/report/gambling-advertising-research, viewed 3 February 2023.

[76]ACMA, Submission 96, page 15.

[77]ACMA, ‘Gambling advertising in Australia – Consumer and advertising placement research’, November2019, page 45, www.acma.gov.au/publications/2019-11/report/gambling-advertising-research, viewed 3 February 2023.

[78]Ms Cathy Rainsford, General Manager, ACMA, Committee Hansard, 30 November 2022, page 4.

[79]Free TV Australia (Free TV), Submission 72, page 4.

[80]Free TV, Submission 72, pages 4-5.

[81]Free TV, Submission 72, page 4.

[82]ACMA, Submission 96.1, pages 1-2.

[83]Free TV, Submission 72, page 5.

[84]Free TV, Submission 72, page 4.

[85]Commercial Radio, Commercial Radio Code of Practice, updated March 2018, pages 13-18.

[86]SBS, Code of Practice, July 2021, page 12.

[87]SBS, Submission 66, page 2.

[88]DITRDCA, Submission 104, page 17.

[89]SBS, Submission 66, page 2.

[90]ACMA, Submission 96, page 1.

[91]ACMA, Submission 96, page 12.

[92]Digital Industry Group, Submission 142, page 5.

[93]DITRDCA, Submission 104, page 11.

[94]Australian Association of National Advertisers (AANA), Codes and Guidelines’, www.aana.com.au/self-regulation/codes-guidelines,viewed 15 March 2023.

[95]Ad Standards, Submission 59, page 2.

[96]Ad Standards, ‘Ad Standards’, www.adstandards.com.au/about/ad-standards, viewed 15 March 2023.

[97]DITRDCA, Communications and the Arts, Submission 104, page 11.

[98]AANA, Submission 21, page 3.

[99]Mr Richard Bean, Executive Director, Ad Standards, Committee Hansard, 10 February 2023, page 54.

[100]SBS, Submission 66, page 4.

[101]AANA, Submission 21, page 4.

[102]AANA, Submission 21, page 4.

[103]AANA, Submission 21, page 3.

[104]AANA, Submission 21, page 2.

[111]Government of South Australia, Liquor and Gambling Commissioner, Submission 121, page 5.

[112]Emeritus Professor Mike Daube, Submission 137, page 4.

[105]Dr Marisa Paterson MLA, Submission 69, page 6.

[106]Turning Point and the Monash Addiction Research Centre, Submission 68, page 20.

[107]Professor Samantha Thomas, Dr Hannah Pitt and Dr Simone McCarthy, Exhibit 23, ‘Protecting children and young people from contemporary marketing for gambling’, 2023, page 4; Turning Point and the Monash Addiction Research Centre, Submission 68, page 20; GTRC, Submission 65, page 19.

[108]Queensland Government, Submission 140, page 2; AHPA, Submission 54, page 3; QueenslandGovernment, Submission 140, page 2.

[109]Children and Media Australia, Submission 102, page 4; Turning Point and the Monash Addiction Research Centre, Submission 68, page 20; Gambling Treatment and Research Clinic, University of Sydney, Submission 65, page 19; ACMA, Gambling advertising in Australia – Consumer and advertising placement research, November 2019, p. 20.

[110]Professor Samantha Thomas, Dr Hannah Pitt and Dr Simone McCarthy, Submission 126, page 8.

[111]Professor Elizabeth Handsley, President, Children and Media Australia, Committee Hansard, 7February2023, page 2.

[112]Queensland University of Technology (QUT), Submission 91, page 4; ACMA, Gambling advertising in Australia – Consumer and advertising placement research, November 2019, p. 2.

[113]AHPA, Submission 54, page 3. Turning Point and the Monash Addiction Research Centre, Submission 68, page 20. Queensland Government, Submission 140, page 2.

[114]Turning Point and the Monash Addiction Research Centre, Submission 69, page 20.

[115]Queensland Government, Submission 140, page 2.

[116]Turning Point and the Monash Addiction Research Centre, Submission 68, page 20.

[117]Mr Kieran Hough, Senior Social Worker, Victorian Arabic Social Services, Committee Hansard, 14February2023, page 8.

[118]Free TV, Submission 72.2, page 4.

[119]QUT, Submission 91, page 4.

[120]Australian Association of National Advertisers, Submission 21, page 2.

[121]Mr Richard Bean, Executive Director, Ad Standards, Committee Hansard, 10 February 2023, page 54.

[122]Ad Standards, Submission 59, page 1.

[123]Mr Richard Bean, Executive Director, Ad Standards, Committee Hansard, 10 February 2023, page 56.

[124]Office of the Australian Information Commissioner (OAIC), Submission 145, page 2.

[125]Turning Point and the Monash Addiction Research Centre, Submission 68, page 21.

[126]Dr Aino Suomi, Submission 90, page 6.

[127]OAIC, Submission 145, page 2.

[128]Turning Point and the Monash Addiction Research Centre, Submission 68, page 21. TikTok’s trial with Sportsbet has now been expanded to include partnerships with Neds and Dabble. See HBelot, ‘TikTok Australia expands trial of gambling advertising despite widespread criticism’, The Guardian, 20 May 2023.

[129]OAIC, Submission 145, page 3.

[130]OAIC, Submission 145, page 2.

[131]OAIC, Submission 145, page 2.

[132]OAIC, Submission 145, page 2.

[133]The Hon Mark Dreyfus KC MP, Attorney-General, ‘Landmark Privacy Act Review report released’, Mediarelease, 16 February 2023

[134]The Hon Mark Dreyfus KC MP, Attorney-General, ‘Landmark Privacy Act Review report released’, Mediarelease, 16 February 2023

[135]Attorney-General’s Department, Privacy Act Review Report 2022, February 2023.

[136]OAIC, Submission 145, page 5. OAIC, Australian Privacy Principles,www.oaic.gov.au/privacy/australian-privacy-principles, viewed 11 May 2023. The Australian Privacy Principles apply to any organisation or agency the Privacy Act 1988 covers.

[137]OAIC, Submission 145, page 4.

[138]OAIC, Submission 145, page 4.

[139]OAIC, Submission 145, page 4.

[140]QUT, Submission 91, page 3; Professor Samantha Thomas, Dr Hannah Pitt and Dr Simone McCarthy, Submission 126, page 9; Financial Counselling Australia (FCA), Submission 152, page 6; Royal Australian and New Zealand College of Psychiatrists and Royal Australasian College of Physicians, Submission 110, page 8; Public Health Association of Australia, Submission 125, page 1; Ms Louise Francis, Member, AHPA, Committee Hansard, 10 February 2023, page 21.

[141]Children and Media, Submission 102, page 4.

[142]Emeritus Professor Mike Daube, Submission 137, page 4; FCA, Submission 152, page 6.

[143]ACMA, Gambling advertising in Australia – Consumer and advertising placement research, November 2019, pages 10-11.

[144]ACMA, Gambling advertising in Australia – Consumer and advertising placement research, November 2019, page 8.

[145]ACMA, Gambling advertising in Australia – Consumer and advertising placement research, November 2019, pages 10-11.

[146]ACMA, Gambling advertising in Australia – Consumer and advertising placement research, November 2019, page 12.

[151]Mr Nick Minchin, Chairman, Responsible Wagering Australia, Committee Hansard, 4 April 2023, page 55.

[147]FCA, Submission 152, page 6.

[148]Professor Samantha Thomas, Committee Hansard, 10 February 2023, page 46.

[149]Professor Samantha Thomas, Committee Hansard, 10 February 2023, page 47.

[150]Dr Angela Rintoul, Submission 150, page 3. Associate Professor Charles Livingstone, Submission 113, page7; Emeritus Professor Mike Daube, Submission 137, page 6.

[151]Associate Professor Charles Livingstone, Submission 113, page 7.

[152]Associate Professor Charles Livingstone, Committee Hansard, 28 February 2023, page 20.

[153]Associate Professor Charles Livingstone, Submission 113, page 7.

[154]Mr Gillon McLachlan, Chief Executive Office, AFL, Committee Hansard, 4 April 2023, pages 30-31 and 33; MrAndrewAbdo, Chief Executive Office, NRL, Committee Hansard, 4 April 2023, page 32.

[155]Emeritus Professor Mike Daube, Submission 137, page 3; Associate Professor Charles Livingstone, Submission 113, page 6; Dr Angela Rintoul, Submission 150, page 3.

[156]Emeritus Professor Mike Daube, Submission 137, page 3.

[157]Emeritus Professor Mike Daube, Submission 137, page 4.

[158]Emeritus Professor Mike Daube, Submission 137, page 4.

[159]Emeritus Professor Mike Daube, Submission 137, page 4.

[160]Tobacco in Australia, Background, www.tobaccoinaustralia.org.au/chapter-11-advertising/11-0-background, viewed 18 April 2023.

[161]Emeritus Professor Mike Daube, Submission 137.1, page 1.

[162]Emeritus Professor Mike Daube, Submission 137.1, page 1.

[163]Emeritus Professor Mike Daube, Submission 137.1, page 3.

[164]Emeritus Professor Mike Daube, Submission 137.1, page 6.

[165]Emeritus Professor Mike Daube, Submission 137.1, page 4.

[166]Emeritus Professor Mike Daube, Submission 137.1, page 8.

[167]Emeritus Professor Mike Daube, Submission 137.1, page 2.

[168]Associate Professor Charles Livingstone, Committee Hansard, 28 February 2023, page 20.

[169]Associate Professor Charles Livingstone, Submission 113, page 5.

[170]Associate Professor Charles Livingstone, Submission 113, page 7.

[171]Turning Point and the Monash Addiction Research Centre, Submission 68, page 22.

[172]Dr Aino Suomi, Submission 90, page 6.

[173]FCA, Submission 152, pages 33-34.

[174]Suicide Prevention Australia, Submission 41, page 10.

[175]FCA, Submission 152, page 34.

[176]FCA, Exhibit 20, ‘The sky didn’t fall in’, Winston Churchill Trust, March 2023, page 7.

[177]QUT, Submission 91, page 5.

[178]QUT, Submission 91, page 5.

[179]Free TV, Submission 72.1, page 1 and Submission 72.2, pages 1-4; Ms Bridget Fair, Chief Executive Officer, Free TV Australia, Committee Hansard, 10 February 2023, page 27; Ms Sarah Kruger, Head, Policy and Legal Affairs, Commercial Radio and Audio (CRA), Committee Hansard, 28February2023, page 29.

[180]SBS, Submission 66, page 5; Free TV, Submission 72, page 8.

[181]Free TV, Submission 72, page 8.

[182]SBS, Submission 66, pages 2-4. Free TV, Submission 72, pages 4-5.

[183]SBS, Submission 66, page 5; Free TV, Submission 72, page 6.

[184]Ms Bridget Fair, Free TV Australia, Committee Hansard, 10 February 2023, page 27.

[185]Ms Bridget Fair, Free TV Australia, Committee Hansard, 10 February 2023, page 29.

[186]Ms Bridget Fair, Free TV Australia, Committee Hansard, 10 February 2023, page 35.

[187]Ms Bridget Fair, Free TV Australia, Committee Hansard, 10 February 2023, page 35.

[188]SBS, Submission 66, pages 4-5.

[189]Free TV, Submission 72, pages 4 and 7; SBS, Submission 66, page 1.

[190]SBS, Submission 66, page 1.

[191]Ms Bridget Fair, Free TV Australia, Committee Hansard, 10 February 2023, pages 28-29; MsClareO’Neil, Director, Corporate Affairs, SBS, Committee Hansard, 10 February 2023, page40.

[192]Ms Bridget Fair, Free TV Australia, Committee Hansard, 10 February 2023, page 30.

[193]Ms Bridget Fair, Free TV Australia, Committee Hansard, 10 February 2023, page 32.

[194]Ms Bridget Fair, Free TV Australia, Committee Hansard, 10 February 2023, pages 30-31.

[195]Ms Bridget Fair, Free TV Australia, Committee Hansard, 10 February 2023, pages 30 and 37.

[196]Ms Bridget Fair, Free TV Australia, Committee Hansard, 10 February 2023, page 30.

[197]Ms Bridget Fair, Free TV Australia, Committee Hansard, 10 February 2023, page 32.

[198]Ms Sarah Kruger, CRA, Committee Hansard, 28 February 2023, page 26.

[199]Ms Sarah Kruger, CRA, Committee Hansard, 28 February 2023, pages 26-27.

[200]Ms Sarah Kruger, CRA, Committee Hansard, 28 February 2023, page 28.

[201]Ms Sarah Kruger, CRA, Committee Hansard, 28 February 2023, page 30.

[202]Ms Sarah Kruger, CRA, Committee Hansard, 28 February 2023, page 26.

[203]Ms Sarah Kruger, CRA, Committee Hansard, 28 February 2023, page 29.

[204]Ms Sarah Kruger, CRA, Committee Hansard, 28 February 2023, page 27.

[205]CRA, Submission 103, pages 5.

[206]CRA, Submission 103, pages 4.

[207]This organisation consists of consists of the Australian Football League (AFL), Cricket Australia, FootballAustralia, National Rugby League (NRL), Netball Australia, Rugby Australia, and Tennis Australia.

[208]Coalition of Major Professional and Participation Sports (COMPPS), Submission 42, page 6.

[209]COMPPS, Submission 42, pages 3-4.

[210]COMPPS, Submission 42, page 4.

[211]COMPPS, Submission 42, page 6.

[212]Senate Environment and Communications Legislation Committee, Inquiry into Communications Legislation Amendment (Online Content Services and Other Measures) Bill 2017, Submission 3, COMPPS, January2018, pages 2-3.

[213]COMPPS, Submission 42.1, pages 1-8.

[214]Mr Gillon McLachlan, AFL, Committee Hansard, 4 April 2023, page 27; MrAndrewAbdo, NRL, CommitteeHansard, 4 April 2023, page 27.

[215]Mr Gillon McLachlan, AFL, Committee Hansard, 4 April 2023, pages 30-31 and 33; MrAndrewAbdo, NRL, Committee Hansard, 4 April 2023, page 32.

[216]N Mitchell, ‘“Going a long time”: AFL boss addresses Hawthorn investigation, concussion class action’, 3AW, 17 March 2023.

[217]Mr Gillon McLachlan, AFL, Committee Hansard, 4 April 2023, page 30.

[218]Mr Gillon McLachlan, AFL, Committee Hansard, 4 April 2023, page 29.

[219]Mr Barni Evans, Chief Executive Officer, Sportsbet, Committee Hansard, 4 April 2023, pages 38 and 48.

[220]Mr Andrew Abdo, NRL, Committee Hansard, 4 April 2023, page 28.

[221]Mr Gillon McLachlan, AFL, Committee Hansard, 4 April 2023, page 30.

[222]Mr Andrew Abdo, NRL, Committee Hansard, 4 April 2023, page 27; Mr Gillon McLachlan, AFL, CommitteeHansard, 4 April 2023, page 26.

[223]Mr Gillon McLachlan, AFL, Committee Hansard, 4 April 2023, page 26.

[224]Mr Gillon McLachlan, AFL, Committee Hansard, 4 April 2023, page 33.

[225]Mr Gillon McLachlan, AFL, Committee Hansard, 4 April 2023, page 33.

[226]Mr Gillon McLachlan, AFL, Committee Hansard, 4 April 2023, page 26; Mr Andrew Abdo, NRL, CommitteeHansard, 4 April 2023, pages 32 and 34.

[227]Mr Gillon McLachlan, AFL, Committee Hansard, 4 April 2023, page 26.

[228]Mr Gillon McLachlan, AFL, Committee Hansard, 4 April 2023, page 26.

[229]Sportsbet, Submission 81, page 17; Entain, Submission 61, page 12; PointsBet, Submission 105, pages2and 4.

[230]Entain, Submission 61, page 13. PointsBet, Submission 105, page 4.

[231]Entain, Submission 61, page 13. Sportsbet, Submission 81, page 17.

[232]Sportsbet, Submission 81, page 17.

[233]PointsBet, Submission 105, page 4.

[234]Mr Steven Lang, Entain, Committee Hansard, 4 April 2023, page 17.

[235]Mr Steven Lang, Entain, Committee Hansard, 4 April 2023, page 18.

[236]Sportsbet, Submission 81, page 17.

[237]Sportsbet, Submission 81, page 15.

[238]Sportsbet, Submission 81, page 17; PointsBet, Submission 105, page 3

[239]Sportsbet, Submission 81, page 15; Mr Steven Lang, Director, Regulatory Strategy and Safer Gambling, Entain, Committee Hansard, 4 April 2023, page 18.

[240]Mr Barni Evans, Sportsbet, Committee Hansard, 4 April 2023, page 48.

[241]Tabcorp, Submission 101, page 5.

[242]Tabcorp, Submission 101, page 5.

[243]Mr Adam Rytenskild, Tabcorp, Committee Hansard, 4 April 2023, page 11.

[244]Mr Adam Rytenskild, Tabcorp, Committee Hansard, 4 April 2023, page 9.

[245]Tabcorp, Submission 101, page 5.

[246]Mr Adam Rytenskild, Tabcorp, Committee Hansard, 4 April 2023, page 9.

[247]The Lottery Corporation, Submission 74, page 2; Australian Lottery and Newsagents Association (ALNA), Submission 56, page 2.

[248]ALNA, Submission 56, page 2; STRSConsultants, Submission 28, page 3.

[249]The Lottery Corporation, Submission 74, page 4; ALNA, Submission 56, page 4.