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Jenni Garratt

Betting shops are top of the league for preventing under-18s using betting products

Jenni Garratt of Serve Legal writes about how consistent age verification testing has driven up pass rates.

It’s a very straight forward situation. Excluding the National Lottery, no-one under the age of 18 is allowed to gamble, regardless of whether they do that in a shop, online or at a race track. We work with a range of retail betting operators to help them prevent anyone under the age of 18 from using a bookmakers.

One of the first ever age verification testing exercises carried out by the Gambling Commission showed fewer than half of the betting shops tested had actually passed. A terrible result, yes, but it was one that could be addressed. And it was.


Firstly, everyone recognised this was an issue the industry was not taking seriously enough – it was the wake up call everyone needed.

Second, the industry worked together, rather than in competition, to have a set of agreed standards for testing.

And third, we introduced a ‘Think 21’ standard, where anyone who looks 21 or under is asked for proof of ID.

Serve Legal has been auditing age restricted sales since 2008, across all types of retailers and establishments. We carry out over 160,000 a year, whether that is in betting shops or anywhere else that offers age-restricted products, including pubs, tanning salons, supermarkets and cinemas.

Key to improving performance around age-restricted sales are management priority, staff training and continuous testing – including re-testing shops which fail within a short time.

Serve Legal’s audit programmes are completely independent and operators have no idea when or which shops will be tested. The first they know is when the result is shared with them and every result is shared with the Gambling Commission.

The testing itself has also evolved. Initially, the focus was on a straight pass or fail – if one of our auditors was asked for proof of age, at any point in the shop, before trying to place a bet, then that was a pass. If they were able to place a bet over the counter or play on a machine without being asked to prove they were at least 18, then that was a fail.

But since 2013 the focus has moved on to testing for what is called ‘challenge on entry’. This means that our auditors should always be asked for proof of age as soon as they enter a betting shop.

In addition, there are now very strict rules in place to ensure consistency in the audit process used across the sector. So whatever the shop, wherever it is, the auditing standards are the same.

Previously, operators were concerned that they could have shops in one part of the country tested by a local authority and fail, while another one of their shops could be tested in a different part of the country by another local authority and pass. There were no national standards in place. In 2009, the Government’s Primary Authority system addressed this by creating a nationally agreed set of standards for a variety of regulatory issues, including age verification. This means that all tests are fair and, crucially, consistent.

The evidence shows this consistent approach has worked. From being one of the worst offenders, betting shops now top the class, with the highest pass rates of any age-restricted product retailers – a higher pass rate than pubs, supermarkets, convenience stores and petrol stations.

What our audit programmes have shown is that a continuous focus on improving performance around age-restricted sales yields results. In the case of our work with the Betting and Gaming Council, we audit independent bookies, where initially the pass rates were very low, but have now improved significantly.

10 years ago, the pass rate for the whole bookmakers sector stood at 67%. Now, it is 91%. Since 2013, the challenge on entry pass rate has risen from 58% to 81%, and has not dropped below 80% for several years.

While it is very difficult to achieve 100% success, the fact is we will only drive the pass rates up by prioritising this important issue, training management and staff, and consistently testing and re-testing. Our audits have become a key part of a shop team’s work, and a key measurement on which a shop’s success is measured. We know from speaking with the BGC and its members that shop staff have immense pride when they have been given a pass, and take it personally if they get a fail, working hard to make sure it never happens again.

The reason for this success is straightforward. By constantly testing, and then re-testing those who fail, it means staff in betting shops are always focused on this vital part of their work, and are stopping under-18s from gambling before they have even crossed the threshold.


Serve Legal is the leading provider of compliance auditing services in the UK & Ireland. The company provides extensive independent audit services to retailers, leisure operators and sports broadcasters to check that key operational and compliance standards are in place across different areas of their business. Its highly accurate site audits help clients protect revenues, improve operational standards and support responsible retailing.

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