PGRWB 13 Betting and Gaming Council

Senedd Cymru | Welsh Parliament

Pwyllgor Diwylliant, Cyfathrebu, y Gymraeg, Chwaraeon, a Chysylltiadau Rhyngwladol | Culture, Communications, Welsh Language, Sport, and International Relations Committee

Bil Gwahardd Rasio Milgwn (Cymru) | Prohibition of Greyhound Racing (Wales) Bill

Ymateb gan: Y Cyngor Betio a Hapchwarae | Response from: Betting and Gaming Council

1. What are your views on the general principles of the Bill, and whether there is a need for legislation to deliver the stated policy intention?

The Betting and Gaming Council (BGC) represents over 90% of the UK’s regulated betting and gaming sector (excluding lotteries). Our sector supports 109,000 jobs, contributes £6.8 billion in economic value, and delivers £4 billion in tax revenue to the Exchequer annually. Our mission is to set world class standards to ensure an enjoyable, fair and safe betting experience for all of our customers.

As part of our mission, the BGC has introduced 20 Codes and 100 measures which our members abide by as a condition of membership to drive up standards and to support a sustainable and safer gaming environment for all. It is in this vein, the BGC believes that robust regulation and not prohibition is the most effective safeguard to welfare which also considers economic and social benefits. The BGC notes that the Greyhound Board of Great Britain (GBGB) provides an extremely robust framework to ensure the welfare and integrity of the sport.

Whilst we acknowledge and respect the Welsh Government’s autonomy in this area, we note that banning of greyhound racing is fundamentally opposed to UK government policy. On 27 February 2025, the Secretary of State of Culture, Media and Sport told the House of Commons:

“We have absolutely no plans whatsoever to ban greyhound racing. We appreciate the joy it brings to many, many people in our country and the economic contribution it makes.”

We support these comments by the Secretary of State, in that greyhound racing is a significant net contributor to the UK, not just in terms of economics but also the enjoyment it brings to fans of the sport, and the many people employed around the UK. The GBGB have a robust welfare system in place, ensuring that every greyhound participating within the sport receives the highest levels of care, both during their career and in retirement. The fact is, that banning greyhound racing will have a negative impact on welfare, not a positive one.

2. What are your views on the terms used in the Bill, whether defined or not? In particular, are they workable and will they deliver the stated policy intention?

The policy intention of the Bill is to prohibit greyhound racing in Wales, which will make it an offence to:

a) Operate a stadium or similar venue in Wales and use it, or knowingly permit it to be used, for greyhound racing; and

b) Be involved in organising greyhound racing in Wales.

If enacted, this Bill will deliver the stated policy intention. However, the BGC makes the following observation:

The Bill does not fully address the welfare of greyhounds nor the material threat that unregulated, illegal racing may be allowed to flourish in the absence of a regulated body presiding over the sport.

In progressing with this regulation, the Senedd must be confident that it has fully understood the welfare implications for greyhounds currently involved in racing within Wales and the wider impacts relating to a blanket ban. We defer to the GBGB for their detailed analysis of this.

3. What are your views on the provisions set out in sections 1 – 3 and Schedule 1 of the Bill -Prohibition of Greyhound Racing? In particular, are the provisions workable and will they deliver the stated policy intention?

The provisions set out in sections 1-3 are:

Prohibition of greyhound racing

(1) A person commits an offence if a person—

(a) is an operator of a stadium or similar venue in Wales and uses it, or knowingly permits it to be used, for greyhound racing, or

(b) is involved in organising greyhound racing in Wales.

(2) A person guilty of an offence under subsection (1) is liable on summary conviction to a fine.

Interpretation

In this Act—

(a) “greyhound racing” means setting greyhounds to run around a track in pursuit of a lure activated by mechanical means (and this includes timing or training a greyhound as it runs around a track);

(b) “operator” (in relation to a stadium or similar venue) means—

(i) the owner of the stadium or venue;

(ii) the person, other than the owner, with overall responsibility for the operation of the stadium or venue or, if that person is not present in the United Kingdom, the person in the United Kingdom responsible for the operation of the stadium or venue. Offences by bodies corporate etc.

Schedule 1 makes provision about offences under section 1 committed by bodies corporate, partnerships and unincorporated associations other than partnerships.

Schedule 1 of the Bill relates to Offences by Corporate Bodies detailing the commission of offences and proceedings.

The policy intention is to ban greyhound racing. Should the Bill be enacted sections 1-3 and Schedule 1 of the Bill will deliver the stated policy intention. However, the BGC makes the following observations:

Section 1 of the Bill will likely jeopardise the welfare of greyhounds in Wales as the regulated body of Greyhound racing will no longer be able to provide resources, care and support to Greyhounds during their lifetime.

Section 2 of the Bill includes the training of greyhounds which will likely result in Welsh based Greyhounds travelling intercountry in order train and compete, significantly impacting the greyhounds and increasing their risk of injury.

The BGC has no comments on Section 3.

The BGC has no comments on Schedule 1.

4. What are your views on the provisions set out in section 4 and Schedule 2 of the Bill - Enforcement? In particular, are the provisions workable and will they deliver the stated policy intention?

Section 4 relates to enforcement of prohibition of greyhound racing. Section 2 details these powers.

The policy intention is to ban greyhound racing. Should the Bill be enacted Schedule 2 will deliver the stated policy intention. The BGC again reiterates that robust regulation over prohibition is the best course of action and in the best interest for the welfare of greyhounds.

5. What are your views on the provisions set out in sections 5- 6 of the Bill – General? In particular, are the provisions workable and will they deliver the stated policy intention?

The provisions set out in sections 5-6 are:

Coming into force

(1) This section and section 6 come into force on the day after the day on which this Act receives Royal Assent.

(2) The remaining provisions of this Act come into force on a day appointed by the Welsh Ministers in an order made by Welsh statutory instrument, but they must be brought into force on a day that is—

(a) no sooner than 1 April 2027, and

(b) no later than 1 April 2030.

Title

This Act may be referred to as—

(a) the Prohibition of Greyhound Racing (Wales) Act 2026, or

(b) Deddf Gwahardd Rasio Milgwn (Cymru) 2026.

The policy intention is to ban greyhound racing. Should the Bill be enacted Schedule 2 will deliver the stated policy intention no sooner than 1st April 2027 and no later than 1 April 2030. However, the BGC makes the following observations: Should this Bill be enacted, there must sufficient resources available to rehome the inevitably large number of greyhounds who will no longer continue racing. Under the current regulated system, the GBGB is working towards a sustainable scheme where the amount of greyhounds entering racing is equal to those being rehomed once retiring from the sport. This Bill will undoubtedly disrupt this progress and unduly impact the welfare of greyhounds.

6. What are the potential barriers to the implementation of the Bill’s provisions and how does the Bill take account of them?

Sufficient care, resources and planning must be taken into account with regards to the welfare of the greyhounds if this bill is enacted.

7. How appropriate are the powers in the Bill for Welsh Ministers to make subordinate legislation, as set out in Chapter 5 of Part 1 of the Explanatory Memorandum)?

The BGC has no comments on Chapter 5 of Part 1 of the Explanatory Memorandum.

8. Are there any unintended consequences likely to arise from the Bill?

As previously set out, there is a material and significant risk towards the welfare of greyhounds. There is uncertainty of rehoming and sufficient care towards greyhounds who will no longer be under the protection of the GBGB. There is also a risk of unlicensed, illegal greyhound racing which will primarily negatively affect greyhounds, but will also undermine the regulated market, put consumers at risk, as well as incur financial and time resources to police and enforce against.

The Senedd must also take into account the impact on the local economy due to the closing of the track. We defer to submissions by the track, GBGB and others with regard the financial detail of this.

9. What are your views on the Welsh Government’s assessment of the financial implications of the Bill, as set out in Part 2 of the Explanatory Memorandum?

The financial impacts on the owners of the Valley Stadium is not fully detailed in the Explanatory Memorandum. The Memorandum states that employment would be adversely affected both on the track and through trainers. All negative employment impacts are stated to be small in the context of the general labour market churn in Wales.

It is the view of the BGC that more thorough and conclusive analysis should have been carried out to provide an accurate depiction of the true impact on employment losses to the track and local community. Furthermore, those who are trainers are highly skilled and have specialised knowledge, by removing this sector, these people cannot simply transfer jobs in the local community. This would force many to relocate or learn new skills, the cost of which is significant and not accounted for in the memorandum.

10. Are there any other issues you would like to raise about the Bill and the Explanatory Memorandum or any related matters?

The BGC would respectfully urge Welsh Government to reconsider this Bill. The improvement of Greyhound welfare can be achieved through sensible and robust regulation with no undue impact on the welfare of greyhounds, local employment, the economy and the sport itself (which is enjoyed responsibly by many). If the Government believes that the sport is currently contrary to the public interest or the welfare of greyhounds; the starting point should be to raise standards and not to put a blanket ban on the sports.