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UK Disposable Vapes Consultation: Health Department Flagged 90,835 Bot Responses, Tobacco Control Study Says

Bot Mutiny | October 28, 2026

The UK Department of Health and Social Care (DHSC) identified 90,835 of the 118,756 responses to its 2023 consultation on a "smokefree generation" and youth vaping as submitted by bots, according to a peer-reviewed study published in the journal Tobacco Control. The Guardian, which reported on the study, described the submissions as AI bots. Nearly all of the flagged responses opposed restrictions on disposable vapes, and the authors could not independently verify DHSC's classification. The department excluded the flagged responses from its decision-making, and the ban went ahead, the Guardian reports.

What the study found

The study, a short report by Dr Nason Maani of the University of Edinburgh and Prof Anna Gilmore of the University of Bath, examined the consultation that the government ran in October 2023. It drew on DHSC's published consultation reports and on a Freedom of Information Act request to the department.

Of the 118,756 total responses, 90,835, or 76%, were identified by DHSC as fraudulent using bot detection methods, the authors write. That left 27,921 responses from genuine respondents. According to the FOI response, every bot-flagged submission consisted only of multiple-choice selections, with no free-text answers. Of the 90,835, a total of 90,833 answered only three questions, and over 99.9% of those disagreed with restrictions on disposable vapes. The paper says the same number reported that they had learnt of the consultation through social media.

The bots would have changed the headline result. The authors calculate that if all responses had been counted as genuine, 81.3% of respondents would have appeared to disagree with restrictions on the sale and supply of disposable vapes. After the bot responses were excluded, 79.6% of valid respondents supported such restrictions.

How DHSC identified the responses

DHSC has not disclosed the specific detection methods it used, the study says. The department's public consultation report said it treated responses as fraudulent where "the data submitted was incompatible with the survey flow followed by genuine respondents who completed the consultation form manually." It added that such responses were "often duplicated many times and sent at high frequency from a small number of IP addresses."

The researchers could not check that classification. They write that their initial request for all responses was refused on cost grounds, and that a narrower request for responses clearly identified as bot-generated was refused because metadata and demographic data were considered exempt under sections 24 and 31 of the Act. After the authors clarified and narrowed the request to response content only, DHSC released a summary table and a CSV file. As a result, the authors say, independent verification of DHSC's classification was not possible.

Who was behind it is not known

The paper does not say who sent the responses. The authors write that "it is not possible on the basis of the information received to attribute source, intent or commercial sponsorship." They also say the scale and directional consistency of the bot responses "suggest a coordinated campaign, consistent with prior evidence of tobacco industry efforts to manipulate public consultations through mass coordinated submissions." As an earlier example, they cite the UK's plain packaging consultation, where 665,989 of 668,433 responses were campaign responses.

The paper describes the submissions as bots and automated responses. It does not state what technology generated them. The "AI" description comes from the Guardian, which called the episode "thought to be the first coordinated attempt to use AI to derail health policymaking in the UK." The study itself says it "appears to be the first documented instance of large-scale automated interference in a formal public health policy consultation."

Reactions

Maani told the Guardian that "the threat is that future campaigns become harder to catch, and what we can't catch, we don't know about." He added that such campaigns "raise the possibility of a handful of powerful interests looking like a mass movement."

Caroline Cerny, deputy chief executive of Action on Smoking and Health, said the evidence was "deeply concerning" and that "we need to be alert to the risk that technological advances can be used to further commercial interests around health policy."

Azzurra Moores, associate director for information ecosystems at the think tank Demos, called the findings "pretty alarming." She said there were no easy answers: "Every barrier that keeps bots out also makes it harder for real people to take part, and AI makes fake responses far harder to spot."

A DHSC spokesperson told the Guardian that its controls "worked effectively in this case." The spokesperson said "the fake responses were removed, and the consultation helped inform the landmark action we are taking to create a smoke-free generation," and that the department "will remain alert to interference of this kind in future consultation processes."

What happened to the ban

The Conservative government of Rishi Sunak ran the consultation. According to the Guardian, Keir Starmer's Labour government inherited the tobacco and vapes bill in 2024 and passed it into law, including the ban on businesses selling or supplying disposable vapes. The study says the Tobacco and Vapes Act received Royal Assent on 29 April 2026.

The authors recommend that future consultations strengthen bot screening and add explicit conflict-of-interest questions and barriers. They note that tools such as IP-based rate limiting or CAPTCHAs may raise the bar for automated campaigns, but that the underlying incentive to influence consultations remains. The study was funded by UK Research and Innovation, and the authors declare no competing interests.