2025: A year in review
Over the past year, the industry has experienced significant but steady change. As the year draws to a close, we look back at the key developments over the past 12 months and assess what may lie ahead for 2026.
What happened in 2025?
The year began much as anticipated, with the Department for Media, Culture and Sport (“DCMS”) and the Gambling Commission opening 2025 on a familiar footing of continued consultations and implementation of the Government’s 2023 White Paper proposals. Much of the early part of the year was characterised by regulatory development, rather than disruption, as long-anticipated reforms progressed through amendments to the Licence Conditions and Codes of Practice (“LCCP”) and various statutory instruments coming into force.
Whilst implementation of the White Paper proposals continued into the later stages of the year, the industry experienced a notable shift, as the Gambling Commission stepped up enforcement with a stronger focus on compliance, accountability and the licensing objectives. Seemingly at the beginning of the year, industry failings were less severe than that of previous years, which were reflected through the severity of sanctions imposed. Nevertheless, recent enforcement activity suggests that licensees are facing an increasing pressure to meet regulatory requirements. The Gambling Commission’s approach to enforcement was compounded by substantial tax increases announced in the Autumn 2025 Budget in November, sending shockwaves through the sector.
Throughout the year, the Gambling Commission maintained a steady focus on tackling the illegal gambling market, reinforcing its strategic priorities and sending a clear message to both licensed and unlicensed gambling businesses. Against this backdrop, the industry heads into 2026 contending with heightened scrutiny, financial pressures, and an expectation for licensees to demonstrate stronger culture and governance.
Key developments throughout the year include:
Remote sector
DCMS and the Gambling Commission continued to consult on and implement a series of White Paper proposals. Notable changes to the remote sector include the following:
- Amendments to the Remote gambling and software technical standards (“RTS”) came into effect in January following the Gambling Commission’s response to its Summer 2023 consultation. New remote game design requirements, that already applied to slots, were extended to other online products.
- The RTS was further updated in October 2025, revising financial limit requirements under RTS 12 as set out in the Gambling Commission’s response to its Autumn 2023 consultation. Responses to the Autumn 2023 consultation also revealed inconsistencies with the interpretation of ‘deposit limits’ across the sector prompting the Gambling Commission’s Supplementary consultation on further changes to RTS 12 aiming to bring greater clarity to the different types of financial limits. The Gambling Commission’s response noted that the relevant changes are due to come into effect on 30 June 2026.
- The introduction of social responsibility code provision (“SRCP”) 3.4.4(6), arguably one of the most debated White Paper proposals, now requires remote licensees (noting named exceptions within the relevant SRCP) to conduct financial vulnerability risk checks on customers reaching the relevant threshold of £150 in a rolling 30-day period.
- The Gambling Act 2005 (Operating Licence Conditions) (Amendment) Regulations 2025, signed into law in February 2025 and introduced via a licence condition, maximum stake limits for online slots games – £2 for under 25 years (effective from 21 May 2025) and £5 for those 25 years and older (effective from 9 April 2025).
Non-remote sector
Liberalisation for the land-based casino sector was achieved on 22 July 2025 when four statutory instruments came into effect following welcomed reforms proposed in the White Paper (“Non-remote Casino Regulations”). The Non-remote Casino Regulations expanded gaming machine entitlements for “converted casinos”, creating a new category of “extended converted casinos” that may host up to 80 machines subject to floor-space and table-to-machine ratios. The Non-remote Casino Regulations also set out detailed specifications for table gaming areas, gambling areas and non-gambling areas for extended converted casinos, larger converted casinos (with a gambling area of no less than 200m² and which are not extended converted casinos) and eased restrictions for 2005 Act Small Casinos. Additionally, the Non-remote Casino Regulations allow converted casino premises to offer sports betting provided that the licensee holds the relevant operating licence.
Enforcement
Throughout 2025, enforcement action continued against both operating and personal licensees; however, not at the same rate as previous years. In the FY 2024-25, 24 operating licensees faced enforcement action that led to a total of £4.2 million in fines or regulatory settlements, compared to 19 operating licensees and £13.4 million in FY 2023-2024.
We witnessed a marked change in approach in Q4 2025 with various licence suspensions. Andrew Rhodes, CEO of the Gambling Commission, reported in his speech at the BACTA Annual Convention on 27 November 2025 that the Gambling Commission has “undertaken some 13 suspensions across the whole industry in the last few months”. Rhodes also set the tone in respect of future enforcement action at the CEO briefing on 6 November 2025, in the context of conducting due diligence on business partners, stated “…there are no excuses. [The Gambling Commission] will not accept any excuses. And you should as a sector, expect to see more enforcement action in the coming weeks and months’’.
Statutory levy
This year, a new mandatory statutory levy was introduced to fund research, education and the treatment of gambling-related harms, replacing the previous voluntary contribution system. The Gambling Levy Regulations 2025 were signed into law in February 2025 and came into force on 6 April 2025. Under the Gambling Levy Regulations 2025, the levy is calculated at a fixed rate, ranging from 0.1% to 1.1% dependant on licensed product, based on the amounts reported in a licensee’s regulatory returns for the preceding 12 months (“Levy Period”). The first statutory levy invoices were issued on 1 September 2025, with payment due each year for that year’s Levy Period before 1 October. The main takeaway from this first year is the importance of submitting accurate regulatory returns to avoid facing inflated statutory levy invoices and regulatory action.
Tackling illegal online gambling
Tackling illegal gambling remains a central priority for the Gambling Commission, as reflected in its 2024–27 corporate strategy. This focus has intensified over the past year, with the publication of a four-part series analysing consumer engagement with illegal online gambling. Additionally, the Gambling Commission is seeking enhanced enforcement powers through the Crime and Policing Bill (the “Bill”), introduced into parliament on 25 February 2025, proposing to grant the Gambling Commission powers to remove IP addresses and domain names linked to unlawful gambling. As of December 2025, the Bill is in the Committee Stage in the House of Lords.
Whilst the Bill progresses through Parliament, the Gambling Commission has continued active enforcement, including reviewing suppliers’ operating licences for links to unlicensed operators and issued repeated warnings to licensees to conduct thorough due diligence on third-party partners, including the Industry Warning Notice issued in January 2025 and issuing a joint Institutional Statement together with other European regulators in November 2025.
The Chancellor also announced in the Autumn 2025 Budget that the Gambling Commission will receive an additional £26 million of funding in the next three years to tackle the illegal market. Given these developments, it is highly likely that the Gambling Commission will maintain and strengthen its focus on tackling illegal gambling throughout 2026.
Tax
The Autumn 2025 Budget was delivered by the Chancellor of the Exchequer on 26 November 2025. The industry had braced itself for some heavy hitting tax increases, the disappointing remote sector increases were higher than expected. The Chancellor announced that:
- from April 2026 Remote Gaming Duty will increase from 21% to 40%;
- a departure from a unified tax rate for non-remote and remote betting, introducing a remote General Betting Duty increasing tax on remote betting from the current 15% to 25% from April 2027;
- the abolition of Bingo Duty effective from April 2026.
There is no doubt that the significant increases in tax are going to have a direct impact on gambling businesses with profits shrinking. We expect to see increased M&A activity, as businesses struggle to compete, and a reduction in spend in areas such as marketing and promotions expected across the industry.
2025 industry timeline
- 17 January – Various updates to the RTS relating to game design requirements came into effect.
- 20 January –The Gambling Commission issued an industry warning notice on licensed software appearing on the illegal market.
- 29 January –The Gambling Commission opened its January 2025 consultation, consulting on proposed changes to the Gaming Machine Technical Standards, the Gaming Machine Testing Strategy and the LCCP.
- 30 January –Gambling Commission published its guidance on online stake limits.
- 4 February –The Gambling Commission published its response to its Autumn 2023 consultation confirming new requirements for customer led tools, improved transparency on customer funds and removing RET requirements.
- 10 February –The Gambling Commission confirmed that the first stage of its three-stage financial risk assessment pilot was complete.
- 25 February – The Gambling Act 2005 (Operating Licence Conditions) (Amendment) Regulations 2025, signed into law, requiring £2 stake limits for 18 to 25 year olds and £5 stake limits for over 25 year olds. The Gambling Levy Regulations 2025, were also signed into law, requiring all operating licence holders in Great Britain to pay a mandated levy to the Gambling Commission.
- 28 February –SRCP 3.4.4(7) requiring financial vulnerability checks at £500 a month were reduced to £150 a month, as set out in SRCP 3.4.4(6).
- 6 March – The Gambling Commission launched its Supplementary consultation setting out proposals relating to the RTS and definitions of ‘deposit limits’ and other types of financial limits.
- 26 March – The Gambling Commission published a further response to its Autumn 2023 consultation in relation to a ban on mixed product promotions, a cap on wagering requirements on bonus funds and rewording of SRCP 5.1.1 (Rewards and Bonuses).
- 31 March – SRCP 3.1.1(2) was removed from the LCCP as licensees are no longer required to make annual financial contributions to a list of research, prevention and treatment organisations.
- 6 April – The Gambling Levy Regulations 2025 came into force.
- 9 April – The Gambling Act 2005 (Operating Licence Conditions) (Amendment) Regulations 2025 came into effect, requiring licensees who hold a remote casino operating licence to introduce a maximum stake limit of £5.
- 17 April – The Gambling Commission issued an industry warning notice on the failure to complete and/or timely submission of regulatory returns.
- 1 May – SRCP 5.1.12 introduced new direct marketing requirements. Licensees must now provide customers with options to opt-in to direct marketing on a per product, per channel basis.
- 21 May – The £2 stake limit for 18 to 24 year olds came into effect and the Gambling Commission issued an update on its three-stage financial risk assessment pilot.
- 1 July – Statutory instruments affecting the Non-remote Casino Regulations were signed into law.
- 10 July – The Gambling Commission published its response to its December 2023 consultation confirming updates to the Statement of principles for determining financial penalties aiming to provide greater clarity and transparency.
- 22 July – The Non-remote Casino Regulations came into effect.
- 22 August – The Gambling Commission published guidance on the calculation and collection of the statutory gambling levy.
- 1 September – The first statutory levy invoices were issued. The Advertising Standards Authority (“ASA”) also broadened the scope of the Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code) to extend its application to capture non-paid-for online marketing communications (content marketing, such as social media posts), and capturing advertisements targeting UK customers, preventing licensees that are registered overseas from bypassing the ASA’s regulatory regime.
- 9 September – The Gambling Commission published guidance on the Non-remote Casino Regulations.
- 14 September – The ASA published updated guidance to add strength and clarity to the CAP Code requirements on “strong appeal” in relation to gambling advertising.
- 7 October – The Gambling Commission published its response to its Supplementary consultation confirming further changes to RTS 12 (Financial limits) in respect of deposit limits and other financial limits. The changes to RTS 12 shall come into effect on 30 June 2026.
- 10 October – Proposed changes to the Statement of principles for determining financial penalties came into effect.
- 15 October – DCMS launched a consultation on Category D gaming machines and licensing for bingo premises regarding categorisation and stake and prize limits to category D gaming machines and defining bingo areas.
- 31 October – Updates to RTS 12 in respect of customer led tools came into force and the implementation of licence condition 4.2.1 requiring licensees who have selected a ‘not protected’ rating in respect of customer funds, to remind the customers every six months that their funds are not protected in the event of insolvency.
- 6 November – The Gambling Commission announced it had concluded its four-part series on illegal online gambling and Andrew Rhodes delivered his speech at the CEO briefing.
- 25 November – European regulators issued a joint institutional statement calling for stronger measures against illegal gambling.
- 26 November – Autumn Budget 2025 announcing increases to Remote Gaming Duty (from April 2026) the abolition of Bingo Duty (from April 2026) and the introduction of remote General Betting Duty (from April 2027).
- 18 December – The Gambling Commission published a further response to its December 2023 consultation on financial key event reporting and response to its consultation on proposed amendments to LCCP as a result of the Digital Market and Competition Consumers Act 2024.
Looking ahead to 2026
Changes due to be implemented in 2026:
- 19 January 2026 – Updates to SRCP 5.1.1 will come into force introducing socially responsible incentives.
- 19 March 2026 – Changes to licence condition 15.2.1 impacting financial key event reporting come into force.
- 30 June 2026 – Further updates to RTS 12 (Financial limits) come into effect.
Expected updates in 2026:
- Outcome of the Gambling Commission’s financial risk assessment pilot.
- Establishment of the Gambling Ombudsman.
- Response to the Gambling Commission’s January 2025 consultation on Gaming Machine Technical Standards, Gaming Machine Testing Strategy and LCCP.
- Response to DCMS’s consultation on category D gaming machines and licensing for bingo premises.
- DCMS’s consultation on Gambling Commission fees as proposed in the White Paper.
- Progress with the Criminal Justice Bill and extension of the Gambling Commission’s powers to tackle illegal gambling.
- The Gambling Commission reviewing its position on crypto.
2025 has been a year of considerable change for the industry, the effect of which is expected to be felt in the coming year. We expect that enforcement action will increase in 2026, in a similar way to what we have seen in Q4 2025, and there will be an uptick in M&A activity as the remote sector braces itself for steep tax increases.
We look forward to seeing what 2026 has in store.
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