Harris Hagan

05Jan

ICE Barcelona 2026 – John Hagan to speak at Sport Leaders Conference

5th January 2026 Harris Hagan 27

Between 19-21 January 2026, ICE Barcelona will again be providing attendees with opportunities to drive revenue through innovative solutions, technology, valuable insights, and unrivalled networking opportunities.

Harris Hagan co-founder and Partner, John Hagan will speak at the Sport Leaders Conference on Protecting Growth, Safety and Integrity in Global Sports Markets. The session will not only look at the roles played by data, technology, regulators and international sports leagues in protecting sports players and bettors, but will also touch on the regional and national market specificities that international operators need to attune with when entering emerging markets.

John’s fellow panellists will include:

Gossy Ukanwoke, Managing Director – KingMakers (BetKing)
Graciela Garay, Director of Ethics, Compliance & Integrity – CONMEBOL
Tom Santos, Chief Commercial Officer – Bet da Sorte

Please see the below details for your calendar:

Date: Tuesday 20 January 2026

Time: 12:15pm – 13:00pm CET

Location: CC4.1, Fira Barcelona Gran Via

Partners, Bahar Alaeddini and David Whyte will also be attending ICE Barcelona 2026. Please do not hesitate to get in touch if you would like to arrange a meeting to discuss the UK market and how Harris Hagan may support you.

23Dec

Bahar Alaeddini to host IAGA webinar with Andrew Rhodes on 12 January 2026

23rd December 2025 Harris Hagan 40

Bahar Alaeddini will be hosting the International Association of Gaming Advisors‘ (“IAGA”) In Conversation Best Practices Webinar with Andrew Rhodes, the CEO of the British Gambling Commission on 12 January 2026.

The webinar will be a timely conversation with Andrew on the present — and future — of gambling regulation in the United Kingdom and globally.

In this session Andrew will share his perspective on:

The year ahead and the Gambling Commission’s priorities for 2026, including key areas of regulatory focus.
The evolving UK regulatory landscape – recent reforms, emerging policy trends, and their implications.
The impact, from a regulatory perspective, on the online gambling industry of very substantial tax increases.
The Gambling Commission’s ongoing efforts to combat illegal gambling.
Insights from recent enforcement actions and regulatory interventions, and how the Commission is working to drive earlier, more effective compliance across the industry.

This event is intended for advisors, operators, suppliers, regulators, and other industry stakeholders who want an up-to-date view of UK regulation. We hope you can join us for what promises to be an insightful conversation about the future of global gambling regulation in 2026.

Monday 12 January 2026

8am PST / 11am EST / 4pm GMT

The webinar is free to attend.

Share details about the webinar via:

11Dec

Chambers Gaming Law 2025 Global Practice Guide

11th December 2025 Harris Hagan 65

The Chambers Global Practice Guide for Gaming Law 2025 (“the Guide”) has been released and continues to provide guidance on the framework that applies to all types of regulated gambling, while setting out the current outlook and recent changes in around 30 key jurisdictions at the time of writing.

Bahar Alaeddini has reprised her role as Contributing Editor and in her introduction to the Guide, provides an overview of the gambling ecosystem, the global threat of illegal gambling, M&A activity, prediction markets and emerging markets. She is also joined by David Whyte and Jessica Wilson as co-authors of the chapters on UK Law and Practice, and UK Trends and Developments.

The Guide continues to be a helpful resource to lawyers, gambling businesses and others in the industry, providing the latest legal information on a range of topics, including: land-based and online gambling; B2C and B2B licences; application requirements; affiliates; white labels; responsible gambling; AML legislation; restrictions on advertising; acquisitions and changes of control; trends in social gaming, esports, fantasy sports and blockchain; and taxation.

Harris Hagan contributed to the following parts of the publication:

Key trends are covered by jurisdiction under the Trends and Developments section, and the Guide also provides users with the opportunity to perform jurisdiction comparisons using the Compare locations tool.

Please use the above links to review our contributions and use the Guide.

21Oct

2026 Chambers & Partners and The Legal 500: Harris Hagan ranked in top tier and awarded client satisfaction accolade

21st October 2025 Harris Hagan 85

We are delighted to announce Harris Hagan’s top tier ranking in both Chambers and Partners and The Legal 500 for 2026.

Chambers & Partners

For the 22^nd consecutive year, Harris Hagan retains its Band 1 ranking for Gaming.

“Harris Hagan’s vast experience within the gambling industry is first-class.”

Partners, John Hagan and Bahar Alaeddini, continue to be recognised in Band 1, and Partner David Whyte has been elevated to Band 2. Our congratulations also to Senior Associate, Jessica Wilson, who we are very proud to say has been recognised as an Associate to Watch, “an up-and-coming lawyer who has taken on the culture of Harris Hagan in providing excellent service”.

Positive testimonials include:

“Harris Hagan’s depth of expertise and breadth of experience means it is able to quickly digest and distil the complex and sophisticated questions faced by operators.”

“In the world of gambling law, John Hagan is a legend.”

“Bahar is an excellent partner; the advice she offers is always on point and she bridges the gap between regulation, business and culture effortlessly.”

“David Whyte’s advice is very clear, completely practical and hugely commercial. He totally understands the competing demands within an operator.”

“Jessica Wilson is really a dynamo and coming on fast.”

By invitation from Chambers, David Whyte and Jessica Wilson co-authored the UK-wide overview of the practice area for Chambers UK 2026.

The Legal 500

For the 22^nd consecutive year, Harris Hagan retains its Tier 1 Ranking for Gaming and Betting.

“They are the leading gambling-focused law firm in the UK, combining unmatched regulatory expertise with deep industry insight. We value the team’s clarity, responsiveness and ability to navigate complex, evolving frameworks. The firm stands apart for its close engagement with regulators, clear communication, and collaborative ethos—helping clients stay ahead of change, not just react to it.”

Harris Hagan also receives a Client Satisfaction accolade, which is measured by The Legal 500 based on their “assessment of the complexity and significance of the work completed, the strength of practice and key individual professionals on the team, and peer and client endorsement… the elite of the profession in each practice area”.

Managing Partner, John Hagan, continues to be listed in The Legal 500’s Hall of Fame. Partners, Bahar Alaeddini and David Whyte and Senior Associate, Jessica Wilson, also retain their rankings as Leading Partner, Next Generation Partner and Leading Associate respectively.

Amongst our many positive testimonials:

“They are experts in gambling law. What makes the practice different is their strong, in-depth knowledge of how the Gambling Commission operates, making them invaluable for operators navigating a changing regulatory environment. They provide a quick service to solve issues and are always available in a crisis with cool, considered advice, which has always been accurate and actionable.”

“Working closely with David Whyte and John Hagan, they have both proved very knowledgeable in their field and provided excellent training for our company, including for executive-level senior staff.”

We have received two sessions of PML training as a team and the information that has been communicated from Bahar and the Harris Hagan team has been invaluable.”

In an ever changing and developing industry, clients of all varieties require not just the expected factual and legal accuracy, but a keen sense of where the boundaries are potentially moving and the opportunities and threats that these bring. Harris Hagan have been at the forefront of this and are a “go-to” firm for advice and support across this complex, multi-jurisdictional environment.”

“They are the pre-eminent specialist firm active in the UK casino and gaming sector and have been a leading player since their foundation 20 years ago. All of the partners and staff are focused on this single sector, which gives a degree of commercial awareness and technical skill not matched by other firms.”

We would like to extend our heartfelt thanks to all our clients, colleagues and friends to whom we are incredibly grateful for their continuing instructions and for helping us achieve these impressive rankings.

06Aug

White Paper Series: Gambling Commission guidance on legislative changes to the non-remote casino sector

6th August 2025 Harris Hagan 128

On 29 July 2025, the Gambling Commission published its guidance on the legislative changes relevant to the non-remote casino sector (the “Guidance”). In this blog, we outline the changes, the Gambling Commission’s licensing guidance for operators and local licensing authorities, and how these changes will affect the content of the Gambling Commission’s Guidance to Lic ensing Authorities.

Background

In April 2023, the Department for Culture, Media and Sport (“DCMS”) published a white paper, High stakes: gambling reform for the digital age (the “White Paper”). A key part of the White Paper proposals was a series of measures relating to the land-based casino sector, which would allow casinos that were already operating when the Gambling Act 2005 (the “2005 Act”) came into force – known as “converted casinos” – to access new entitlements if certain conditions were met.

Statutory Instruments

The following statutory instruments (effective from 22 July 2025) have been introduced to deliver the proposed changes for casino licensed premises:

The Gambling Act 2005 (Commencement No. 6 and Transitional Provisions) (Amendment) Order 2025 (the “No. 6 Amendment Order”)

The No. 6 Amendment Order implements the following key changes:

Enables a converted casino premises licensee to make up to 80 gaming machines (including Category B machines) available for use by reference to a sliding scale where the gambling area in the casino is no less than 280m² and the number of gaming machines does not exceed 5 times the number of gaming tables used, or available to be used, in that casino. Any converted casinos which exercise their right to these entitlements will be known as “extended converted casinos”.
Restricts the number of gaming machines that can be made available when two or more casinos are “connected” (at the same location or immediately adjacent to each other). Where casinos are so connected, the maximum number of gaming machines that may be made available across all of those casinos, taken together, is 80. This restriction only applies to connected casinos that choose to exercise the extended entitlement.
Prevents a converted casino that takes up the new gaming machine allowances (i.e. an extended converted casino) from reverting to its previous entitlements.
Amends the definition of a gaming table for converted casinos, in line with the changes made by the Gambling Act 2005 (Gaming Tables in Casinos) (Definitions) (Amendment) Regulations 2025 (see 4 below).
Allows betting in converted casino premises.

The Casinos (Gaming Machines and Mandatory Conditions) Regulations 2025 (the “Casinos Regulations”)

The Casinos Regulations set out requirements relating to the size of gambling, non-gambling and table gaming areas, and the maximum number of separate betting positions in land-based casinos that provide facilities for betting.

Extended converted casinos:

The table gaming area and non-gambling area must be no less than half the size of the gambling area, or 250m², whichever is smaller.
The gambling area must be less than 1,500m², subject to an exemption for those casinos where the gambling area was 1,500m² or greater on 12 May 2025.
A sliding scale is provided setting out the maximum number of separate betting positions permitted based on the size of the floor area of the gambling area, starting at 16 if the gambling area is less than 280m², going up to a maximum of 40 if the gambling area is 500m² or more.

Larger converted casinos (with a gambling area of no less than 200m² and which are not extended converted casinos):

The gambling area must be less than 1,500m², subject to an exemption for those casinos where the gambling area was 1,500m² or greater on 12 May 2025.
A sliding scale is provided setting out the maximum number of separate betting positions permitted based on the size of the floor area of the gambling area, starting at 16 if the gambling area is less than 280m², going up to a maximum of 40 if the gambling area is 500m² or more.

Any other converted casinos which have a gambling area of less than 280m² will be limited to a maximum of 16 separate betting positions.

The Casinos Regulations also make two changes which will benefit 2005 Act Small casinos: (1) the minimum table gaming area is reduced from 500m² to 250m²; and (2) the gaming machine to gaming table ratio is amended from 2:1 to 5:1.

The Gambling Act 2005 (Premises Licences and Provisional Statements) (Amendment) (England and Wales) Regulations 2025 (the “Premises Licence Amendment Regulations”)

The Premises Licence Amendment Regulations enable converted casinos who wish to access the extended gaming machine entitlements to apply to the relevant licensing authority to vary their premises licence, and requires that they submit a scale plan showing the location and extent of a table gaming area (in addition to the existing requirements for converted casinos to show the non-gambling and gambling areas). No other forms of gambling are permitted to take place in a table gaming area.

The Gambling Act 2005 (Gaming Tables in Casinos) (Definitions) (Amendment) Regulations 2025 (the “Gaming Tables Regulations”)

The Gaming Tables Regulations amend the definition of a “gaming table” in a casino for the purposes of subsections (3) to (5) of section 172 of the 2005 Act. These subsections set out gaming machine entitlements in 2005 Act casinos with reference to a fixed numerical maximum, which is subject to a ratio of gaming machines to gaming tables. Under the new definition, only gaming tables controlled or operated by casino staff can qualify as a gaming table for the purposes of calculating gaming machine allowances.

As these four statutory instruments came into effect on 22 July 2025, any converted casino licensees that wish to exercise the new gaming machine entitlements are now able to apply to their local authority to vary their premises licences.

Licensing guidance for licensees and local authorities

Operating licences and betting

In its Guidance, the Gambling Commission has reminded converted casino licensees who wish to utilise the extended machine entitlements, or to offer betting, to consider whether they need to apply to the Gambling Commission to vary their operating licence to:

amend the fee category; and/or
amend the licensed activities being offered.

If the casino wishes to provide non-remote facilities for betting, they will need to hold a non-remote general betting (standard) operating licence. To offer self-service betting terminals (“SSBTs”), casinos will be required to apply for a remote general betting (standard) (real events) licence. It will not be possible for a casino licensee to rely on an ancillary remote betting licence, even where SSBTs are available alongside a non-remote offering, as the ancillary remote betting licence attaches to a betting premises licence, not a casino premises licence.

In addition, Small 2005 Act casinos which take advantage of the new machine to table ratio, and/or the reduced minimum table gaming area, are reminded that they will need to apply to their local licensing authority to vary their premises licence to reflect the changes to their non-gambling and gambling areas.

To assist casino licensees, the Guidance provides example scenarios outlining related licensing requirements that are triggered, and reminds any licensees wishing to utilise the extended entitlements that they should inform the Gambling Commission by submitting an LCCP notification.

Premises Licences

Converted casino licensees wishing to utilise the extended gaming machine entitlements must apply to the relevant licensing authority to vary their premises licence so the casino plan shows the location and extent of any part of the premises which will be a table gaming area.

Accordingly, the Gambling Commission will need to update its Guidance to Licensing Authorities (“GLA”), and the Guidance outlines which paragraphs of the GLA have been affected by the legislative changes. The affected sections of the GLA are to be reviewed and amended in due course.

Next steps

The full detail of the entitlements delivered by each of the instruments and any requirements and conditions attached to them are set out in the instruments and further detail can be found in the respective statutory instrument’s Explanatory Memorandum.

If you have any questions regarding these legislative changes that are now in effect, or would like assistance with varying your premises licence or operating licence, please do not hesitate to get in touch.

20Jun

21 years of Harris Hagan

20th June 2025 Harris Hagan 132

Last week in Berlin, during the International Association of Gaming Advisors (IAGA) International Gaming Summit, we were proud to celebrate a major milestone – 21 years of Harris Hagan.

To our clients, family, friends, colleagues, and regulators who joined us and who have supported us over the years – thank you. Your trust, collaboration and friendship have made this incredible journey possible.

Since 2004, we have been privileged to help clients navigate the complexities of gambling law – securing and protecting licences, guiding them through regulatory enforcement, and advising on major transactions. We are honoured to work with the world’s best gambling businesses and executives, and to occupy a special place in an industry we truly cherish.

Reflecting on the occasion at the celebration, our Managing Partner John Hagan shared:

“Julian Harris and I had some high hopes and aspirations in 2004 but we did not know what the future held, and I do not know what the future holds today. But I do know that it involves striving every day to uphold our high standards, it does involve the UAE and the fantastic opportunity to support our clients in this exciting jurisdiction, which we are uniquely placed to do, and it absolutely involves my brilliant partners Bahar Alaeddini and David Whyte in whose hands the future of the firm is bright, and who are a joy to work with, each and every day in their own inimitable way.”

Here’s to the next chapter!

Details about our UAE services will be published soon.

19May

White Paper Series: Draft Casino Regulations and statutory instruments for non-remote casinos laid before Parliament

19th May 2025 Harris Hagan 166

On 12 May 2025, the Department for Culture, Media and Sport published its draft proposals to modernise the rules relating to machine allowances and gaming floor dimensions in land-based casinos. The Casinos (Gaming Machines and Mandatory Conditions) Regulations (“the Casinos Regulations”) have been laid in draft before Parliament and form part of a package of interlinked statutory instruments (“SI”) which were published alongside the Casinos Regulations to enable proper scrutiny of the changes to the regulatory framework.

The Statutory Instruments

Two SIs have been published, namely:

the Gambling Act 2005 (Commencement No. 6 and Transitional Provisions) (Amendment) Order (the “No. 6 Amendment Order”); and
the Gambling Act 2005 (Premises Licences and Provisional Statements) (Amendment) (England and Wales) Regulations (the “Premises Licences Amendment Order”).

The No. 6 Amendment Order will amend The Gambling Act 2005 (Commencement No.6 and Transitional Provisions) Order 2006 by extending the machine entitlements for converted casinos located in England and Wales so that they may make up to 80 Category B, C, or D machines available to use, as long as they meet certain criteria, including:

maintaining a gambling floor area of no less than 280m²; and
ensuring that the number of gaming machines is not more than five times the number of gaming tables which are being ‘used’. A gaming table is ‘being used’ at a particular time if it is actually being used to play a casino game, or is available to be used to play a casino game.

Only converted casinos with a gambling area of at least 500m² will be permitted the full entitlement of 80 gaming machines. For any converted casinos with a smaller gambling area, the No. 6 Amendment Order sets out a tiered scale linking the maximum number of gaming machines to the minimum gambling area. The maximum permitted number of gaming machines is reduced by 5 for every 20m² decline in minimum gambling area, from 80 gaming machines for 500m² down to a maximum of 25 gaming machines for a minimum gambling area of 280m².

Whilst the No.6 Amendment Order significantly increases machine entitlements for converted casinos, it also intends to close a loophole in the existing framework. Currently, where two (or more) converted casino premises are connected, they can effectively double (or triple etc.) their gaming machine entitlement. The No. 6 Amendment Order makes clear that for such connected converted casino premises, no more than 80 gaming machines are permitted across both premises – taken together – unless customers moving from one premises to the other have to travel through an area which is not subject to certain specified licences or permits issued under the Gambling Act 2005.

In addition, the No. 6 Amendment Order will allow betting to take place in casinos covered by a converted casino premises licence, which is currently only permitted in Gambling Act 2005 small and large casinos.

The Premises Licences Amendment Order updates the current Gambling Act 2005 (Premises Licences and Provisional Statements) Regulations 2007 so that any converted casino applying to utilise the new entitlements under the No.6 Amendment Order must submit a scale plan indicating an area for ‘table gaming’. This must identify the “location and extent of any part of the premises which will be the table gaming area” and “any other part of the premises which will be used for providing facilities for gambling in reliance on the licence.” Currently, only Gambling Act 2005 small and large casinos are required to identify a table gaming area on their plans.

The Casinos Regulations

In addition to effecting the SIs, the draft Casinos Regulations propose:

Increasing the ratio of gaming machines permitted per gaming table in Gambling Act 2005 small casinos from two per table to five per table, whilst maintaining an overall cap of 80 machines per premises.
Reducing the minimum size of the table gaming area in small casinos from 500m² to 250m².

Timing

Whilst they are currently in draft form, the SIs state that they will come into force on 22 July 2025.

If the draft Casinos Regulations are approved by both Houses, Ministers intend to make the No.6 Amendment Order prior to signing the draft Casinos Regulations.

Please let us know if you have any questions on the above and sign up to our blog to receive insight and commentary on the continued journey of the White Paper.

15May

IAGA Gaming Summit: A Fireside Chat with Andrew Rhodes moderated by John Hagan – “a discussion you won’t want to miss”

15th May 2025 Harris Hagan 131

The firm is proud to be a Silver sponsor of the 42^nd annual International Association of Gaming Advisors (IAGA) summit which takes place this year from 9 – 12 June 2025 at the Ritz-Carlton, Berlin.

As part of the 2025 Gaming Summit Agenda, our Managing Partner, John Hagan, will moderate a Fireside Chat with Gambling Commission CEO, Andrew Rhodes on Wednesday 11 June 2025.

The session will consist of an open discussion and Q&A on the trials and tribulations of Andrew Rhodes’ tenure during an eventful period for gambling, the many learnings and successes along the way and the future direction of gambling regulatory reform in Great Britain.

Date: Wednesday 11 June 2025

Time: 9am CEST / 8am BST

Location: Ritz-Carlton, Berlin

02May

HM Treasury Consultation: Tax Treatment of Remote Gambling

2nd May 2025 Harris Hagan 149

On 28 April 2025, HM Treasury launched a consultation on Tax Treatment of Remote Gambling (the “Tax Consultation”). The Tax Consultation aims to create a simpler, streamlined system by proposing a new, single Remote Betting & Gaming Duty which would replace the current tax regime for online operators.

Background and purpose of the Tax Consultation

Since 2014, remote gambling operators in the UK are subject to the following taxes:

General Betting Duty (“GBD”) – Due at 15% of gross profit for fixed-odds bets, totaliser bets on horse or dog races, and bets taken on betting exchanges, 10% for sports spread bets and 3% for financial spread bets.
Pool Betting Duty (“PBD”) – Due at 15% of gross profit on bets not at fixed-odds apart from those on horse and dog racing.
Remote Gaming Duty (“RGD”) – Due at 21% of gross profit and is payable on the provision of online gaming to a UK customer.

In the Tax Consultation, HM Treasury proposes to move to a single tax called Remote Betting & Gaming Duty (“RBGD”) for UK-facing remote gambling in order to harmonise the existing duties into a single rate. This tax would have in its scope betting and gaming activities offered remotely, such as online casino, bingo, and remote betting, including general and pool betting.

HM Treasury notes that “as remote gambling has matured, the distinctions in tax treatment between general betting, pool betting and remote gaming are less reflective of real-life distinctions in customer experience of the products”. Given the common features across the different forms of remote gambling, HM Treasury’s view is that “there is no longer a strong rationale to maintain this historical distinction” in the duty rates.

The Tax Consultation seeks views from stakeholders on the shape, scope, coverage, administration, and enforcement of the new proposed RBGD.

Consultation themes

The proposal of a single remote gambling tax

This chapter explains why the government is considering introducing a single RBGD and a high-level view of how the tax would operate. For instance, the government acknowledges that operators providing gambling to UK customers have limited familiarity with the UK tax system and its administration, therefore simplification is at the heart of this proposal.

As explained above, the proposal is to harmonise the current duty rates for RGD, GBD and PBD in a single rate. Should the government proceed with the RBGD, the rate will be set as part of the Budget process.

Basic framework and scope of the tax

This chapter details the proposed approach to use the existing ‘place of consumption’ (“POC”) framework. POC in this context means that a gamble or bet is subject to UK gambling duties if:

the person making the bet is a ‘UK person’;
it is made on UK premises where betting facilities are available.

This chapter also sets out the basis for calculation of taxable profits. Under the existing RGD, GBD and PBD regimes, gambling tax liability is calculated by applying the appropriate tax rate to taxable profits. Taxable profits are calculated based on stakes paid in, less prizes paid out. The government does not see the need to add unnecessary complexity by changing this and will mostly retain the current approach to establishing taxable profits (beyond the issues around freeplays, free bets and prizes discussed below).

Regarding the scope of RBGD, it is proposed that the government will be led by existing legal definitions of ‘remote’ gambling, as contained in section 154 of the Finance Act 2014, which reflect the definition of ‘remote gambling’ in section 4 of the Gambling Act 2005 and its regulatory licence structure.

Given the definition of ‘remote gambling’, all ancillary activities other than those covered by Bingo Duty, Gaming Duty or Machine Games Duty (and therefore already subject to other duties) would be in scope of RBGD. The remote betting activities of an on-course bookmaker and remote spread betting would also be activities included in RBGD. However, HM Treasury is seeking views on whether the inclusion of spread betting is appropriate, or whether alternative treatment is required.

Consistency of treatment of free bets, freeplays, and prizes

As freeplays and free bets are subject to tax-specific treatments, HM Treasury wants to test whether RBGD should adopt a common treatment for freeplays and free bets offered for all remote gambling.

Free bets

The government proposes to align the tax treatment of remote free pool bets with the treatment of free bets as stakes for GBD purposes. This means that when a customer places a free pool bet, the value of that bet would be included in the licensee’s taxable amount. Any winnings paid to UK customers from these taxable free pool bets would count as deductible expenditure in their duty calculation.

Freeplays

Currently, there is an exception for re-wagering under RGD, where only the first use of a freeplay has a notional value for the purposes of tax calculation. The introduction of RBGD provides an opportunity to consider the application of the re-wagering exception, alongside the introduction of a re-wagering cap taking effect on 19 December 2025, following the Gambling Commission’s Autumn 2023 consultation response.

The Tax Consultation welcomes suggestions for options to reform the treatment of freeplays and remove opportunities for avoidance.

Prizes

The government proposes to align the tax treatment of prizes by extending the current RGD provisions, including rules about valuation of prizes to all activities under RBGD. This would give betting providers scope for the deduction of non-money prizes and provide opportunities for innovation regarding prize offerings made to customers.

Under RBGD, it’s proposed to align the tax treatment of prizes with the approach under GBD and PBD, so that only winning prizes can be deducted.

Registration, returns and sanctions

This chapter sets out the government’s proposals for the RBGD administrative framework, including registration, remote filing, sanctions and enforcement.

To keep administrative changes for businesses to a minimum, the government intends to adopt the existing administrative framework for RBGD.

The government considers that the current sanctions available for enforcement of the tax regimes and unlicensed gambling are sufficient.

Next steps

The Tax Consultation will be open for 12 weeks, closing at 11:59pm on 21 July 2025. Responses can be submitted online, or by email to [email protected].

Please get in touch with us if you would like to discuss this matter further or require our assistance preparing responses.

11Apr

White Paper Series: Gambling Commission publishes statutory levy guidance

11th April 2025 Harris Hagan 170

On 7 April 2025, the Gambling Commission published its guidance on the statutory levy and how licensees can prepare for it. The Gambling Levy Regulations 2025 (the “Levy Regulations”) took effect on 6 April 2025 and introduced a mandated levy on all operating licence holders in Great Britain to fund research, prevention and treatment of gambling harms. Please refer to our previous blog, White Paper Series: Statutory Instrument published for statutory levy, for further details of the Levy Regulations.

The Gambling Commission’s guidance sets out snapshot information on the statutory levy, including:

Who will collect the statutory levy

The Gambling Commission collects the levy on behalf of the Department for Culture, Media and Sport.

Who must pay the statutory levy

The levy will be charged to all gambling licensees. However, licensees are not required to pay the levy where the amount of that levy is £10 or less (for a given period).

How the statutory levy is calculated

The levy will be charged at a set rate for all Gambling Commission licence holders, ranging from 0.1% – 1.1%.

The basis and rate to be paid will vary depending on the licensed product (see the statutory levy rates by licence product table). The basis will be from the following list, as appropriate:

Gross Gambling Yield
proceeds retained after good causes and prizes paid out
gross value of sales or any amounts that will otherwise accrue to the licensee in connection with activities authorised by the licence.

The calculation for the amount owed under the statutory levy is based on the data that licensees provide via Regulatory Returns. The guidance reminds licensees of their obligation to provide ‘true and correct’ data, and any incorrect data submitted would impact the calculation of the amount owed by levy.

When licensees need to pay

Licensees must not pay the statutory levy until they receive their invoice.

The first invoices will be issued on 1 September 2025, with payment required on or before 1 October 2025.

The levy will then be invoiced annually on 1 September and will cover the period of 12 months beginning with 1 April.  

How to pay the statutory levy

Invoices will be issued to licensees by email (not via eServices) and payment can be made using GovPay or Bank Transfer.

Statutory levy payments must be paid in full by 1 October, and in line with the details on the invoice. Full details of how to make the payments will be provided by the Gambling Commission before September 2025.

Consequences of not paying the statutory levy

Payment of the statutory levy is a licence requirement, and therefore non-payment, or late payment, of the levy by the licensee will result in revocation of the operating licence. 

Removal of voluntary RET Contributions

Following the announcement of the introduction of the statutory levy, the Gambling Commission responded to the consultation proposing to amend the Licence Conditions and Codes of Practice to remove the requirement for licensees to make a voluntary annual financial contribution to one or more organisation.

Accordingly, as of 31 March 2025, licensees are no longer required to make annual financial contributions to research, prevention and treatment due to the levy’s introduction.

Next steps

Licensees can prepare for the statutory levy payment by ensuring:

regulatory returns data is submitted correctly and on time,
the Gambling Commission holds the correct contact details (i.e. email address) for your organisation, and
payment is only made once an invoice has been received.

Please get in touch with us if you have any questions about the Levy Regulations or the Gambling Commission’s guidance on the statutory levy.

Harris Hagan

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