23Dec

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

23rd December 2025 Harris Hagan 14

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:

22Dec

Department for Culture, Media and Sport publish voluntary Code of Good Practice for prize draw operators

22nd December 2025 Ruby Duncalf 19

On 21 November 2025, the Department of Media, Culture and Sport (“DCMS”) published the Voluntary Code of Good Practice for Prize Draw Operators (the “Code”) in Great Britain. DCMS estimates the annual market value of the prize draw sector to be £1.3 billion with 7.4 million adult participants annually across approximately 400 operators. DCMS recognises that whilst the operation of prize draws does not require a licence under the Gambling Act 2005, research has shown how prize draws sit adjacent to the gambling industry, presenting concerns in light of gambling-related harms. The Code, agreed by the Government and a significant number of prize draw operators, aims to strengthen player protections and ensure that individuals who participate in prize draws do so more safely.

Purpose and scope of the Code

The Code applies to prize draws in Great Britain where:

a) the outcome (and therefore allocation of prizes) is determined by chance; and

b) there is both a paid entry route and a free entry route.

The Code outlines key measures that prize draw operators are expected to implement to strengthen player protections and ensure that those who participate in these draws do so more safely. The Code is voluntary, applies only to free-entry draw elements of a business, and does not replace existing regulation and requirements for prize draw operators. Any failure to abide by the Code will not itself constitute a breach of an operator’s legal responsibilities.

Implementation timeline

At the time of writing, the Code has been signed by 141 signatories who have committed to implement the Code in full within 6 months of its publication and not later than 20 May 2026 (“Implementation Date”). Operators becoming a signatory of the Code after the Implementation Date must ensure their full compliance immediately. In the absence of an established industry trade body, signatories are expected to share practices on how to implement measures and work with operators who are not yet signatories to the Code to adopt these measures and subsequently join the Code.

Oversight and compliance

DCMS will have oversight of the Code, reserving the right to delegate oversight to an industry trade body as necessary. DCMS will periodically review the Code’s effectiveness, noting that should the Code not be suitably implemented or complied with, DCMS reserve the right, following consultation, to introduce changes where necessary.

All signatories of the Code have agreed to act in good faith. If concerns arise about non-compliance, these should first be raised with the relevant operator or by contacting DCMS at [email protected].

The Code

The Code is divided into three core areas: Player Protections, Transparency, and Accountability, each summarised in turn below.

Player protections

a) Prize draws should only be made available for players aged 18 or over with a reasonable age verification process in place. Advertising should not be targeted at under 18s.
b) Credit card payments in excess of £250 per month per player should not be accepted.
c) Suitable proportionate maximum monthly total spends should be set for players or players should be permitted to set their own, including the option to set a limit at £0.
d) The option to suspend or permanently close an account should be provided to players.
e) Reasonable efforts should be made to have effective systems and processes in place to monitor player activity to identify harm or potential harm.
f) Where operators are able to identify any indicators of harm, they should take a tailored and proportionate approach to intervention that mitigates harm and encourages responsible play.
g) Operators should signpost players to available support for those experiencing harm.
h) An appropriate time period should lapse between a prize draw opening and concluding.
i) Operators should ensure that all marketing and advertising of their prize draws is in line with the CAP and BCAP code, and should be undertaken in a socially responsible manner.

This section of the Code also covers complaints processes, operators’ conduct during a player’s suspension, measures in relation to instant win games, and further requirements regarding marketing and advertising.

Transparency

a) Operators should provide a clear summary of how each prize draw works, including the statement that prizes are to be awarded by chance.
b) Promoters of prize draws should ensure that prizes are awarded fairly in accordance with the rules and terms displayed to players, and this should be by (or under the supervision of) an independent person, unless the winners are selected by a computer process that produces verifiably random and auditable results, or by a certified physical drawing machine.
c) Where possible, prior to entering a draw, operators should provide players with clear and easily accessible information regarding the likelihood of winning a prize and how prizes will be allocated.
d) Operators should clearly and prominently provide players with details of any “free entry” options for the prize draw before the point of purchase, and in line with the requirements of the Gambling Act 2005.
e) Operators should promptly provide the winning player with the advertised prize for a draw or a reasonable cash alternative.

This section of the Code also covers charitable contributions and further details regarding free entry options.

Accountability

a) Operators should have processes in place to monitor and regularly review their own compliance with the Code and, where inadequacies are identified, take swift actions to ensure compliance with the Code.
b) Operators should take reasonable steps to ensure that all relevant Code requirements are also followed by any third parties that support their prize draw operations, such as affiliate marketers or draw management partners. Where third parties are not compliant with the Code, terminating relationships should be considered.
c) Operators should engage with other operators to share best practice in relation to player protections, transparency and accountability.
d) Operators should publish all of the measures they have in place relating to player protections, transparency and accountability, and ensure their adherence with the Code is transparently displayed on their websites.
e) Operators are encouraged to work with DCMS to ensure the Code remains fit for purpose and share any learnings or challenges.

The full Code and requirements can be found here.

Next steps

Please get in touch with us if you have any questions about the implementation or compliance with the Code.

17Dec

Regulators issue joint institutional statement on illegal online gambling

17th December 2025 Ruby Duncalf 30

On 25 November 2025, the gambling regulators of Austria, France, Germany, Great Britain, Italy, Portugal and Spain (the “Regulators”) issued a joint institutional statement, calling for stronger measures against illegal online gambling (the “Statement”).

The Statement acknowledges that “illegal online gambling continues to undermine the integrity of regulated markets”, and that “its borderless nature and the speed of technological innovation make it easier for illegal operators to evade regulatory oversight”.

The Regulators expressed their concern at the increasing level of advertising by illegal operators aimed at their jurisdictions. The Statement stressed that advertising disseminated through digital channels, including social media, video platforms and affiliate networks, not only contravenes national legislation but also places citizens, including minors and vulnerable individuals, at heightened risk from illegal gambling activities.

The Statement follows the Gambling Commission’s heightened effort to understand the illegal gambling market, signified by the publication of its four-part series between September 2025 and November 2025, launched to better understand consumer engagement with illegal online gambling, the associated risks and the actions being taken to disrupt it.

In June 2025, experts at the International Association of Gaming Advisors (IAGA) conference, estimated that in 2024 alone, illegal online gambling represented 71% of total iGaming revenue in all 27 EU states or €80.6bn.

By issuing the Statement, the Regulators wished to highlight their strong commitment to consumer protection, market integrity and compliance with national and international regulations within the respective legal frameworks by:

Sharing information on illegal operators between them;
Calling on digital platforms and social media networks to strengthen their control mechanisms to prevent the dissemination of advertising content from unauthorised operators; and
Reaffirming their commitment to share knowledge and better practices in identifying, investigating, and sanctioning operators acting outside the law.

The Statement ultimately signals a clear message: regulators across Europe are united in their determination to combat illegal online gambling, strengthen the integrity of the regulated gambling sector and to protect citizens from the risks posed by illegal gambling activities.

Next steps

Please get in touch if you have any questions regarding unlicensed gambling in Great Britain, your due diligence obligations, and how to actively monitor your business relationships.

11Dec

Chambers Gaming Law 2025 Global Practice Guide

11th December 2025 Harris Hagan 39

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.

20Nov

The Legal 500 Country Comparative Guide – Gambling Law

20th November 2025 Ruby Duncalf 58

In its fourth year of publication, Partners Bahar Alaeddini and David Whyte have jointly contributed to the UK chapter of The Legal 500: Gambling Law Comparative Guides 2025 4^th Edition (the “Guide”), with Bahar once again acting as contributing editor.

Legal 500 – Country Comparative Guides 2025 Download

The publication – which this year spans 22 jurisdictions – gives the readers an overview of gambling law, regulatory and licensing requirements in various jurisdictions and the UK, on matters including:

key gambling legislation and the legal definition of gambling;
types of gambling licences available, with a headline of the application procedures;
prohibited gambling products;
information on gambling advertising and marketing affiliates;
penalties for unlawful gambling;
anti-money laundering and safer gambling requirements;
shareholder reporting and approval thresholds;
the regulator’s enforcement and sanction powers; and
horizon scanning across the next 12-24 months and risks to the sector.

Of particular interest, in this year’s edition of the Guide are the key proposals for regulatory development expected over the next 12-24 months, including outstanding White Paper reforms, which we outline in the UK chapter.

This year’s edition of the Guide is accompanied by The Legal 500: Hot Topics with Bahar Alaeddini, David Whyte and Associate Ruby Duncalf jointly contributing to the UK chapter, providing a history of and status update on the 2023 White Paper proposals.

You can read the Guide and compare jurisdictions here.

17Nov

White Paper Series: Gambling Commission update on deposit limits

17th November 2025 Ruby Duncalf 63

The Gambling Commission has announced further changes to the remote gambling and software technical standards (“RTS”) aiming to improve the gambling management tools available to consumers. From 30 June 2026, all online operators must provide customers with the opportunity to set a ‘deposit limit’ which is based solely on the amount a customer pays into their account over a set duration.

Background

Following the Autumn 2023 consultation, the Gambling Commission announced changes to take effect on 31 October 2025 to strengthen consumer protection in online gambling (“Initial Consultation”). Responses to the Initial Consultation identified inconsistencies with the way operators interpret ‘deposit limits’. The Gambling Commission launched a supplementary consultation in March 2025, setting out proposals for clarifying ‘deposit limits’, and other financial limits in the RTS.

Helen Rhodes, the Gambling Commission’s Director of Major Policy Projects, said in relation to the proposed changes to the RTS:

“Our work will help empower consumers to have greater awareness and control over their gambling. These further changes will also bring consistency and clarity for those consumers choosing to set deposit limits, while still supporting gambling businesses to offer customer choice for different forms of limits.”

Summary of the proposals and new requirements

Proposal 1: Default ‘gross’ deposit limits must be offered to the customer

The proposal was to include a requirement that, as a minimum, ‘gross’ deposit limits must be offered to customers. The intention was to improve consistency across the industry and to simplify the landscape for consumers.

RTS requirement 12B:

As a minimum, the gambling system must offer gross deposit limits – where the amount a customer deposits into their account is limited over a particular duration.
Where more than one type of limit is made available in the gambling system, operators must ensure that ‘gross’ deposit limits are offered to customers with at least equal prominence to other limits.

The following requirements will also be added to RTS 12B, which provide further clarity:

Where a customer sets simultaneous time frames, for example a daily deposit limit and a weekly limit, the most restrictive must always apply. Therefore, if a daily deposit limit of £10 and a weekly limit of £100 are both set then the maximum the system must allow to be deposited is £10 per day and £70 per week.

The gambling system must prevent a customer from further depositing funds once a deposit limit is reached, until the defined period of the limit restarts or the customer takes action to increase the limit (subject to a standard 24 hour cooling off period).

Applies to: all gambling – except subscription lottery.

Proposal 2: The application of the term and definition of deposit limit

The intention of this proposal was to improve clarity for the consumer and consistency across the industry.

RTS requirement 12B: Only limits that meet this definition can be referred to as a deposit limit, and limits meeting this definition must be described to a customer as a deposit limit.

Applies to: all gambling – except subscription lottery.

Proposal 3: Wording of financial limits in the implementation guidance including the introduction of ‘net’ deposit limits

The intention of this proposal was to provide increased consumer choice by amending the implementation guidance to allow for other types of limits should operators choose to make them available.

RTS implementation guidance 12B: In order to maximise consumer choice, operators could also offer:

stake limits: where the amount a customer stakes on gambling (or specific gambling products) is restricted for the period or duration of the limit applied; and/or
loss limits: the total value of stakes placed on gambling products minus the total value of any winnings or returns from those stakes is limited for the period or duration of the limit applied; and/or
net deposit limits: the amount deposited into the account minus any withdrawals made for the period/duration of the limit applied.

Applies to: all gambling – except subscription lottery.

The Gambling Commission has published the amended RTS 12 wording in full including both the changes coming into effect from 30 June 2026 and the changes to RTS that are in effect from 31 October 2025.

Next steps

The new RTS requirements come into force on 30 June 2026. Licensees must adhere to these requirements before this date.

Please get in touch with us if you have any questions about the new deposit limit rules.

10Nov

Gambling Commission concludes its series on illegal online gambling

10th November 2025 Ting Fung 57

On 6 November 2025, the Gambling Commission published the final report in its four-part series on illegal gambling. The series, which launched in September 2025, aims to understand consumer engagement with illegal online gambling, the associated risks posed and the actions being taken to disrupt it, and has thus far addressed:

Part 1: Consumer awareness, drivers and motivations
Part 2: Consumer engagement and trends
Part 3: Disruption of illegal online gambling

The final report, titled ‘Challenges of estimating the size of the illegal online gambling market’, explores the challenges of quantifying an activity that is, by its nature, hidden. Chief Executive, Andrew Rhodes states that:

“Illegal online gambling remains a serious threat to consumers and to the integrity of the regulated market. While measuring the full scale of the problem is complex, our understanding is growing — and so too is our ability to disrupt illegal operators.”

Challenges to understanding, progress building and shared responsibility

The final report notes the continuing significant methodological challenges of measuring the scale of the illegal online gambling market but also, that although no single estimate of market size has been published, the Gambling Commission has nevertheless, developed a stronger evidence base and clearer understanding of both consumer behaviour and illegal operator tactics. The Gambling Commission emphasises that tackling illegal gambling requires a coordinated response and continued collaboration across government, industry and digital platforms.

Next steps

The Gambling Commission will continue its programme of research, data collection and enforcement activity on illegal gambling, which it identifies as a ‘key strategic priority’ and will provide updates accordingly as it progresses. Annex A of the final report outlines a summary of next steps to improve the reliability of estimates, including options for new sources of data and evidence, alongside an assessment of whether these options will satisfactorily fill key information gaps.

28Oct

DCMS Consultation on Category D gaming machines and licensing for bingo premises

28th October 2025 Ting Fung 70

The Department for Culture, Media and Sport opened its consultation on Category D gaming machines and licensing for bingo premises on 15 October 2025.

Consultation proposals

The aim of the consultation is to ensure that the regulatory framework is fit for purpose, with the proposals addressing:

Stakes and prizes for Category D machines

For non-money prize machines, Government is proposing to split the “non-money prize machine” category into two; one for “non-money prize, slot style” machines, which maintain the current 30p stake limit and a £8 non-money prize limit, and one for “non-money prize, non-slot style” machines with a stake limit of up to 50p and non-money prize limits of up to £20. Other proposed changes include creation of a new pusher subcategory of machines, an increased non-money prize limit from £50 to £75 for crane-grabs and an increased stake limit from 20p to 30p for coin pushers.

Age limit for ‘cash out’ slot style machines

The consultation includes the proposal to make it an offence to invite, cause or permit anyone under 18 to use ‘cash out’ slot-style Category D machines, as set out in the previous government’s response to its consultation on measures relating to the land-based sector.

In respect of the voluntary agreement implemented by Bacta members in 2021 to ban under 18s using adult-only gaming machines, Government proposes to move this agreement into legislation to cover the minority of family entertainment centres not already complying with Bacta’s age restriction agreement.

Bingo licensing

The key proposal relates to the establishment of a ‘bingo area’ in all licensed bingo premises to help create a clearer distinction between adult gaming centres and bingo premises, and to ensure that land-based gambling premises are appropriately licensed. The consultation proposes three options for the amount of floor space in licensed bingo premises that should be designated as a continuous bingo area – either a 30, 40 or 50 percent minimum (it is Government’s view that requiring a proportion of floor space greater than 50 percent of the venue could be disproportionately burdensome for some small bingo venues.).

Government is also seeking views on rules that could apply to a ‘bingo area’, including prohibiting cabinet and in-fill style gaming machines in a ‘bingo area’, the type of content that can be included on electronic bino terminals in the ‘bingo area’, and requiring a minimum number of positions for bingo in the ‘bingo area’.

Participants may respond online or email their responses to the consultation questions to [email protected]. The consultation closes at 11:59pm on 9 January 2026.

If you have any questions, please do not hesitate to contact us.

21Oct

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

21st October 2025 Harris Hagan 74

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.

20Jun

21 years of Harris Hagan

20th June 2025 Harris Hagan 122

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.