21May

IAGA Gaming Summit 2026 – join us for the responsible gambling panel moderated by David Whyte

21st May 2026 Harris Hagan 20

The 43rd annual International Association of Gaming Advisors (IAGA) Summit will be held at the Ritz-Carlton in Sarasota, Florida from 2 – 4 June 2026.

As part of the 2026 Summit Agenda, Partner, David Whyte, who also sits on IAGA’S EMEA Engagement & Steering Committee will moderate the panel Innovations and Global Perspectives in Responsible Gambling on Thursday 4 June 2026. The session will explore:

The latest trends in responsible gambling programs worldwide, featuring insights from the UK’s advanced initiatives and the Better Gambling Forum’s work.

How the industry is addressing the negative community impacts of betting, including player health and youth protections, and compare international approaches to self-exclusion.

The funding models for research, prevention, and treatment and examining models across jurisdictions that do or do not work.

The session’s panellists are:

Stephen Martino, Chief Compliance Officer

Sarah McCarthy, CEO, Responsible Gambling Council

Jamie McKelvey, Deputy Attorney General and Responsible Gaming Coordinator, New Jersey Division of Gaming Enforcement

Kane Purdy, Managing Director, Gamesys Operations Limited, and Chair, GamProtect, UK

Sarah Taylor, Executive Director, Hoosier Lottery

Date: Thursday 4 June 2026

Time: 1-2pm

Location: Ritz-Carlton, Sarasota

Register for the 2026 Gaming Summit. All Harris Hagan Partners will be in attendance – if you would like to arrange a meeting, please do not hesitate to get in touch.

01May

Gambling Commission provides post-Pilot update on financial risk assessments

1st May 2026 James Frudd 84

On 16 April 2026, the Gambling Commission released a post-Pilot update on the Financial Risk Assessments Pilot (“the Pilot”). In this blog, we consider the Gambling Commission’s findings from the final stage of the Pilot.

Background

The Gambling Commission has been reviewing the results of last year’s financial risk assessments Pilot, and assessing whether the model could meet the aims set out in the 2023 Gambling Act Review White Paper and operate as a practical way of identifying high-spending customers who are in current financial difficulty.

Currently, operators take different approaches to identifying financial difficulties and the information they use to do so. Some operators request documents where this may not be necessary, while others fail to identify and support customers showing signs of financial risk. Financial risk assessments were therefore identified as a more consistent and frictionless means of identifying financial difficulty.

The Gambling Commission says that some commentary on the proposal has been “ill-informed or inaccurate”, including suggestions that consumers are currently being driven to illegal operators as a result of financial risk assessments. The Gambling Commission notes that these checks are not yet in force and no customer has had action taken on the basis of one. Further, they confirm that the proposal does not involve introducing spending caps or limits, and instead, the proposed threshold would act as trigger to check on whether that customer is in financial difficulties.

Financial Risk Assessments and the Pilot

The Gambling Commission summarised financial risk assessments as:

A way of identifying high-spending remote gambling customers who may be in financial difficulties.
Not an “affordability check”.
A targeted and proportionate way of identifying customers who are in current significant or imminently worsening financial difficulties by flagging customers who are, for example, in significant or multiple arrears, defaults or bankruptcy.
Triggered automatically when certain spend thresholds are met.
An assessment made based on data held by credit reference agencies which, for the vast majority of people, would happen behind the scenes.

The purpose of the Pilot was to test whether, and how, financial risk assessments could be introduced to support customers in financial difficulties without adding unnecessary friction to the customer journey. You can read more about the background of the Pilot in our stage 1 and stage 2 blogs.

Current Position and Findings

The Gambling Commission states that the Pilot produced encouraging results in terms of speed and frictionless assessments, and it has been investigating into the practical issues that were raised by businesses during the Pilot.

The Gambling Commission is collating its findings to inform decisions on whether and how to introduce financial risk assessments, and set out the following outcomes and commentary:

Based on the White Paper and the consultation proposals, fewer than 3% of active customer accounts would trigger any operator action under the proposed model.
Of the 3%, the Pilot found that around 97% would be assessed through a frictionless process, without the customer needing to provide documents or take any action. This represents an improvement on the White Paper’s estimate that 80 per cent of assessments would be frictionless.
The White Paper had also estimated that approximately 0.6% of active accounts would both trigger an assessment and be unable to be assessed frictionlessly. However, the Pilot suggests that the figure may in fact be closer to 0.1%. Based on these estimates, operators would only be unable to carry out a frictionless assessment for around 1 in every 1,000 accounts across the remote sector.
The Pilot also showed that better identity and age verification by operators would significantly improve their own frictionless rate. Some operators still allow account details that do not support proper verification, such as allowing customers to register with an initial instead of a full name or using a commercial address, which does not deliver age or identify verification properly. Fixing these cases will support frictionless customer journeys later on. The Gambling Commission will publish further material to assist.
The Gambling Commission recognises operators’ concerns that the customers most likely to fall within scope are often high-spending customers, meaning the practical impact may be more significant than the headline percentages alone suggest. This is an important consideration and any ongoing evaluation will need to assess whether the forms of support used are effective in helping customers gamble sustainably, rather than simply causing them to shift to land-based gambling, other operators or to the illegal market.
The Gambling Commission notes that some operators say the real friction may arise after a risk indicator is identified. Its response is that this is the point of the policy, which is not just to identify financially vulnerable customers, but to ensure support follows.
Customers in the Pilot cohort were found to be more likely to have debt management plans and recent defaults in the last 12 months, comparable consumers in the population. Some of these customers are being supported by operators now, but not all. The Gambling Commission recommends that support could include steps such as deposit limits or reduced marketing, but does not want operators to respond by routinely demanding bank statements or automatically closing accounts as the Gambling Commission wants better outcomes for consumers and not for them to be unnecessarily pushed out of the licensed market by a risk averse response to indicators of risk.
The Gambling Commission recognises that differences between credit reference agencies and the consistency of their data remain an issue but says the Pilot has provided useful evidence on those variations which can help inform practical steps if financial risk assessments are implemented.

The findings from the Pilot will be presented to the Gambling Commission Board for consideration of next steps, although it is stressed that no final decision has yet been taken.

“Despite the success of the pilot in informing those considerations, no one should pre-judge what comes next”

If the proposal is taken forward, it will work with operators and credit reference agencies on a sensible implementation plan, while being mindful of the risk of over-implementation or unnecessarily rapid implementation creating friction for consumers. Guidance will also be developed to help operators take a proportionate approach when offering support to consumers where financial risk is present and high customer spending continues.

The Gambling Commission further emphasises the importance of ongoing evaluation. NatCen has acted as the evaluation partner for the Pilot, and its reports are expected to be published alongside the Commission’s next steps.

Next steps

Please get in touch with us if you have any questions about the financial risk assessments post-Pilot update.

14Apr

Casino sector AML guidance updates

14th April 2026 Ruby Duncalf 139

The Gambling Commission has recently issued two notices relevant to both remote and non-remote casino operating licence holders, reflecting its ongoing expectations in relation to anti-money laundering (“AML”) and compliance. The updates relate to (1) the new digital identity guidance published by HM Treasury and (2) guidance for casinos offering Money Service Business (“MSB”) services.

New digital identity guidance

On 26 February 2026, HM Treasury published its new digital identity guidance setting out how entities regulated under the Money Laundering Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLRs”), including casinos, can use digital identity services for customer due diligence checks (“Digital Identity Guidance”).

The Digital Identity Guidance confirms that digital identity services certified against the UK digital verification services trust framework and listed on the Digital identity and attribute services register can be used by regulated entities as part of their customer due diligence processes, specifically to satisfy their obligations under Regulation 28 of the MLRs. Entities should also ensure that any digital identity services used comply with the record-retention requirements in Regulation 40 of the MLRs. Digital identity services which are not certified and therefore not on the Digital identity and attribute services register cannot reliably be deemed suitable for identity verification in compliance with the MLRs.

The Digital Identity Guidance states that regulated entities should continue to make their own assessment of a customer’s risk and apply enhanced due diligence measures where appropriate, noting that digital verification services are unable to fulfil all aspects of customer due diligence such as assessing and maintaining information on a customer and the purpose and intended nature of the business relationship or occasional transaction. Regulated entities should be mindful that they remain liable for any failures to apply appropriate due diligence measure when using digital identity services.

2. Guidance for casinos offering MSB activities and update notice

Casinos that provide services to customers such as acting as a cheque casher or currency exchange, accepting winners’ cheques and foreign currency or transmitting money are considered to be providing MSB activities under the MLRs. Whilst ordinarily MSBs are regulated by HM Revenue & Customs (“HMRC”), pursuant to Regulation 7(2) of the MLRs, the Gambling Commission and HMRC have agreed that the Gambling Commission will act as the supervisory body for casinos carrying out incidental MSB activities.

All casinos offering MSB services are required to register with HMRC. On 8 January 2026, the Gambling Commission entered into an agreement with HMRC that the Gambling Commission will provide the necessary registration details of those operators providing MSB services directly to HMRC to facilitate their registration. The Gambling Commission issued a further notice on 26 March 2026 requiring casinos offering MSB activities to notify the Gambling Commission within 10 days from the date that they started or stopped providing MSB services, alongside the following information:

Full name of casino
Licence number
Date the MSB service started or stopped
Type of MSB service

This information is to be emailed to the Gambling Commission at [email protected].

Casinos providing certain payment services, such as money remittance or any other payment service, as defined under Schedule 1 of The Payment Services Regulations 2017 (The PSR 2017) must also be authorised or registered with the Financial Conduct Authority. In this instance, licensees holding a casino operating licence will also need to inform the Gambling Commission if they conduct any MSB activity covered under The PSR 2017.

Keeping up-to-date with AML guidance

It is no industry secret that the casino sector, in particular the non-remote casino sector, has been the subject of Gambling Commission focus over the last few months. With that in mind, operators should ensure that they stay up to date with the Gambling Commission’s latest notices and updates.

Please get in touch with us if you have any questions about the use of digital identity services, MSB activities in casinos or any other AML queries in relation to the remote or non-remote casino sector.

20Feb

Gambling Commission Launches Consultation on the Destination of Future Regulatory Settlements

20th February 2026 James Frudd 186

On 5 February 2026, the Gambling Commission opened a consultation on amending section 2.39 of its Statement of Principles for Determining Financial Penalties. The proposal is that future regulatory settlements (payments in lieu of a financial penalty) be paid into the Consolidated Fund, which receives the proceeds of taxation and other government receipts to fund public expenditure. This would align the funding’s destination with financial penalties under the Gambling Act 2005 (the Act).

Background

The regulatory framework provides that the Gambling Commission may impose financial penalties, which are paid to the Consolidated Fund under the Act. The Gambling Commission may also enter into regulatory settlements as an alternative enforcement mechanism. Regulatory settlements, which may involve payments in lieu of a financial penalty, enable the Gambling Commission to reach an appropriate regulatory outcome without initiating a formal licence review.

Currently, the Commission’s Statement of principles for determining financial penalties sets out that payments made in lieu of a financial penalty as part of a regulatory settlement do not need to paid into the Consolidated Fund in the same way as financial penalties. Instead, the Commission has the power to approve the destination of the monies paid as part of a regulatory settlement, which could include returning monies to any identified victims or directing money to charities for socially responsible purposes.

Following the April 2023 White Paper, a statutory levy was introduced and came into force in April 2025. The statutory levy funding is used for the purposes of research, prevention and treatment. In its November 2023 supplementary advice to Government, the Commission identified the need to consider the future destination of regulatory settlement monies in light of the levy and to avoid a dual system.

The proposal

Section 2.39 of the Statement of principles for determining financial penalties to be amended to confirm that payments in lieu of financial penalties are directed to the Consolidated Fund, in the same way as financial penalties.

The proposed wording is as follows:

Payments made in lieu of a financial penalty as part of a regulatory settlement will be paid into the Consolidated Fund in the same way that financial penalties imposed under section 121 of the Act are.

Rationale for the proposal by the Gambling Commission

Alignment with the levy system

The Gambling Commission explored mirroring settlement flows with the levy’s commissioning structures to avoid duplication. After discussions with Government and levy commissioning bodies, this was deemed not feasible due to the complexity and potential volatility of regulatory settlement funds.

Avoiding a dual system

Paying settlements into the Consolidated Fund would prevent parallel funding streams or duplication of work being funded by the statutory levy.

Administrative efficiency

Directing settlements to the Consolidated Fund would facilitate prompt payment and enable Government to determine their use, as is the case for financial penalties.

Next steps

The consultation will run for 8 weeks and will close on Thursday 2 April 2026. Responses can be submitted online or by post to: Policy Team, Gambling Commission, 4^th Floor, Victoria Square House, Birmingham, B2 4BP

Please get in touch with us if you have any questions about the consultation.

19Feb

Gambling Commission announces new gaming machine rules

19th February 2026 Ruby Duncalf 200

On 29 January 2026, the Gambling Commission announced changes to the Licence Conditions and Codes of Practice (“LCCP”) ensuring that non-compliant gaming machines are removed from premises quickly and effectively. The changes come into force on 29 July 2026.

What are the new requirements?

In January 2025, the Gambling Commission opened its January 2025 consultation proposing a new general licence condition to simplify the Gambling Commission’s enforcement processes and to ensure that non-complaint machines are removed from the market. The Gambling Commission recently published its consultation response (the “Response”) confirming a new licence condition applicable to all non-remote casino, bingo, betting, adult gaming centre and family entertainment centre operating licences. The following new licence condition shall come into force on 29 July 2026:

18. Removal of non-compliant gaming machines

18.1. Removal of non-compliant gaming machines

18.1.1. Removal of non-compliant gaming machines

1. 1. Licensees must not make a specified gaming machine available for use in reliance on the licence if the Commission has notified the licensee in writing that the manufacture, supply, installation, adaption, maintenance or repair of the machine:

a. was not carried out in reliance on a gaming machine technical operating licence, or

b. did not comply with the Commission’s gaming machine technical standards.

The written notifications will be sent from the Gambling Commission to the licensee’s primary contact and will clearly outline:

(a) why the Gambling Commission considers the specified gaming machine(s) to be non-compliant;

(b) the actions required; and

The written notification will also clearly identify the “specified gaming machines” in question. The gaming machines would be identified through information such as the machine name, machine manufacturer, machine category and/or premises location.

In the Response, the Gambling Commission re-iterates that licensees who make gaming machines available for use have existing responsibilities to ensure that the gaming machines offered are compliant with the Gambling Act 2005, LCCP and applicable Regulations.

Next steps

The new licence condition comes into force on 29 July 2026. Please get in touch with us if you have any questions about gaming machine compliance or the new licence condition.

19Jan

Reminder: Socially responsible incentives come into effect on 19 January 2026

19th January 2026 Ruby Duncalf 227

Licensees are reminded that the changes to Social Responsibility Code Provision (“SRCP”) 5.1.1 came into effect today, 19 January 2026. The changes apply to all licences (including ancillary licences), except gaming machine technical and software licences.

Summary of changes

Further to the Gambling Commission’s Autumn 2023 consultation response, the new promotional rules, as outlined in our previous blog, resulted in three main changes that came into effect today:

Mixed product promotion ban.
Bonus wagering requirements limited to 10.
Rewording SRCP 5.1.1 Rewards and Bonuses section of the Licence Conditions and Codes of Practice to read:

Social Responsibility Code 5.1.1 Rewards and Bonuses

1. The following applies where a licensee makes available to any customer, or potential customer, an incentive or reward scheme or other arrangement under which a customer may receive money, goods, services or any other advantage (including the discharge in whole or in part of any liability of his) (‘the benefit’).

2. Licensees must:

a. Set out terms and conditions, in relation to an incentive, which are clear, transparent, and fair and readily accessible to any customer or potential customer to whom it was offered.

3. Licensees must not:

a. Apply wagering requirements, which requires a customer to play through bonus funds, over a maximum of 10 times. A wagering requirement is where a customer is required to make wagers totalling a particular value for funds to become withdrawable.

b. Include more than one type of gambling product (betting, casino, bingo, and lottery) within an incentive.

c. Alter or increase the receipt or the value, or amount of the incentive if the qualifying activity or spend is reached within a shorter time than the whole period over which the benefit is offered.

d. Construct incentives where, if the benefit comprises of free or subsidised travel or accommodation which encourages the customer’s attendance at a particular licensed premises, it is offered on terms that directly relate to the level of the customer’s prospective gambling.

Guidance on compliant product promotions

The Gambling Commission’s blog ‘Socially responsible incentives: what operators need to know’ published on 12 December 2025 includes helpful guidance on acceptable forms of product promotions following the Gambling Commission’s ban on mixed product promotions that came into force today. In summary, the following are examples of compliant and non-compliant product promotions:

Examples of compliant promotions

- Promotions that do not mix product types between the initial customer activity and the prize. For example, ‘Bet £5 and get a £10 free bet’.
- Promotions where the initial customer activity and the prize are both within the same product category. For example, ‘Spend £5 on casino products and get 20 free spins’.
- Promotions that are construed in a manner that allows the customer to have full freedom of choice in which product category to use credits or bonus money, for example, ‘Bet £5 to get £10 credit or bonus to be used on all products available’.
- Promotions that allow the customer the freedom to choose which product category they chose to play and the prize or reward is also not limited to product category. For example, ‘Spend £10 on any licensed product of your choice and get £10 credit or bonus to spend on your choice’, or ‘Deposit £5 (not linked to participation of a product category) and get £5 credit or bonus of any licensed product’.

Examples of non-compliant promotions

- Promotions that mix product types. For example, ‘Bet £5 to get 20 free spins’. This offer invites the customer to participate in one type of gambling activity, to get a prize from a different product category.
- Promotions that offer a prizes in respect of different products. For example, ‘Bet £5 and get a £5 free bet and 20 free spins’.
- Promotions that provide the customer with the choice of initial qualifying activity but specify the product category to which the prize is applicable. For example, ‘Spend £10 on any licensed product of your choice and get £5 free bet’.

Next steps

Licensees are encouraged to review the changes to SRCP 5.1.1 to ensure that all necessary changes are made from today, 19 January 2026. Please get in touch with us if you have any questions about the socially responsible incentives.

22Dec

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

22nd December 2025 Ruby Duncalf 237

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 215

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.

17Nov

White Paper Series: Gambling Commission update on deposit limits

17th November 2025 Ruby Duncalf 182

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 174

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.