20Feb

Gambling Commission Launches Consultation on the Destination of Future Regulatory Settlements

20th February 2026 James Frudd 1

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 6

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 51

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.

23Dec

2025: A year in review

23rd December 2025 Ruby Duncalf 83

Over the past year, the industry has experienced significant but steady change. As the year draws to a close, we look back at the key developments over the past 12 months and assess what may lie ahead for 2026.

What happened in 2025?

The year began much as anticipated, with the Department for Media, Culture and Sport (“DCMS”) and the Gambling Commission opening 2025 on a familiar footing of continued consultations and implementation of the Government’s 2023 White Paper proposals. Much of the early part of the year was characterised by regulatory development, rather than disruption, as long-anticipated reforms progressed through amendments to the Licence Conditions and Codes of Practice (“LCCP”) and various statutory instruments coming into force.

Whilst implementation of the White Paper proposals continued into the later stages of the year, the industry experienced a notable shift, as the Gambling Commission stepped up enforcement with a stronger focus on compliance, accountability and the licensing objectives. Seemingly at the beginning of the year, industry failings were less severe than that of previous years, which were reflected through the severity of sanctions imposed. Nevertheless, recent enforcement activity suggests that licensees are facing an increasing pressure to meet regulatory requirements. The Gambling Commission’s approach to enforcement was compounded by substantial tax increases announced in the Autumn 2025 Budget in November, sending shockwaves through the sector.

Throughout the year, the Gambling Commission maintained a steady focus on tackling the illegal gambling market, reinforcing its strategic priorities and sending a clear message to both licensed and unlicensed gambling businesses. Against this backdrop, the industry heads into 2026 contending with heightened scrutiny, financial pressures, and an expectation for licensees to demonstrate stronger culture and governance.

Key developments throughout the year include:

Remote sector

DCMS and the Gambling Commission continued to consult on and implement a series of White Paper proposals. Notable changes to the remote sector include the following:

Amendments to the Remote gambling and software technical standards (“RTS”) came into effect in January following the Gambling Commission’s response to its Summer 2023 consultation. New remote game design requirements, that already applied to slots, were extended to other online products.

The RTS was further updated in October 2025, revising financial limit requirements under RTS 12 as set out in the Gambling Commission’s response to its Autumn 2023 consultation. Responses to the Autumn 2023 consultation also revealed inconsistencies with the interpretation of ‘deposit limits’ across the sector prompting the Gambling Commission’s Supplementary consultation on further changes to RTS 12 aiming to bring greater clarity to the different types of financial limits. The Gambling Commission’s response noted that the relevant changes are due to come into effect on 30 June 2026.
The introduction of social responsibility code provision (“SRCP”) 3.4.4(6), arguably one of the most debated White Paper proposals, now requires remote licensees (noting named exceptions within the relevant SRCP) to conduct financial vulnerability risk checks on customers reaching the relevant threshold of £150 in a rolling 30-day period.
The Gambling Act 2005 (Operating Licence Conditions) (Amendment) Regulations 2025, signed into law in February 2025 and introduced via a licence condition, maximum stake limits for online slots games – £2 for under 25 years (effective from 21 May 2025) and £5 for those 25 years and older (effective from 9 April 2025).

Non-remote sector

Liberalisation for the land-based casino sector was achieved on 22 July 2025 when four statutory instruments came into effect following welcomed reforms proposed in the White Paper (“Non-remote Casino Regulations”). The Non-remote Casino Regulations expanded gaming machine entitlements for “converted casinos”, creating a new category of “extended converted casinos” that may host up to 80 machines subject to floor-space and table-to-machine ratios. The Non-remote Casino Regulations also set out detailed specifications for table gaming areas, gambling areas and non-gambling areas for extended converted casinos, larger converted casinos (with a gambling area of no less than 200m² and which are not extended converted casinos) and eased restrictions for 2005 Act Small Casinos. Additionally, the Non-remote Casino Regulations allow converted casino premises to offer sports betting provided that the licensee holds the relevant operating licence.

Enforcement

Throughout 2025, enforcement action continued against both operating and personal licensees; however, not at the same rate as previous years. In the FY 2024-25, 24 operating licensees faced enforcement action that led to a total of £4.2 million in fines or regulatory settlements, compared to 19 operating licensees and £13.4 million in FY 2023-2024.

We witnessed a marked change in approach in Q4 2025 with various licence suspensions. Andrew Rhodes, CEO of the Gambling Commission, reported in his speech at the BACTA Annual Convention on 27 November 2025 that the Gambling Commission has “undertaken some 13 suspensions across the whole industry in the last few months”. Rhodes also set the tone in respect of future enforcement action at the CEO briefing on 6 November 2025, in the context of conducting due diligence on business partners, stated “…there are no excuses. will not accept any excuses. And you should as a sector, expect to see more enforcement action in the coming weeks and months’’.

Statutory levy

This year, a new mandatory statutory levy was introduced to fund research, education and the treatment of gambling-related harms, replacing the previous voluntary contribution system. The Gambling Levy Regulations 2025 were signed into law in February 2025 and came into force on 6 April 2025. Under the Gambling Levy Regulations 2025, the levy is calculated at a fixed rate, ranging from 0.1% to 1.1% dependant on licensed product, based on the amounts reported in a licensee’s regulatory returns for the preceding 12 months (“Levy Period”). The first statutory levy invoices were issued on 1 September 2025, with payment due each year for that year’s Levy Period before 1 October. The main takeaway from this first year is the importance of submitting accurate regulatory returns to avoid facing inflated statutory levy invoices and regulatory action.

Tackling illegal online gambling

Tackling illegal gambling remains a central priority for the Gambling Commission, as reflected in its 2024–27 corporate strategy. This focus has intensified over the past year, with the publication of a four-part series analysing consumer engagement with illegal online gambling. Additionally, the Gambling Commission is seeking enhanced enforcement powers through the Crime and Policing Bill (the “Bill”), introduced into parliament on 25 February 2025, proposing to grant the Gambling Commission powers to remove IP addresses and domain names linked to unlawful gambling. As of December 2025, the Bill is in the Committee Stage in the House of Lords.

Whilst the Bill progresses through Parliament, the Gambling Commission has continued active enforcement, including reviewing suppliers’ operating licences for links to unlicensed operators and issued repeated warnings to licensees to conduct thorough due diligence on third-party partners, including the Industry Warning Notice issued in January 2025 and issuing a joint Institutional Statement together with other European regulators in November 2025.

The Chancellor also announced in the Autumn 2025 Budget that the Gambling Commission will receive an additional £26 million of funding in the next three years to tackle the illegal market. Given these developments, it is highly likely that the Gambling Commission will maintain and strengthen its focus on tackling illegal gambling throughout 2026.

Tax

The Autumn 2025 Budget was delivered by the Chancellor of the Exchequer on 26 November 2025. The industry had braced itself for some heavy hitting tax increases, the disappointing remote sector increases were higher than expected. The Chancellor announced that:

from April 2026 Remote Gaming Duty will increase from 21% to 40%;
a departure from a unified tax rate for non-remote and remote betting, introducing a remote General Betting Duty increasing tax on remote betting from the current 15% to 25% from April 2027;
the abolition of Bingo Duty effective from April 2026.

There is no doubt that the significant increases in tax are going to have a direct impact on gambling businesses with profits shrinking. We expect to see increased M&A activity, as businesses struggle to compete, and a reduction in spend in areas such as marketing and promotions expected across the industry.

2025 industry timeline

17 January – Various updates to the RTS relating to game design requirements came into effect.
20 January –The Gambling Commission issued an industry warning notice on licensed software appearing on the illegal market.
29 January –The Gambling Commission opened its January 2025 consultation, consulting on proposed changes to the Gaming Machine Technical Standards, the Gaming Machine Testing Strategy and the LCCP.
30 January –Gambling Commission published its guidance on online stake limits.
4 February –The Gambling Commission published its response to its Autumn 2023 consultation confirming new requirements for customer led tools, improved transparency on customer funds and removing RET requirements.
10 February –The Gambling Commission confirmed that the first stage of its three-stage financial risk assessment pilot was complete.
25 February – The Gambling Act 2005 (Operating Licence Conditions) (Amendment) Regulations 2025, signed into law, requiring £2 stake limits for 18 to 25 year olds and £5 stake limits for over 25 year olds. The Gambling Levy Regulations 2025, were also signed into law, requiring all operating licence holders in Great Britain to pay a mandated levy to the Gambling Commission.
28 February –SRCP 3.4.4(7) requiring financial vulnerability checks at £500 a month were reduced to £150 a month, as set out in SRCP 3.4.4(6).
6 March – The Gambling Commission launched its Supplementary consultation setting out proposals relating to the RTS and definitions of ‘deposit limits’ and other types of financial limits.
26 March – The Gambling Commission published a further response to its Autumn 2023 consultation in relation to a ban on mixed product promotions, a cap on wagering requirements on bonus funds and rewording of SRCP 5.1.1 (Rewards and Bonuses).
31 March – SRCP 3.1.1(2) was removed from the LCCP as licensees are no longer required to make annual financial contributions to a list of research, prevention and treatment organisations.
6 April – The Gambling Levy Regulations 2025 came into force.
9 April – The Gambling Act 2005 (Operating Licence Conditions) (Amendment) Regulations 2025 came into effect, requiring licensees who hold a remote casino operating licence to introduce a maximum stake limit of £5.
17 April – The Gambling Commission issued an industry warning notice on the failure to complete and/or timely submission of regulatory returns.
1 May – SRCP 5.1.12 introduced new direct marketing requirements. Licensees must now provide customers with options to opt-in to direct marketing on a per product, per channel basis.
21 May – The £2 stake limit for 18 to 24 year olds came into effect and the Gambling Commission issued an update on its three-stage financial risk assessment pilot.
1 July – Statutory instruments affecting the Non-remote Casino Regulations were signed into law.
10 July – The Gambling Commission published its response to its December 2023 consultation confirming updates to the Statement of principles for determining financial penalties aiming to provide greater clarity and transparency.
22 July – The Non-remote Casino Regulations came into effect.
22 August – The Gambling Commission published guidance on the calculation and collection of the statutory gambling levy.
1 September – The first statutory levy invoices were issued. The Advertising Standards Authority (“ASA”) also broadened the scope of the Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code) to extend its application to capture non-paid-for online marketing communications (content marketing, such as social media posts), and capturing advertisements targeting UK customers, preventing licensees that are registered overseas from bypassing the ASA’s regulatory regime.
9 September – The Gambling Commission published guidance on the Non-remote Casino Regulations.
14 September – The ASA published updated guidance to add strength and clarity to the CAP Code requirements on “strong appeal” in relation to gambling advertising.
7 October – The Gambling Commission published its response to its Supplementary consultation confirming further changes to RTS 12 (Financial limits) in respect of deposit limits and other financial limits. The changes to RTS 12 shall come into effect on 30 June 2026.
10 October – Proposed changes to the Statement of principles for determining financial penalties came into effect.
15 October – DCMS launched a consultation on Category D gaming machines and licensing for bingo premises regarding categorisation and stake and prize limits to category D gaming machines and defining bingo areas.
31 October – Updates to RTS 12 in respect of customer led tools came into force and the implementation of licence condition 4.2.1 requiring licensees who have selected a ‘not protected’ rating in respect of customer funds, to remind the customers every six months that their funds are not protected in the event of insolvency.
6 November – The Gambling Commission announced it had concluded its four-part series on illegal online gambling and Andrew Rhodes delivered his speech at the CEO briefing.
25 November – European regulators issued a joint institutional statement calling for stronger measures against illegal gambling.
26 November – Autumn Budget 2025 announcing increases to Remote Gaming Duty (from April 2026) the abolition of Bingo Duty (from April 2026) and the introduction of remote General Betting Duty (from April 2027).
18 December – The Gambling Commission published a further response to its December 2023 consultation on financial key event reporting and response to its consultation on proposed amendments to LCCP as a result of the Digital Market and Competition Consumers Act 2024.

Looking ahead to 2026

Changes due to be implemented in 2026:

19 January 2026 – Updates to SRCP 5.1.1 will come into force introducing socially responsible incentives.
19 March 2026 – Changes to licence condition 15.2.1 impacting financial key event reporting come into force.
30 June 2026 – Further updates to RTS 12 (Financial limits) come into effect.

Expected updates in 2026:

Outcome of the Gambling Commission’s financial risk assessment pilot.
Establishment of the Gambling Ombudsman.
Response to the Gambling Commission’s January 2025 consultation on Gaming Machine Technical Standards, Gaming Machine Testing Strategy and LCCP.
Response to DCMS’s consultation on category D gaming machines and licensing for bingo premises.
DCMS’s consultation on Gambling Commission fees as proposed in the White Paper.
Progress with the Criminal Justice Bill and extension of the Gambling Commission’s powers to tackle illegal gambling.
The Gambling Commission reviewing its position on crypto.

2025 has been a year of considerable change for the industry, the effect of which is expected to be felt in the coming year. We expect that enforcement action will increase in 2026, in a similar way to what we have seen in Q4 2025, and there will be an uptick in M&A activity as the remote sector braces itself for steep tax increases.

We look forward to seeing what 2026 has in store.

Please sign up to our blog to receive continued updates throughout 2026.

22Dec

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

22nd December 2025 Ruby Duncalf 81

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 83

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 95

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 100

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 113

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 115

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.

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