20Nov

The Legal 500 Country Comparative Guide – Gambling Law

20th November 2025 Ruby Duncalf 6

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 13

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 18

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 23

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.

24Oct

Reminder: Updates to the RTS and transparency of protection of customer funds come into effect on 31 October 2025

24th October 2025 Ruby Duncalf 29

Licensees are reminded that updates to the remote gambling and software technical standards (“RTS”), along with new requirements regarding the transparency of protection of customer funds, come into effect on 31 October 2025. We previously reported on the upcoming changes he r e, and this post serves as a timely reminder to ensure all licensees are fully prepared for the upcoming changes. Licensees should ensure they are compliant with the requirements before 31 October 2025.

Summary of the RTS updates

Following the Gambling Commission’s response to its Autumn 2023 consultation, amendments to RTS 12 – Financial limits are scheduled to come into effect at the end of the month. These changes will apply across all gambling products, with the exception of subscription lotteries. For ease of reference, we have set out below the RTS 12 in effect from 31 October 2025. Licensees should familiarise themselves with the updated RTS to ensure they are compliant.

RTS requirement 12A

The gambling system must provide easily accessible facilities for customers to set their own financial limits at any time from the point of registration. 

Customers must be prompted to set a limit as part of the registration process or at the point at which the customer makes the first deposit or payment. The limit must be implemented as soon as practicable after the customer’s request. The customer must be informed when the limit will come into force. 

RTS implementation guidance 12A:

Limits could be in the form of:
1. deposit limits: where the amount a customer deposits into their account is limited over a particular duration.
2. spend limits: where the amount a customer spends on gambling (or specific gambling products) is restricted for a given period – this type of limit may be appropriate where the customer does not hold a deposit account with the operator.
3. loss limits: where the amount lost (that is, winnings subtracted from the amount spent) is restricted (for instance when a customer makes a £10 bet and wins £8, the loss is £2).
The period/duration of the limits on offer should include:
1. 24 hours;
2. 7 days; and
3. one month
where a customer sets simultaneous time frames, for example a daily deposit limit and a weekly limit, the lowest limit should always apply. Therefore, if a daily deposit limit of £10 and a weekly limit of £100 are both set then the maximum the system should allow to be deposited is £10 per day and £70 per week.

RTS requirement 12B

Customers must be presented with a ‘free text’ box to set a limit, or the equivalent in the case of telephone gambling. 

As a minimum, limits must be applied at the account level. 

RTS implementation guidance 12B:

In addition to account-level limits, limits could be implemented across individual products or channels. Where gambling licensees offer the facility to set limits for individual products or channels it should be made clear to customers using the facility whether those limits apply at the account or product/channel level. For example, where a limit has been set for a specific game, a customer should not be misled into assuming that the limit automatically applies to other products.
Where a customer sets simultaneous time frames, gambling licensees should provide clear information on how the interaction between those limits works.
Operators could provide links to tools or resources to inform budgeting and aid customers in determining appropriate limits for their personal circumstances.
In order to mitigate against user error, the gambling system could permit specific monetary increments for limits, such as whole pounds.

RTS requirement 12C

Financial limit facilities must be provided via a direct link on the homepage and be clearly visible and accessible. 

Financial limit facilities must be clearly visible and accessible on deposit pages/screens or via a direct link on these pages or screens. 

The gambling system must minimise the number of clicks or pages customers make in order to access financial limit facilities.

RTS implementation guidance 12C: Links to limit-setting facilities from communications such as emails or notifications should link directly to the facilities and not via a home page or other intermediate page(s), unless required by account log in security settings.

RTS requirement 12D

Customer-led limits must only be increased at the customer’s request, only after a cooling-off period of at least 24 hours has elapsed and only once the customer has taken positive action at the end of the cooling off period to confirm their request. 

Unless systems/technical failures prevent it, customer-led reductions to limits must be implemented immediately.  

The gambling system must provide a prompt to customers to review their own account and transaction information, as is currently made available under RTS 1 – Customer account information. This must be provided at a minimum of six-month intervals for accounts with activity within a rolling 12-month period. Customers must be provided with facilities to set more frequent reminders to receive this statement and review their limits. 

RTS implementation guidance 12D:

In the event of systems or technical failure not facilitating an automated and/or immediate reduction in limits, the customer should be informed when the limit reduction will take effect.
Operators should monitor engagement with and responses to alerts, in order to inform good design and best practice.

RTS requirement 12E

Financial limit-setting facilities must present setting a limit as the default choice. The gambling system must require an action by the customer in order to decline setting a limit. 

The gambling system must receive confirmation that the customer does not wish to set a limit before moving on to deposit/gamble. 

The gambling system must prompt existing customers without limits set to review this position as a minimum on an annual basis.

RTS implementation guidance 12E:

Presentation of financial limits as the default option could take the form of pre-selected fields such as tick boxes, or through visual distinction.
Action to decline setting a limit and receiving confirmation could take the form of a tick box, dismissing a message or other action by the customer.
Customers who choose to opt out of setting a limit could be provided with information or links to tools and resources such as budgeting tools and information about safer gambling.

Please note that on 7 October 2025 the Gambling Commission published its response to its supplementary consultation on the definitions of different types of financial limits, which will result in further changes to RTS 12 which will take effect on 30 June 2026.

Summary of update to transparency of customer funds

On 31 October 2025, licence condition 4.2.1 shall be amended with a paragraph added at licence condition 4.2.1(3). Subsequent paragraphs will be renumbered accordingly. The amendment shall apply to all operating licences, with the exception of gaming machine technical standards, gambling software, host, ancillary remote bingo and ancillary remote casino licences.

Under the updated licence condition, licensees who have selected a ‘not protected’ rating (i.e. in the case of a gambling company becoming insolvent, any money in a customer’s account would be classed as part of the company’s assets), will be required to remind customers every six months that their funds are not protected in the event of insolvency. The reminder must refer to the value of funds held for the customer. The licensee must require the customer to acknowledge receipt of the information and must not permit the customer to utilise the funds for gambling until they have done so.

Next steps

Licensees are strongly encouraged to review the revised RTS and implementation guidance in full, and updated licence condition 4.2.1, to ensure all necessary changes are made ahead of the 31 October 2025 implementation date.

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

17Sep

Failure to prevent fraud offence in force from 1 September 2025

17th September 2025 Ting Fung 71

The new corporate criminal offence of ‘failure to prevent fraud’, which may apply to certain Gambling Commission licensees, came into to force on 1 September 2025 under the Economic Crime and Corporate Transparency Act 2023 (“ECCTA”).

The offence applies to “large” organisations only (defined in section 201 of ECCTA, and is based on turnover, balance sheet total and/or number of employees) and applies across the UK. Nevertheless, guidance published by the Home Office (Economic Crime and Corporate Transparency Act 2023: Guidance to organisations on the offence of failure to prevent fraud) (“Guidance”) states:

Although the offence of failure to prevent fraud applies only to large organisations, the principles outlined in this guidance represent good practice and may be helpful for smaller organisations.

Relevant licensees can find further information in the Guidance to assist them in taking appropriate action to prevent fraud, as well as in the Home Office’s collection on ECCTA.

It is a licensing objective under the Gambling Act 2005 to prevent gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime, and the Gambling Commission expects all licensees to have effective measures in place to do so.

If you have any queries about the above, please do not hesitate to get in touch.

05Aug

Gambling Commission Annual Report and Accounts 2024-2025

5th August 2025 Tiffany Babayemi 92

On 29 July 2025, the Gambling Commission published its Annual report and accounts 2024 – 2025 (the “Annual Report”) for the period 1 April 2024 to 31 March 2025 (the “Period”), which the Gambling Commission describes as a “busy and productive year…in its work to make gambling in Great Britain safer, fairer and crime-free”.

Key focuses of the Gambling Commission during the Period include (a) the publication of its new three-year Corporate Strategy, (b) the implementation of measures flowing from the Gambling Act Review (the “Review”), and (c) the National Lottery. The Gambling Commission also highlights other areas in which it considers to have made progress, including tackling illegal gambling, its collection and use of data, and improving its operational and financial performance.

The Annual Report contains a performance report in which the Gambling Commission provides a detailed overview of its delivery during the Period against the five strategic objectives from its Corporate Strategy 2024 to 2027. Key highlights from the performance report in respect of each strategic objective are set out below:

Using data and analytics to make gambling regulation more effective

The Gambling Commission progressed in closing evidence gaps in priority areas across all licensing objectives by publishing its Evidence Gaps and Priorities programme. The Gambling Commission has also been exploring drivers of consumers’ trust in gambling which can be tracked over time through the Gambling Survey for Great Britain (“GSGB”).
Regulatory return requirements were amended following consultation by streamlining the number of questions asked and harmonising reporting periods to be on a quarterly, rather than annual, basis. The first annual report from the new GSGB was published.
The Gambling Commission launched a pilot scheme by collaborating with a small group of volunteering operators to develop the Gambling Commission’s approach to obtaining a regular feed of core data that will give up-to-date insight into how people’s gambling is changing.

Enhancing core operational functions

In 2024, the Gambling Commission’s licensing team piloted a revised relationship management approach where licensees were supported by a dedicated team via phone and email to resolve queries, ranging from advice on filling out the new regulatory return forms to technical queries relating to the application of requirements. It also established an Operator Engagement Forum.
The Gambling Commission took steps to increase its efforts in tackling and disrupting illegal gambling activity, issuing 516 cease and desist requests to illegal operators (an increase from 384 during 2023-2024), and a further 352 to advertisers and/or affiliates of unlicensed operators. The Gambling Commission’s response to the December 2023 consultation on financial penalties was published and made significant changes to its Statement of Principles for Determining Financial Penalties.
During 2024 -2025, the Gambling Commission improved the transparency of industry compliance by reporting on the findings of its compliance work within its suite of impact metrics, a set of headline figures intended to help demonstrate the Gambling Commission’s impact.

Setting clear evidence-based requirements for licensees

During 2024-2025, the Gambling Commission published multiple consultation responses and fully implemented several reformative measures of the White Paper. This included launching the Financial Risk Assessment pilot scheme, introducing the Statutory Levy and increasing the coverage of Personal Management Licences.

Being proactive and addressing issues at the earliest opportunity

The Gambling Commission developed and embedded an Industry Forum to provide insight into the Gambling Commission’s plans, the quality of its service and the wider environment in which licensees work.
A comprehensive strategic assessment of the fair and open licensing objective was conducted, which has resulted in the Gambling Commission focusing on a package of improvement works during 2025-2026 to improve transparency for consumers on the reasons for identity checks or account restrictions, particularly where these take place later in the consumer journey, such as on withdrawal.

Regulating a successful National Lottery

The 4th National Lottery (“4NL”) Licence started on 1 February 2024 with Allwyn succeeding Camelot UK Lotteries Limited as the licensee. The Gambling Commission continued to prioritise and uphold the National Lottery duties. The 4NL controls have been fully embedded through the 4NL Programme, which includes agreed upgrades to the systems, the website and mobile application, to enhance the user experience and ensure the National Lottery is fit for purpose for the duration of the Licence and beyond.
The Gambling Commission notes its enforcement investigation against Allwyn for not delivering full functionality by February 2025, and also the active litigation brought against the Gambling Commission by The New Lottery Company, one of the unsuccessful bidders for the 4NL Licence.

The Gambling Commission also acknowledges:

Its increased cooperation with international regulators during 2024-2025 and its intention to continue to build its international network.
That the current system for Gambling Commission fees is “unusual and inflexible” and that it has begun to explore options for reforming its fee structure, which is a key commitment of the White Paper.

The remainder of the Annual Report discusses the financial and sustainability performance of the Gambling Commission, its corporate governance and internal risk management systems, and provides details of the Gambling Commission’s financial statements.

What’s next?

In the Foreword of the Annual Report, Gambling Commission Interim Chair, Charles Counsell, and its Chief Executive and Accounting Officer, Andrew Rhodes, both agree that:

“The substantial work done in 2024-2025 gives the Commission a great opportunity to make further steps forward in our work to make gambling safer, fairer and crime free. This is an opportunity everyone at the Commission is fully dedicated to making the most of in the year ahead.”

We encourage readers to read the Annual Report and the Gambling Commission’s Corporate Strategy 2024 to 2027. For further details on the Corporate Strategy, please see our previous blog. If you have any questions regarding the Gambling Commission’s various areas of focus in the industry, please do not hesitate to get in touch.

16Jul

Gambling Commission improvements to financial penalties determination process

16th July 2025 Ting Fung 106

The Gambling Commission confirmed last week that improvements to its process for calculating and imposing financial penalties are imminent, with all changes to come into effect on 10 October 2025.

The changes aim to strengthen the transparency and consistency of how the Gambling Commission imposes penalties. John Pierce, Director of Enforcement and Intelligence at the Gambling Commission stated that:

“The…changes will to improve the efficiency and effectiveness of our enforcement work. Crucially, the new approach also encourages compliance at the earliest opportunity, supporting the protection of consumers alongside fair and proportionate outcomes for operators.”

The upcoming changes follow the Gambling Commission’s 2023 consultation on its Statement of principles for determining financial penalties (“Statement of Principles”) which will be updated to include the following changes:

providing a clear and distinct seven step process that the Gambling Commission will follow when assessing and imposing a financial penalty;
providing added clarity on the ‘disgorgement’ element of the penalty where clear consumer detriment and/or financial gain by the licensee has resulted directly from the breach;
providing transparency on how the Gambling Commission will determine the level of seriousness of the breach, which factors will be relevant, and introducing five levels of seriousness;
setting out a defined methodology for determining the starting point for the penal element of the penalty by reference to the seriousness of the breach and (in most cases) a percentage of Gross Gambling Yield (GGY) or equivalent income generated during the period of the breach;
including a methodology for addressing situations involving multiple breaches during a period; and
including a methodology for making adjustments to the penalty for aggravating and mitigating factors, deterrence and early resolution.

Further information on these changes, including the revised wording that will appear in the Gambling Commission’s Statement of Principles, is set out in its consultation response document.

Please also see our previous blog “Naughty or Nice?” – the Gambling Commission publishes its latest consultation on financial penalties and financial key event reporting.

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

15Jul

DCMS research report on online prize draws and competitions market study, harms and potential interventions

15th July 2025 Tiffany Babayemi 96

On 26 June 2025, the Department for Culture, Media and Sport (“DCMS”) published a research report on online prize draws and competitions market study, assessment of harm and review of potential interventions (the “Report”). London Economics, a leading specialist policy and economics consultancy, was commissioned by DCMS in August 2023 to conduct research into the prize draws and competitions (“PDCs”) industry, with the view to providing DCMS with a better understanding of the PDCs market, and to inform consideration of whether any government intervention may be required in this sector and, if so, what form that intervention could take.

Purpose and objectives of the study

It is recognised that although the PDCs industry has grown rapidly in the UK in recent years, little research into this sector has been conducted to date. PDCs are similar to lotteries in that players purchase tickets to participate and prizes are awarded at least partly based on chance. However, they differ from lotteries in (at least) one of two ways: ‘prize draws’ offer a free entry route and ‘prize competitions’ have a skill element (e.g. answering a question) meaning that prizes are not allocated entirely by chance. Due to these characteristics PDCs are not regulated under the Gambling Act 2005 (unlike lotteries), meaning that they are not subject to gambling regulatory oversight.

The research was structured around three overarching questions:

What is the size and scale of the prize draws and competitions market (both demand and supply)? (Section 2 of the Report)
What evidence is there of negative consequences from these products? (Section 3 of the Report)
If any harm is identified, what would be the most effective and proportionate intervention? (Section 4 of the Report)

Section 3 reviews the evidence about whether there is any harm both gambling and non-gambling (consumer), arising from PDCs, and the impact that they have on the regulated lottery industry.

Section 4 focuses on the case for government intervention in the PDCs industry to address reducing the risk of gambling harm from PDCs, improving the integrity and transparency of PDCs, and protecting donations to charities. It suggests three interventions:

Changes to gambling regulation

The Report considers the possibility of bringing PDCs under the oversight of the Gambling Commission and the requirement for PDC operators to have a licence to operate. Doing so would mean PDC operators would be required to implement player protection and transparency obligations, including:

Minimum age for participation
Provision of self-exclusion mechanisms
Safer gambling messaging and signposting to gambling harm charities
Caps on entries and/or spend per player
Limits on promotional offers
Ban on accepting credit card payments
Provision of information to consumers on how and where proceeds are used, on how prizes are allocated and the likelihood of winning a prize
Possible limits on sizes of prizes and ticket sales

Bringing PDCs within the Gambling Commission’s remit would give the Gambling Commission an opportunity to regulate the instant win games offered by operators, and to mandate gambling duty/minimum charitable donations for PDC operators.

Greater enforcement of consumer protection rules

The Report offers an alternative option of pursuing more assertive enforcement of consumer protection rules, which could be an effective way to address consumer harm in the market for PDCs. Such an intervention could include the existing framework of rules for consumer protection, including the work done by consumer protection bodies such as the Advertising Standards Authority, which has previously taken action against potentially harmful advertising by PDC operators, for example in relation to the free entry route. Whilst this intervention method is expected to increase transparency in the market, it is noted that additional costs incurred by operators to comply with enforcement may be passed on to consumers in the form of increased prices or reduced quality.

Voluntary code of conduct

The Report suggests that the introduction of a voluntary code of conduct for operators of PDCs could be used to set industry standards for measures used to protect players from harm. Although such a code would not legally require PDC operators to implement the kinds of player protection measures that lotteries have, it may induce them to do so, especially if the alternative is direct regulation. Of the three possible interventions, this would be the quickest and least costly to implement, and of the three, was the preferred option of the PDC industry, with many PDC operators expressing an interest in being involved in a Working Group to develop such a code. However, this intervention runs the risk of having poor take-up and/or adherence, given its voluntary status.

The Report concludes that the three interventions outlined offer different strengths and weaknesses in addressing the case for intervention and carry different practical implications and different risks of negative consequences, and notes that all these considerations should inform the government’s eventual choice of intervention(s).

We encourage stakeholders to read the full Report published by the DCMS. Please get in touch with us if you have any questions about this research report or the PDCs market.

09Jun

Gambling Commission welcomes OSR review of the Gambling Survey for Great Britain

9th June 2025 Tiffany Babayemi 111

On 22 May 2025, the Gambling Commission welcomed the findings from the Office for Statistics Regulation’s (“OSR”) review of the Gambling Survey for Great Britain.

The GSGB

In July 2024, the Gambling Commission published the Gambling Survey for Great Britain (the “GSGB”), which sets out the Gambling Commission’s official statistics on gambling behaviours in Great Britain. After several years of extensive development, the Gambling Commission asked OSR to review GSGB against its standards in the Code of Practice for Statistics to support continual improvement and provide independent assurance on quality and transparency.

OSR review of the GSGB

OSR published a public statement and comprehensive review of the GSGB and provided a series of important recommendations to further enhance its reliability and user engagement.

According to OSR, the absence of accredited official statistics status does not imply the GSGB is of lower quality or reliability than other surveys which have “accredited official statistics” status, and that the decision on which one to use should be based on user need and not accreditation status. OSR acknowledged how the Gambling Commission had presented clear and impartial information about the strengths and limitations of the methodological approach and statistical uncertainty of survey estimates.

While the Gambling Commission had already acted on several areas outlined in the report based on earlier feedback, the Gambling Commission has confirmed it will provide a further, fuller update in July 2025 in line with OSR’s request. The Gambling Commission has noted that its guidance for users of the GSGB was updated in February 2025, with clearer examples and dedicated contact channels for questions or concerns. The Gambling Commission has also committed to promoting this guidance more widely and embedding it across all future releases.

OSR noted that communication and user engagement will be critical to the GSGB’s ongoing success. In response, the Gambling Commission has announced plans to establish a GSGB Statistics User Group. Around 70 stakeholders have already expressed interest in joining the group, which will serve as a forum for dialogue, feedback, and shared learning.

Ben Haden, Director of Research and Statistics at the Gambling Commission, said:

“We welcome the findings from OSR, both the public statement regarding casework they have received in relation to GSGB and their overall review of the GSGB. We are pleased they recognise the huge amount of work that the team has put into developing and delivering the largest survey of its kind in the world. We also welcome OSR’s recommendations for further action, which closely align with work that we already have underway.”

Other recommendations

The Gambling Commission has noted that further improvements are underway in line with recommendations from the independent review of the GSGB by Professor Patrick Sturgis of the London School of Economics and Political Science. An experimental research project was launched by the Gambling Commission in April 2025 to test specific aspects of the GSGB’s methodology, and fieldwork is now in progress, with findings expected in Summer 2025. These results will inform the second GSGB annual report, due for publication on 2 October 2025.

Other recommendations that the Gambling Commission confirms it has already actioned:

survey improvement plan updated with further information for users;
new survey questions designed to validate GSGB findings against external data sources, such as GAMSTOP and the Bingo Association; and
improvements to accessibility and usability of GSGB outputs which links to guidance added to statistical outputs released on 22 May 2025.

Other recommendations that the Gambling Commission says it will action:

comparisons with forthcoming datasets from the Health Survey for England and the Adult Psychiatric Morbidity Survey, due in 2025;
publication of a communications strategy to improve how GSGB updates are shared; and
ongoing improvements to accessibility and usability of GSGB outputs to be informed by GSGB stats user group.

The Gambling Commission highlights its continued engagement with other official statistics producers, including Ofcom, the Money and Pensions Service, and devolved government agencies, and is reviewing user engagement frameworks to develop a formal user engagement strategy. In addition, the Gambling Commission stated that a full log of requests to the GSGB statistics from stakeholders has been published as part of its transparency agenda and will be updated quarterly.

The Gambling Commission encourages stakeholders to complete the GSGB Statistics User Group Sign Up Form to learn more about the GSGB or to express interest in joining the user group.

Please let us know if you have any questions on the above and sign up to our blog to receive updates on the continued journey of the GSGB.

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