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 11

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.

10Oct

Gambling Commission publishes update on emerging money laundering and terrorist financing risks

10th October 2025 Ruby Duncalf 26

As part of the Gambling Commission’s ongoing efforts to combat financial crime in the UK gambling sector, its latest emerging risk update (October 2025) highlights the continued and evolving risks posed by pre-payment methods.

This serves as a critical reminder to operators to review their money laundering and terrorist financing (“MLTF”) risk assessments and related policies, procedures and controls.

Why this matters

Under licence condition 12.1.1(3) of the Gambling Commission’s Licence Conditions and Codes of Practice, operators are required to remain informed of emerging MLTF risks, ensuring that such policies, procedures and controls are updated as needed, implemented effectively, and remain effective, taking into account any guidelines published by the Gambling Commission from time to time.

The Gambling Commission’s October 2025 update reinforces earlier emerging risks bulletins published in April 2020 and February 2022 and the Gambling Commission’s 2023 MLTF Risk Assessment, which classified pre-paid payment methods as high risk.

Pre-paid payment methods: Key risk factors

The Gambling Commission considers pre-paid payment methods as high risk due to a variety of factors, including:

Merging of funds – the ability to pre-pay or pre-load using cash and, in some cases cryptoassets either directly or through third party websites.
Anonymity – the anonymous nature of some pre-paid payment methods and lack of traceability.
Credit card circumvention – the ability, in some cases, to pre-pay using credit cards.
Deposits – the open-loop nature of pre-paid methods often do not allow deposits back onto the original card or voucher.

What operators need to do

Update your MLTF risk assessment

In accordance with licence condition 12.1.1, licensees must consider all payment methods in their MLTF risk assessment, including pre-paid cards and pre-paid vouchers. This October 2025 emerging risk bulletin notes that the Gambling Commission’s expectation is that pre-paid payment methods should be treated as high risk, in accordance with the Gambling Commission’s own risk assessment.

Conduct appropriate customer profiling and due diligence checks

The use of pre-paid payment methods must be factored into a customer’s risk profile, and the operator must conduct appropriate due diligence checks. Additional ‘know your customer’ (“KYC”) and source of funds/source of wealth checks are also expected to be conducted by the operator when a customer is identified as presenting a higher risk.

The Gambling Commission reminds operators that they are ultimately responsible for ensuring sufficient customer checks are conducted and that they must not rely on a third party payment processor to conduct such checks on their behalf, or rely on third parties to establish source of funds without scrutiny.

Submit a key event notification (if appropriate)

Licence condition 15.2.1(8) requires operators to submit a key event to the Gambling Commission where there are any changes to the methods by which, and/or the payment processors through which, the licensee accepts payment from customers using their gambling facilities. The Gambling Commission expects such key event notifications to contain the following information as a minimum:

The type of payment method.
The provider.
How the payment method was assessed in the operator’s MLTF risk assessment.

Do not accept payment by credit card

The Gambling Commission reminds licensees that under licence condition 6.1.2(1) they must not accept payment for gambling by credit card, including payments to the licensee made by credit card through a money service business or top up methods for pre-paid cards. Operators must ensure that where pre-paid methods are authorised, they are not used to circumvent this restriction.

Review and update policies and procedures

Licence condition 12.1.1(2) requires that following completion of, and having regard to, the MLTF risk assessment, licensees must ensure that they have appropriate policies, procedures and controls to prevent money laundering and terrorist financing. Licensees must therefore ensure that whenever they update their MLTF risk assessments, their anti-money laundering (“AML”) policies, procedures and controls are also reviewed and updated as needed.

Next steps

Please get in touch with us if you have any questions or would like further advice on updating your AML policies and procedures, and sign up to our blog to make sure you receive updates on any emerging MLTF risks.

17Sep

White Paper Series: Payment of the first statutory levy now due

17th September 2025 Ruby Duncalf 58

On 1 September 2025, licensees should have received their first invoice in respect of the Government’s statutory levy. The Gambling Levy Regulations 2025 (“the Regulations”) took effect on 6 April 2025 and introduced a mandated levy on all operating licence holders in Great Britain to fund research, prevention and treatment of gambling harms, which replaces the previous system of RET payments, of which the amount contributed was voluntary.

The Gambling Commission has now provided its guidance on the calculation, collection and payment of the statutory gambling levy (the “Guidance”), which we outline below.

How the statutory levy is calculated

The levy is charged at a set rate ranging from 0.1% to 1.1% of the “leviable amount” (defined in regulations 2(3)-(5) of the Regulations) depending on the licensed activity.

For the majority of operators, the levy is calculated based only on gaming facilities provided to customers in Great Britain (“GB”). For licensees that hold a gambling software licence or are required to hold a licence because they site key remote equipment in GB, the levy is calculated on income deriving from those activities, whether in GB or abroad.

The calculation for the amount owed under the statutory levy is based on the data that licensees provide to the Gambling Commission via their quarterly regulatory returns. The Guidance reminds licensees of their obligation to provide ‘true and correct’ data in their returns, and that any incorrect data submitted would impact the calculation of the amount owed under the levy, and risks licensee non-compliance with the law.

Timing of the statutory levy

The calculation for the first statutory levy period for all licences (except for lottery operating (society) licences) is based on regulatory returns data covering the period July 2024 to March 2025, multiplied by one and one-third. For society lottery licensees, it is based on data for the period 1 April 2024 and 31 March 2025.

Going forward, for all licensees, the statutory levy will be calculated on regulatory returns data from April through to the following March. Invoices will be issued annually on 1 September and will be based on the licensee’s activity from the previous financial year.

Payment of statutory Levy

The first invoices were issued to licensees on 1 September 2025 with full payment required before 1 October 2025. Invoices are available in the invoices tab on licensees’ eServices accounts, and payment can be made by GovPay or bank transfer.

Statutory levy payments must be paid in full (they cannot be made in instalments) only after the invoice has been issued, and before 1 October in the relevant year. Payments must be made to the correct bank account, quoting the invoice number in full, and must not be combined with any other payments to the Gambling Commission. If the levy payment does not meet these requirements, there is a risk that it may be returned and the operating licence could be at risk of revocation.

Invoices relating to GB and non-GB activity

For the first statutory levy period, each licensee will receive one combined invoice for all GB activity and a second invoice for non-GB activity, if appropriate. Operators must pay the full amount of the GB activity invoice before 1 October 2025.

In relation to non-GB activity, the Gambling Commission recognises that some operators may have submitted returns that that either do not fully account for leviable foreign income, or include non-leviable foreign income. If a licensee believes that the Gambling Commission’s non-GB invoice includes non-leviable activity from foreign customers, it is the operator’s responsibility to notify the Commission promptly, and in any case before 1 October 2025, and provide full reasons at to why they believe particular sums are not due. The Gambling Commission will suspend enforcement of that element of the levy until the query is solved.

Incorrect invoices

It is the operator’s responsibility to notify the Gambling Commission if its invoices do not include any sums that ought to be brought into account, and to pay the full sums due, including any shortfall. If it fails to do so, the Gambling Commission may take enforcement measures, including revocation of the licence pursuant to section 119 of the Gambling Act 2005.

Operators should notify the Gambling Commission of any such errors by email at [email protected].

Consequences of not paying the statutory levy

Payment of the statutory levy is a licence requirement, and therefore non-payment, or late payment of the levy, by the licensee could result in revocation of the operating licence, unless the Gambling Commission is satisfied that the late or non-payment is due to an administrative error.

Next steps

Licensees can prepare for the statutory levy payment by ensuring:

regulatory returns data is submitted correctly and on time;
they have access to their organisation’s eServices account;
the Gambling Commission holds the correct contact details (i.e. email address) for their organisation; and
payment is only made once an invoice has been received.

Please get in touch with us if you have any questions about the Regulations or payment of the statutory levy.

15Aug

Horizon Scanning: Key Dates for your Diary

15th August 2025 Ruby Duncalf 105

As the implementation of a number of the White Paper proposals continue to take effect, it is essential that licensees and stakeholders are prepared for the upcoming regulatory reforms. This blog sets out the key dates for licensees to be aware of, to avoid falling foul of the forthcoming changes to regulations.

Key dates for your diary

1 October 2025 – Statutory Levy – the first invoices for this year’s statutory levy will be issued from 1 September 2025, with payment required before 1 October 2025. The statutory levy replaces the previous “RET” payments, and is charged to all gambling licensees (if it is more than £10) at a set percentage rate applied to licensees’ regulatory returns. See our previous blog on the statutory levy here. The Gambling Commission will be issuing guidance on how to pay the levy before September.

10 October 2025 – Changes to the Financial Penalties Determination Process – updates to the Gambling Commission’s Statement of principles for determining financial penalties will come into effect on 10 October 2025, strengthening the transparency and consistency of how the Gambling Commission calculates and imposes penalties. For further details of the changes, please see our previous blog.

31 October 2025 –Updates to the RTS – updates to the remote gambling and software technical standards (“RTS”) to enact minor changes to the existing RTS wording, ‘elevating’ some parts of the implementation guidance to requirements and to introduce new requirements and implementation guidance in respect of customer led tools. These changes are summarised in our previous blog.

31 October 2025 – Transparency of Protection of Customer Funds – operators whose customer funds are ‘not protected’ in the event of insolvency must inform the customer at the point of first deposit, and actively remind them once every six months that their funds are not protected. See our previous blog on this topic here.

19 January 2026 – Socially Responsible Incentives (extended from original implementation date of 19 December 2025) – operators will need to comply with the updated requirements which we outlined in our previous blog, and include:

a ban on mixed product promotions,
a cap on wagering requirements of promotional offers to ten and
a reworded LCCP Social Responsibility Code Provision 5.1.1.

Next steps

Please get in touch with us if you have any questions about the upcoming regulatory changes and sign up to our blog to receive updates on the continued progress of the implementation of the White Paper proposals.

08Aug

Gambling Commission response to OSR review and Gambling Survey for Great Britain

8th August 2025 Ruby Duncalf 94

On 24 July 2025, the Gambling Commission published its review of the Gambling Survey for Great Britain (“GSGB”) and response to the Office for Statistic Regulation (“OSR”) report. The GSGB sets out the Gambling Commission’s official statistics on gambling behaviours in Great Britain, and in our previous blog, we reported on the OSR’s review of the GSGB and their recommendations to the Gambling Commission.

The Gambling Commission’s review reflects on the first year since the publication of the GSGB and how the data is delivering against the Gambling Commission’s aims and expectations. The paper also responds to the OSR’s assessment of the GSGB, and details plans for its ongoing development.

How the GSGB is being used

One aim of the GSGB was for it to be a source of robust data, available to be analysed and used by stakeholders. The Gambling Commission reports that between February 2024 and March 2025, a total of 5,271 users have visited the GSGB pages on the Gambling Commission’s website; the majority of those users are based in the UK, although there has been some international interest as well.

In line with the Gambling Commission’s aim to be open and transparent with GSGB data, the raw data from the GSGB was submitted to the UK Data Service and subsequently published on 19 February 2025. The Gambling Commission recognises that numerous studies and reports have been published that include GSGB data, as well as the GSGB playing “an important role in contributing to policy developments relating to gambling”, including a Parliamentary debate on gambling harms in February 2025.

Response to OSR’s assessment of the GSGB

As discussed in our previous blog, the Gambling Commission asked the OSR to review the GSGB against its standards in the Code of Practice for Statistics. The Gambling Commission addressed the recommendations of the OSR, setting out progress made to date and future intended actions:

Actions in response to Professor Sturgis review

The Gambling Commission reported that since the OSR review, the National Centre for Social Research (“NCSR”), Professor Sturgis and Professor Kuha of the London School of Economics and Political Science have been commissioned to undertake experimental research to implement the recommendations in Professor Sturgis’ independent assessment of the GSGB, published in February 2025. The experimental research is due to be published in Summer 2025 with the second GSGB report scheduled to be published on 2 October 2025, to allow time for feedback to be incorporated into the report.

The survey improvement plan has also been updated to explain that the Gambling Commission will be able to benchmark results from the GSGB against the 2024 Health Survey for England (“HSE”) (once published) and against the Adult Psychiatric Morbidity Survey (“APMS”) which was published in June 2025.

Quality assurance

The Gambling Commission sets out that the GSGB data undergoes quality assurance by the NCSR followed by further quality assurance undertaken by the Gambling Commission, as detailed on its website.

The Gambling Commission will shortly be publishing a new research governance framework, which will underpin quality assurance and research quality, and notes the importance of validating data against other sources; for example the GSGB Annual Report 2023 included, for the first time, data on suicidal ideation/attempts and if they were related to gambling, which was validated against the data in the APMS.

The Gambling Commission will update the GSGB technical report to include a section on data validation by October 2025.

Supporting appropriate use

The Gambling Commission has been monitoring the use of GSGB data, and notes that there have been some common mistakes. Within statistical releases, the Gambling Commission will make it clearer to users that the GSGB produces estimates and these estimates are subject to potential biases; also that the negative consequences of gambling may be overestimated.

Based on early feedback from the OSR of the existing GSGB guidance, the Gambling Commission updated its guidance on using statistics from the GSGB in February 2025 to explain what statistics can and cannot be used for, and why. The Gambling Commission also intends to make it easier for users to find this guidance, and adding links to the guidance from the statistical landing pages and the Excel data tables shall be standard practice going forward.

Coherence and comparability

In its guidance, the Gambling Commission cautions against comparing GSGB data against the data from previous surveys, due to differences in study methodology, but acknowledges that such comparisons are nevertheless useful. It notes that the publication of the next APMS and HSE and further recommendations from the Professor Sturgis review (see 1 above) will provide further opportunities to investigate the coherence and comparability of GSGB statistics.

The Gambling Commission will be publishing a new evidence roadmaps framework, together with its research governance framework, scheduled for September 2025.

Engagement and communication

The OSR recommended that the Gambling Commission should implement a user engagement strategy. The Gambling Commission reported on the transition from the previous stakeholder engagement groups into the GSGB Statistics User Group, to enhance communication and engagement with users of the GSGB and allow the exchange of views, ideas and information between users and the Gambling Commission, share research findings and inform the continued development of the GSGB.

Following feedback from the OSR, a dedicated email address has been set up to receive feedback or queries in relation to the GSGB ([email protected]). The Gambling Commission encourages users to get in touch via the dedicated email address, or to provide ongoing feedback via a feedback form or by joining the GSGB Statistics Users Group.

The Gambling Commission also appended to the paper their communications strategy for the ongoing publication of statistics from GSGB.

Accessibility and usability

The Gambling Commission will continue to publish data from the GSGB in a variety of formats accessible on the Gambling Commission’s website, and to the UK Data Service so other researchers can access it. From October 2025, hyperlinks will be incorporated from the contents page to the relevant table of data.

Other post launch GSGB development work

Whilst reviewing the content for the 2025 GSGB questionnaire, the Gambling Commission has added questions on the following topics:

Consumer trust in gambling.
Unlicensed gambling.
Bingo, to understand the locations in which bingo is played in person.
Whether respondents have registered with GAMSTOP.

Next steps

We encourage readers to read the Gambling Commission’s full response to the OSR’s review of the GSGB ahead of the second annual report due to be published in October 2025. Please get in touch with us if you have any questions on the GSGB and sign up to our blog to receive updates on the ongoing development of the GSGB.

08Aug

White Paper Series: Gambling Commission update on the new gambling promotion rules

8th August 2025 Tiffany Babayemi 97

On 24 July 2025, the Gambling Commission announced that the changes aimed at increasing the safety and simplicity of consumer promotional offers, originally due to come into force on 19 December 2025, will be pushed back by a month and will take effect on 19 January 2026.

What are the new rules?

In our previous blog, we outlined the key changes, which include:

Mixed product promotion ban.

Bonus wagering requirements being limited to 10.

Rewording the Rewards and Bonuses section of the Licence Conditions and Codes of Practice (“LCCP”) regarding Social Responsibility Code 5.1.1 (Rewards and Bonuses).

These changes are part of the Gambling Commission’s response to the Autumn 2023 Consultation and are in line with the commitments within the White Paper.

The reason for this delay in implementation is to allow the gambling industry more time to prepare for the changes, and is in response to an industry request.

Next steps

Licensees should be aware that these changes will now come into force on 19 January 2026. Please get in touch with us if you have any questions about these upcoming changes.

06Aug

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

6th August 2025 Francesca Burnett-Hall 93

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

Background

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

Statutory Instruments

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

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

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

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

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

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

Extended converted casinos:

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

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

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

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

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

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

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

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

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

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

Licensing guidance for licensees and local authorities

Operating licences and betting

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

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

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

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

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

Premises Licences

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

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

Next steps

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

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

05Aug

Gambling Commission Annual Report and Accounts 2024-2025

5th August 2025 Tiffany Babayemi 86

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 100

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.

09Jun

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

9th June 2025 Tiffany Babayemi 108

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.