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Gambling Law

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30Sep

Government Consults on Prohibiting Third-Party Betting on Powerball

30th September 2026 James Frudd Harris Hagan, Lottery, Powerball 16

On 23 September 2026, the Department for Digital, Culture, Media and Sport (“DCMS”) opened a consultation on a proposal to prohibit third-party operators licensed under the Gambling Act 2005 (the “2005 Act”) from offering bets on Powerball.

Background

Powerball was introduced in the UK on 21 July 2026 as part of the National Lottery’s portfolio of draw-based games. Prior to Powerball’s introduction in the UK, a number of operators have historically and continue to offer bets to UK based customers on the outcome of the Powerball draw in the US.

Under section 95 of the 2005 Act, the holder of a betting licence is prohibited from offering a bet on the outcome of a lottery which forms part of the National Lottery. Since Powerball’s recent introduction to the UK, customers have been eligible to place bets on the outcome of the draw via third party operators. DCMS’ proposal is to prohibit licensed third-party operators from offering these bets, bringing Powerball into line with other National Lottery products.

The proposal is intended to reduce customer confusion, protect National Lottery funding for good causes and to bring Powerball into line with other National Lottery products.

Proposed Implementation

The proposed prohibition is intended to be implemented through a new general licence condition that must be attached to relevant betting operating licences by the Commission (as imposed by the Secretary of State through section 78(1) of the 2005 Act.

The restriction would apply only to Powerball, so operators could continue offering bets on other non-National Lottery products, such as the Irish Lotto. Alternative options – including voluntary action, mandatory contributions to good causes and a ban on all lottery betting – were considered but viewed as less effective or disproportionate.

Consultation Response

The government is inviting responses from the betting and lottery sectors, affected operators, players and other interested parties.

The consultation closes at 11:59pm on 4 November 2026. Responses can be submitted through the government’s online consultation form which can be accessed here.

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

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04Aug

Gambling Commission publishes 2026 Money Laundering Risk Assessment

4th August 2026 James Frudd Anti-Money Laundering, Gambling Commission 182

On 30 July 2026, the Gambling Commission published its Risk Assessment of Money Laundering and Terrorist Financing in the British Gambling Industry 2026 (“Risk Assessment”).

The Risk Assessment is an update to the Gambling Commission’s 2023 publication and takes account of, among other factors, HM Treasury and the Home Office’s National Risk Assessment of Money Laundering and Terrorist Financing 2025.

The Risk Assessment informs operators of the current risks in the British gambling industry and is an important resource for licensed operators when preparing their own money laundering, terrorist financing, and proliferation financing risk assessments.

The updated Risk Assessment also meets the Gambling Commission’s obligation under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLRs”) to identify and assess the risks of money laundering and terrorist financing in the casino sector.

What All Gambling Operators Need to Do

All licensees must assess the risks of their business being used for money laundering, terrorist financing, and proliferation financing under licence condition 12.1.1. Licensees under this licence condition must also take account of any relevant learning or guidance published by the Gambling Commission, including the updated Risk Assessment, and are therefore expected to consider the sections of the Risk Assessment that are relevant to their business.

Licensees should:

  • consider how the risks identified may apply to their business;
  • update their own risk assessments where appropriate; and
  • use the risk ratings to help assess the level of risk to their business.

Where a licensee updates its own risk assessment, it must also review and, where applicable, update its policies, procedures and controls, including where risk ratings have changed.

Additional Requirements for Casino Operators

Casino licence holders have an obligation under the MLRs to take account of the Risk Assessment when preparing their own risk assessments.

Casino licensees must:

  • consider how the risks identified in the Risk Assessment apply to their business;
  • update their risk assessment accordingly; and
  • keep an up-to-date record of the steps taken to identify and assess money laundering, terrorist financing, and proliferation financing risks.

Casino operators must use their risk assessments to inform their anti-money laundering and counter-terrorist financing policies, procedures and controls.

Gambling Commission Expectations

The Gambling Commission states that, in its role as supervisory authority, it has a duty to review casino risk assessments on a risk-based approach.

The Gambling Commission recognises that updates to risk assessments, policies, procedures and controls may require internal review and approval. However, it expects updates to be made in a timely manner and for casino operators to be able to demonstrate the steps taken to implement them.

Please get in touch with us if you have any questions about the Gambling Commission’s updated Risk Assessment of Money Laundering and Terrorist Financing 2026.

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07Jul

DCMS confirms increase to Gambling Commission fees from 1 October 2026

7th July 2026 Ruby Duncalf White Paper 250

A review of Gambling Commission fees was originally proposed in the government’s White Paper, High stakes: gambling reform for the digital age in April 2023. Over three years on from the publication of the government’s White Paper, the Department for Culture, Media and Sport (“DCMS”) has announced that the Gambling Commission’s fees shall increase from 1 October 2026. DCMS originally consulted on an increase to Gambling Commission operating licence fees between 27 January 2026 to 30 March 2026, tabling three main proposals in respect of the structuring of the increase in licence fees (“Consultation”).

Since the Gambling Commission’s fees were last reviewed in 2021, the Gambling Commission has increased its investment in areas including disrupting the illegal gambling market, data capabilities, enhancing core operational functions and implementing reforms proposed in the White Paper. Alongside additional pressures, such as inflation, DCMS recognised a need for review of the current fee structure that has been in place since 2017.

What are the changes to Gambling Commission fees?

In its consultation response published on 30 June 2026 (“Consultation Response”), DCMS confirmed that, based on the 47 consultation responses received, it would be diverging from most of its original proposals set out in the Consultation. The government will effect the following changes to Gambling Commission fees through secondary legislation:

  1. Annual fees and application fees will increase by a headline 25%, with the exception of:
  • Society lotteries, for which licence fees will be frozen.
  • General betting (limited) operating licences, where the basis on which fees are set will be adjusted to a market share-based approach based on gross gambling yield (GGY), rather than the number of days of operation.

For full details of the changes to annual fees by licence type, please see Annex One of the Consultation Response or for details of changes to application fees, please see Annex Two. 

  1. New fee categories will be introduced for most licences.
  2. An increase of 25% for personal licences, supplementary operating licences and single machine permits. Personal Management Licence application fees will therefore increase from £370 to £463. For full details, please see Annex Three of the Consultation Response.
  3. Fees for variations and changes of corporate control will also increase by 25%. For full details, please see Annex Three of the Consultation Response.
  4. First annual fees will continue to be charged at 75% of the annual fees. For full details, please see Annex Three of the Consultation Response.

For reference, the Consultation originally proposed three different options with increases to licence fees of (a) 30%, (b) 20%, or (c) 20% plus 10% ringfenced for illegal markets, revenue protection and related activities.

Following the Consultation, the Gambling Commission’s view is the DCMS’s findings now provide certainty on the Gambling Commission’s future income for the coming years. It should be noted that the changes to fees are subject to the passage of secondary legislation, which is planned to take effect on 1 October 2026.

What can operators expect?

The Gambling Commission has confirmed that, over the coming weeks, it will be making contact with operators about further details on how the increase in Gambling Commission fees will affect them and will provide information about alignment to any new fee category. The Gambling Commission will use licensee’s submitted regulatory returns data for 2025 to 2026 to determine its new fee category.

Next steps

Please get in touch with us if you have any questions on the increase to Gambling Commission’s fees or would like to discuss regulatory returns reporting or fee category tracking to ensure you are in the correct fee category.

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03Mar

DCMS announces consultation on ban of unlicensed gambling operator sponsorship in UK sport

3rd March 2026 James Frudd Harris Hagan, Marketing, Uncategorised 410

On 23 February 2026, the Department for Culture, Media and Sport (“DCMS”) announced that it will launch a consultation this spring on prohibiting sponsorship arrangements between British sports clubs, including Premier League clubs, and operators that are not licensed by the Gambling Commission.

The consultation has been launched in light of government’s concerns on the dangers posed by unlicensed gambling operators who do not adhere to laws and guidelines to protect consumers. Those protections include financial vulnerability checks, responsible advertising, fair terms, and data protection. The proposed new measures would mean gambling operators without an operating licence from the Gambling Commission would be restricted from entering into sponsorship arrangements with sports clubs. The consultation therefore aims to mitigate the risks associated with the illegal market and to help eliminate unfair competition for properly regulated firms.

The consultation builds on the Premier League’s April 2023 voluntary commitment to end front‑of‑shirt gambling sponsorship by the end of the 2025–26 season. Despite the commitment, gambling operators, including those that are unlicensed, can instead enter sponsorship deals in respect of shirt sleeves. Government believes that there is a strong case for stopping unlicensed sponsorship altogether given the possibility of driving consumers towards unlicensed sites operating outside the Gambling Commission’s regulatory protections.

Culture Secretary Lisa Nandy said:

“When placing a bet on the big match, fans deserve to know the sites they’re using are properly regulated, with the right protections in place.

It’s not right that unlicensed gambling operators can sponsor some of our biggest football clubs, raising their profile and potentially drawing fans towards sites that don’t meet our regulatory standards.“

Gambling Minister Baroness Twycross said:

“We know the real harm that unregulated gambling can cause, exploiting vulnerable people and leaving consumers without the protections they deserve”

The consultation forms part of the government’s wide work on illegal gambling. In January, DCMS also launched a cross‑industry Illegal Gambling Taskforce . The taskforce will concentrate on (1) stopping illegal operators advertising on social media, (2) preventing payments to unlicensed sites, and (3) improving cross-agency collaboration.

Next steps

The consultation is expected to open in spring 2026. Please get in touch with us if you have any questions about the upcoming consultation.

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19Feb

Gambling Commission announces new gaming machine rules  

19th February 2026 Ruby Duncalf Harris Hagan, Responsible Gambling, Uncategorised 360

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

What are the new requirements?

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

18.     Removal of non-compliant gaming machines

18.1.   Removal of non-compliant gaming machines

18.1.1. Removal of non-compliant gaming machines

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

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

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

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

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

(b)   the actions required; and

(c)   the timeline for completion.

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

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

Next steps

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

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20Nov

The Legal 500 Country Comparative Guide – Gambling Law

20th November 2025 Ruby Duncalf Harris Hagan, Uncategorised 221

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 4th Edition (the “Guide”), with Bahar once again acting as contributing editor.

Legal 500 – Country Comparative Guides 2025Download

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.

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17Nov

White Paper Series: Gambling Commission update on deposit limits

17th November 2025 Ruby Duncalf Harris Hagan, Responsible Gambling, Uncategorised 244

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:

  1. 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.
  2. 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:

  1. 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
  2. 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
  3. 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.

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28Oct

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

28th October 2025 Ting Fung Harris Hagan, Responsible Gambling, Uncategorised 237

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.

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17Sep

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

17th September 2025 Ruby Duncalf White Paper 246

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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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].

  1. 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.

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19May

White Paper Series: Draft Casino Regulations and statutory instruments for non-remote casinos laid before Parliament

19th May 2025 Harris Hagan White Paper 323

On 12 May 2025, the Department for Culture, Media and Sport published its draft proposals to modernise the rules relating to machine allowances and gaming floor dimensions in land-based casinos. The Casinos (Gaming Machines and Mandatory Conditions) Regulations (“the Casinos Regulations”) have been laid in draft before Parliament and form part of a package of interlinked statutory instruments (“SI”) which were published alongside the Casinos Regulations to enable proper scrutiny of the changes to the regulatory framework.

The Statutory Instruments

Two SIs have been published, namely:

  • the Gambling Act 2005 (Commencement No. 6 and Transitional Provisions) (Amendment) Order (the “No. 6 Amendment Order”); and
  • the Gambling Act 2005 (Premises Licences and Provisional Statements) (Amendment) (England and Wales) Regulations (the “Premises Licences Amendment Order”).

The No. 6 Amendment Order will amend The Gambling Act 2005 (Commencement No.6 and Transitional Provisions) Order 2006 by extending the machine entitlements for converted casinos located in England and Wales so that they may make up to 80 Category B, C, or D machines available to use, as long as they meet certain criteria, including:

  1. maintaining a gambling floor area of no less than 280m2; and
  2. ensuring that the number of gaming machines is not more than five times the number of gaming tables which are being ‘used’. A gaming table is ‘being used’ at a particular time if it is actually being used to play a casino game, or is available to be used to play a casino game.

Only converted casinos with a gambling area of at least 500m2 will be permitted the full entitlement of 80 gaming machines. For any converted casinos with a smaller gambling area, the No. 6 Amendment Order sets out a tiered scale linking the maximum number of gaming machines to the minimum gambling area. The maximum permitted number of gaming machines is reduced by 5 for every 20m2 decline in minimum gambling area, from 80 gaming machines for 500m2 down to a maximum of 25 gaming machines for a minimum gambling area of 280m2.

Whilst the No.6 Amendment Order significantly increases machine entitlements for converted casinos, it also intends to close a loophole in the existing framework. Currently, where two (or more) converted casino premises are connected, they can effectively double (or triple etc.) their gaming machine entitlement. The No. 6 Amendment Order makes clear that for such connected converted casino premises, no more than 80 gaming machines are permitted across both premises – taken together – unless customers moving from one premises to the other have to travel through an area which is not subject to certain specified licences or permits issued under the Gambling Act 2005.

In addition, the No. 6 Amendment Order will allow betting to take place in casinos covered by a converted casino premises licence, which is currently only permitted in Gambling Act 2005 small and large casinos.

The Premises Licences Amendment Order updates the current Gambling Act 2005 (Premises Licences and Provisional Statements) Regulations 2007 so that any converted casino applying to utilise the new entitlements under the No.6 Amendment Order must submit a scale plan indicating an area for ‘table gaming’. This must identify the “location and extent of any part of the premises which will be the table gaming area” and “any other part of the premises which will be used for providing facilities for gambling in reliance on the licence.” Currently, only Gambling Act 2005 small and large casinos are required to identify a table gaming area on their plans.

The Casinos Regulations

In addition to effecting the SIs, the draft Casinos Regulations propose:

  • Increasing the ratio of gaming machines permitted per gaming table in Gambling Act 2005 small casinos from two per table to five per table, whilst maintaining an overall cap of 80 machines per premises.
  • Reducing the minimum size of the table gaming area in small casinos from 500m2 to 250m2.

Timing

Whilst they are currently in draft form, the SIs state that they will come into force on 22 July 2025.

If the draft Casinos Regulations are approved by both Houses, Ministers intend to make the No.6 Amendment Order prior to signing the draft Casinos Regulations.

Please let us know if you have any questions on the above and sign up to our blog to receive insight and commentary on the continued journey of the White Paper.

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