01May

Gambling Commission provides post-Pilot update on financial risk assessments

1st May 2026 James Frudd 10

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

Background

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

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

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

Financial Risk Assessments and the Pilot

The Gambling Commission summarised financial risk assessments as:

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

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

Current Position and Findings

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

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

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

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

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

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

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

Next steps

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

03Mar

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

3rd March 2026 James Frudd 146

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.

20Feb

Gambling Commission Launches Consultation on the Destination of Future Regulatory Settlements

20th February 2026 James Frudd 130

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

Background

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

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

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

The proposal

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

The proposed wording is as follows:

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

Rationale for the proposal by the Gambling Commission

Alignment with the levy system

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

Avoiding a dual system

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

Administrative efficiency

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

Next steps

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

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

23Dec

Bahar Alaeddini to host IAGA webinar with Andrew Rhodes on 12 January 2026

23rd December 2025 Harris Hagan 201

Bahar Alaeddini will be hosting the International Association of Gaming Advisors‘ (“IAGA”) In Conversation Best Practices Webinar with Andrew Rhodes, the CEO of the British Gambling Commission on 12 January 2026.

The webinar will be a timely conversation with Andrew on the present — and future — of gambling regulation in the United Kingdom and globally.

In this session Andrew will share his perspective on:

The year ahead and the Gambling Commission’s priorities for 2026, including key areas of regulatory focus.
The evolving UK regulatory landscape – recent reforms, emerging policy trends, and their implications.
The impact, from a regulatory perspective, on the online gambling industry of very substantial tax increases.
The Gambling Commission’s ongoing efforts to combat illegal gambling.
Insights from recent enforcement actions and regulatory interventions, and how the Commission is working to drive earlier, more effective compliance across the industry.

This event is intended for advisors, operators, suppliers, regulators, and other industry stakeholders who want an up-to-date view of UK regulation. We hope you can join us for what promises to be an insightful conversation about the future of global gambling regulation in 2026.

Monday 12 January 2026

8am PST / 11am EST / 4pm GMT

The webinar is free to attend.

Share details about the webinar via:

23Dec

2025: A year in review

23rd December 2025 Ruby Duncalf 176

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

What happened in 2025?

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

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

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

Key developments throughout the year include:

Remote sector

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

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

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

Non-remote sector

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

Enforcement

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

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

Statutory levy

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

Tackling illegal online gambling

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

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

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

Tax

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

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

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

2025 industry timeline

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

Looking ahead to 2026

Changes due to be implemented in 2026:

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

Expected updates in 2026:

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

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

We look forward to seeing what 2026 has in store.

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

17Dec

Regulators issue joint institutional statement on illegal online gambling

17th December 2025 Ruby Duncalf 192

On 25 November 2025, the gambling regulators of Austria, France, Germany, Great Britain, Italy, Portugal and Spain (the “Regulators”) issued a joint institutional statement, calling for stronger measures against illegal online gambling (the “Statement”).

The Statement acknowledges that “illegal online gambling continues to undermine the integrity of regulated markets”, and that “its borderless nature and the speed of technological innovation make it easier for illegal operators to evade regulatory oversight”.

The Regulators expressed their concern at the increasing level of advertising by illegal operators aimed at their jurisdictions. The Statement stressed that advertising disseminated through digital channels, including social media, video platforms and affiliate networks, not only contravenes national legislation but also places citizens, including minors and vulnerable individuals, at heightened risk from illegal gambling activities.

The Statement follows the Gambling Commission’s heightened effort to understand the illegal gambling market, signified by the publication of its four-part series between September 2025 and November 2025, launched to better understand consumer engagement with illegal online gambling, the associated risks and the actions being taken to disrupt it.

In June 2025, experts at the International Association of Gaming Advisors (IAGA) conference, estimated that in 2024 alone, illegal online gambling represented 71% of total iGaming revenue in all 27 EU states or €80.6bn.

By issuing the Statement, the Regulators wished to highlight their strong commitment to consumer protection, market integrity and compliance with national and international regulations within the respective legal frameworks by:

Sharing information on illegal operators between them;
Calling on digital platforms and social media networks to strengthen their control mechanisms to prevent the dissemination of advertising content from unauthorised operators; and
Reaffirming their commitment to share knowledge and better practices in identifying, investigating, and sanctioning operators acting outside the law.

The Statement ultimately signals a clear message: regulators across Europe are united in their determination to combat illegal online gambling, strengthen the integrity of the regulated gambling sector and to protect citizens from the risks posed by illegal gambling activities.

Next steps

Please get in touch if you have any questions regarding unlicensed gambling in Great Britain, your due diligence obligations, and how to actively monitor your business relationships.

28Oct

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

28th October 2025 Ting Fung 169

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 127

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 143

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 163

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.

Gambling Regulation