19Jan

Reminder: Socially responsible incentives come into effect on 19 January 2026

19th January 2026 Ruby Duncalf 14

Licensees are reminded that the changes to Social Responsibility Code Provision (“SRCP”) 5.1.1 came into effect today, 19 January 2026. The changes apply to all licences (including ancillary licences), except gaming machine technical and software licences.

Summary of changes

Further to the Gambling Commission’s Autumn 2023 consultation response, the new promotional rules, as outlined in our previous blog, resulted in three main changes that came into effect today:

Mixed product promotion ban.
Bonus wagering requirements limited to 10.
Rewording SRCP 5.1.1 Rewards and Bonuses section of the Licence Conditions and Codes of Practice to read:

Social Responsibility Code 5.1.1 Rewards and Bonuses

1. The following applies where a licensee makes available to any customer, or potential customer, an incentive or reward scheme or other arrangement under which a customer may receive money, goods, services or any other advantage (including the discharge in whole or in part of any liability of his) (‘the benefit’).

2. Licensees must:

a. Set out terms and conditions, in relation to an incentive, which are clear, transparent, and fair and readily accessible to any customer or potential customer to whom it was offered.

3. Licensees must not:

a. Apply wagering requirements, which requires a customer to play through bonus funds, over a maximum of 10 times. A wagering requirement is where a customer is required to make wagers totalling a particular value for funds to become withdrawable.

b. Include more than one type of gambling product (betting, casino, bingo, and lottery) within an incentive.

c. Alter or increase the receipt or the value, or amount of the incentive if the qualifying activity or spend is reached within a shorter time than the whole period over which the benefit is offered.

d. Construct incentives where, if the benefit comprises of free or subsidised travel or accommodation which encourages the customer’s attendance at a particular licensed premises, it is offered on terms that directly relate to the level of the customer’s prospective gambling.

Guidance on compliant product promotions

The Gambling Commission’s blog ‘Socially responsible incentives: what operators need to know’ published on 12 December 2025 includes helpful guidance on acceptable forms of product promotions following the Gambling Commission’s ban on mixed product promotions that came into force today. In summary, the following are examples of compliant and non-compliant product promotions:

Examples of compliant promotions

- Promotions that do not mix product types between the initial customer activity and the prize. For example, ‘Bet £5 and get a £10 free bet’.
- Promotions where the initial customer activity and the prize are both within the same product category. For example, ‘Spend £5 on casino products and get 20 free spins’.
- Promotions that are construed in a manner that allows the customer to have full freedom of choice in which product category to use credits or bonus money, for example, ‘Bet £5 to get £10 credit or bonus to be used on all products available’.
- Promotions that allow the customer the freedom to choose which product category they chose to play and the prize or reward is also not limited to product category. For example, ‘Spend £10 on any licensed product of your choice and get £10 credit or bonus to spend on your choice’, or ‘Deposit £5 (not linked to participation of a product category) and get £5 credit or bonus of any licensed product’.

Examples of non-compliant promotions

- Promotions that mix product types. For example, ‘Bet £5 to get 20 free spins’. This offer invites the customer to participate in one type of gambling activity, to get a prize from a different product category.
- Promotions that offer a prizes in respect of different products. For example, ‘Bet £5 and get a £5 free bet and 20 free spins’.
- Promotions that provide the customer with the choice of initial qualifying activity but specify the product category to which the prize is applicable. For example, ‘Spend £10 on any licensed product of your choice and get £5 free bet’.

Next steps

Licensees are encouraged to review the changes to SRCP 5.1.1 to ensure that all necessary changes are made from today, 19 January 2026. Please get in touch with us if you have any questions about the socially responsible incentives.

23Dec

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

23rd December 2025 Harris Hagan 48

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 61

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

What happened in 2025?

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

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

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

Key developments throughout the year include:

Remote sector

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

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

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

Non-remote sector

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

Enforcement

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

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

Statutory levy

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

Tackling illegal online gambling

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

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

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

Tax

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

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

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

2025 industry timeline

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

Looking ahead to 2026

Changes due to be implemented in 2026:

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

Expected updates in 2026:

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

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

We look forward to seeing what 2026 has in store.

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

22Dec

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

22nd December 2025 Ruby Duncalf 54

On 21 November 2025, the Department of Media, Culture and Sport (“DCMS”) published the Voluntary Code of Good Practice for Prize Draw Operators (the “Code”) in Great Britain. DCMS estimates the annual market value of the prize draw sector to be £1.3 billion with 7.4 million adult participants annually across approximately 400 operators. DCMS recognises that whilst the operation of prize draws does not require a licence under the Gambling Act 2005, research has shown how prize draws sit adjacent to the gambling industry, presenting concerns in light of gambling-related harms. The Code, agreed by the Government and a significant number of prize draw operators, aims to strengthen player protections and ensure that individuals who participate in prize draws do so more safely.

Purpose and scope of the Code

The Code applies to prize draws in Great Britain where:

a) the outcome (and therefore allocation of prizes) is determined by chance; and

b) there is both a paid entry route and a free entry route.

The Code outlines key measures that prize draw operators are expected to implement to strengthen player protections and ensure that those who participate in these draws do so more safely. The Code is voluntary, applies only to free-entry draw elements of a business, and does not replace existing regulation and requirements for prize draw operators. Any failure to abide by the Code will not itself constitute a breach of an operator’s legal responsibilities.

Implementation timeline

At the time of writing, the Code has been signed by 141 signatories who have committed to implement the Code in full within 6 months of its publication and not later than 20 May 2026 (“Implementation Date”). Operators becoming a signatory of the Code after the Implementation Date must ensure their full compliance immediately. In the absence of an established industry trade body, signatories are expected to share practices on how to implement measures and work with operators who are not yet signatories to the Code to adopt these measures and subsequently join the Code.

Oversight and compliance

DCMS will have oversight of the Code, reserving the right to delegate oversight to an industry trade body as necessary. DCMS will periodically review the Code’s effectiveness, noting that should the Code not be suitably implemented or complied with, DCMS reserve the right, following consultation, to introduce changes where necessary.

All signatories of the Code have agreed to act in good faith. If concerns arise about non-compliance, these should first be raised with the relevant operator or by contacting DCMS at [email protected].

The Code

The Code is divided into three core areas: Player Protections, Transparency, and Accountability, each summarised in turn below.

Player protections

a) Prize draws should only be made available for players aged 18 or over with a reasonable age verification process in place. Advertising should not be targeted at under 18s.
b) Credit card payments in excess of £250 per month per player should not be accepted.
c) Suitable proportionate maximum monthly total spends should be set for players or players should be permitted to set their own, including the option to set a limit at £0.
d) The option to suspend or permanently close an account should be provided to players.
e) Reasonable efforts should be made to have effective systems and processes in place to monitor player activity to identify harm or potential harm.
f) Where operators are able to identify any indicators of harm, they should take a tailored and proportionate approach to intervention that mitigates harm and encourages responsible play.
g) Operators should signpost players to available support for those experiencing harm.
h) An appropriate time period should lapse between a prize draw opening and concluding.
i) Operators should ensure that all marketing and advertising of their prize draws is in line with the CAP and BCAP code, and should be undertaken in a socially responsible manner.

This section of the Code also covers complaints processes, operators’ conduct during a player’s suspension, measures in relation to instant win games, and further requirements regarding marketing and advertising.

Transparency

a) Operators should provide a clear summary of how each prize draw works, including the statement that prizes are to be awarded by chance.
b) Promoters of prize draws should ensure that prizes are awarded fairly in accordance with the rules and terms displayed to players, and this should be by (or under the supervision of) an independent person, unless the winners are selected by a computer process that produces verifiably random and auditable results, or by a certified physical drawing machine.
c) Where possible, prior to entering a draw, operators should provide players with clear and easily accessible information regarding the likelihood of winning a prize and how prizes will be allocated.
d) Operators should clearly and prominently provide players with details of any “free entry” options for the prize draw before the point of purchase, and in line with the requirements of the Gambling Act 2005.
e) Operators should promptly provide the winning player with the advertised prize for a draw or a reasonable cash alternative.

This section of the Code also covers charitable contributions and further details regarding free entry options.

Accountability

a) Operators should have processes in place to monitor and regularly review their own compliance with the Code and, where inadequacies are identified, take swift actions to ensure compliance with the Code.
b) Operators should take reasonable steps to ensure that all relevant Code requirements are also followed by any third parties that support their prize draw operations, such as affiliate marketers or draw management partners. Where third parties are not compliant with the Code, terminating relationships should be considered.
c) Operators should engage with other operators to share best practice in relation to player protections, transparency and accountability.
d) Operators should publish all of the measures they have in place relating to player protections, transparency and accountability, and ensure their adherence with the Code is transparently displayed on their websites.
e) Operators are encouraged to work with DCMS to ensure the Code remains fit for purpose and share any learnings or challenges.

The full Code and requirements can be found here.

Next steps

Please get in touch with us if you have any questions about the implementation or compliance with the Code.

11Dec

Chambers Gaming Law 2025 Global Practice Guide

11th December 2025 Harris Hagan 73

The Chambers Global Practice Guide for Gaming Law 2025 (“the Guide”) has been released and continues to provide guidance on the framework that applies to all types of regulated gambling, while setting out the current outlook and recent changes in around 30 key jurisdictions at the time of writing.

Bahar Alaeddini has reprised her role as Contributing Editor and in her introduction to the Guide, provides an overview of the gambling ecosystem, the global threat of illegal gambling, M&A activity, prediction markets and emerging markets. She is also joined by David Whyte and Jessica Wilson as co-authors of the chapters on UK Law and Practice, and UK Trends and Developments.

The Guide continues to be a helpful resource to lawyers, gambling businesses and others in the industry, providing the latest legal information on a range of topics, including: land-based and online gambling; B2C and B2B licences; application requirements; affiliates; white labels; responsible gambling; AML legislation; restrictions on advertising; acquisitions and changes of control; trends in social gaming, esports, fantasy sports and blockchain; and taxation.

Harris Hagan contributed to the following parts of the publication:

Key trends are covered by jurisdiction under the Trends and Developments section, and the Guide also provides users with the opportunity to perform jurisdiction comparisons using the Compare locations tool.

Please use the above links to review our contributions and use the Guide.

20Nov

The Legal 500 Country Comparative Guide – Gambling Law

20th November 2025 Ruby Duncalf 83

In its fourth year of publication, Partners Bahar Alaeddini and David Whyte have jointly contributed to the UK chapter of The Legal 500: Gambling Law Comparative Guides 2025 4^th Edition (the “Guide”), with Bahar once again acting as contributing editor.

Legal 500 – Country Comparative Guides 2025 Download

The publication – which this year spans 22 jurisdictions – gives the readers an overview of gambling law, regulatory and licensing requirements in various jurisdictions and the UK, on matters including:

key gambling legislation and the legal definition of gambling;
types of gambling licences available, with a headline of the application procedures;
prohibited gambling products;
information on gambling advertising and marketing affiliates;
penalties for unlawful gambling;
anti-money laundering and safer gambling requirements;
shareholder reporting and approval thresholds;
the regulator’s enforcement and sanction powers; and
horizon scanning across the next 12-24 months and risks to the sector.

Of particular interest, in this year’s edition of the Guide are the key proposals for regulatory development expected over the next 12-24 months, including outstanding White Paper reforms, which we outline in the UK chapter.

This year’s edition of the Guide is accompanied by The Legal 500: Hot Topics with Bahar Alaeddini, David Whyte and Associate Ruby Duncalf jointly contributing to the UK chapter, providing a history of and status update on the 2023 White Paper proposals.

You can read the Guide and compare jurisdictions here.

10Nov

Gambling Commission concludes its series on illegal online gambling

10th November 2025 Ting Fung 85

On 6 November 2025, the Gambling Commission published the final report in its four-part series on illegal gambling. The series, which launched in September 2025, aims to understand consumer engagement with illegal online gambling, the associated risks posed and the actions being taken to disrupt it, and has thus far addressed:

Part 1: Consumer awareness, drivers and motivations
Part 2: Consumer engagement and trends
Part 3: Disruption of illegal online gambling

The final report, titled ‘Challenges of estimating the size of the illegal online gambling market’, explores the challenges of quantifying an activity that is, by its nature, hidden. Chief Executive, Andrew Rhodes states that:

“Illegal online gambling remains a serious threat to consumers and to the integrity of the regulated market. While measuring the full scale of the problem is complex, our understanding is growing — and so too is our ability to disrupt illegal operators.”

Challenges to understanding, progress building and shared responsibility

The final report notes the continuing significant methodological challenges of measuring the scale of the illegal online gambling market but also, that although no single estimate of market size has been published, the Gambling Commission has nevertheless, developed a stronger evidence base and clearer understanding of both consumer behaviour and illegal operator tactics. The Gambling Commission emphasises that tackling illegal gambling requires a coordinated response and continued collaboration across government, industry and digital platforms.

Next steps

The Gambling Commission will continue its programme of research, data collection and enforcement activity on illegal gambling, which it identifies as a ‘key strategic priority’ and will provide updates accordingly as it progresses. Annex A of the final report outlines a summary of next steps to improve the reliability of estimates, including options for new sources of data and evidence, alongside an assessment of whether these options will satisfactorily fill key information gaps.

28Oct

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

28th October 2025 Ting Fung 94

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.

28Apr

White Paper Series: The White Paper, 2 years on

28th April 2025 Jessica Wilson 167

The 27 April 2025 marks two years since the Government published its White Paper. As we reach the two-year anniversary, we take the opportunity to reflect on the last 12 months and consider what is in store for the upcoming year.

Where did we get to?

At the one-year anniversary of the White Paper, we noted in our blog that a lot of work had been done by all parties to advance the implementation of the proposals in the White Paper, particularly through the publication of numerous consultations from the Gambling Commission and Government. Whilst progress had been made, at that stage there was no clear direction of travel (until the Gambling Commission’s response to the Summer Consultation was published, just days after the one-year anniversary). Whilst the Government’s goal of implementing the main White Paper measures by summer 2024 seemed like a tight deadline – particularly for the requirements that required secondary legislation – at that time we understood that the Department for Culture, Media and Sport (“DCMS”) would be publishing responses to the consultations on the statutory levy and land-based measures “in the coming weeks”. The industry was also aware that there would be a General Election in 2024, and whilst delays were anticipated, it was thought that this was unlikely to affect the final outcome of the White Paper proposals.

What happened over the last 12 months?

Momentum continued as we entered the second year since the White Paper was published, and the Gambling Commission published its response to its Summer Consultation on the 1 May 2024. Setting out the planned approach for financial vulnerability checks, remote game design, direct marketing and some land-based changes, the consultation response provided the industry with some certainty and confirmation that tangible progress was being made.

However, all activity was brought to a halt when the General Election was announced on 22 May 2024. Originally anticipated for autumn 2024, the General Election took place on 4 July 2024, resulting in a new Labour government. As the new Government was finding its feet (and was on summer recess), momentum in progressing implementation of the White Paper proposals fizzled, and the proposals that required secondary legislation and parliamentary time were put on hold. The second half of 2024 was quieter while we waited patiently for the Government to make its next move.

The Government’s original target of summer 2024 came and went, and it was not until 27 November 2024 when DCMS published its initial response to its consultation on the statutory levy, and confirmed its approach regarding stake limits for online slots (which were originally anticipated to come into effect in September 2024).

As we entered 2025, activity started to increase. The Gambling Commission launched its January 2025 consultation regarding Gaming Machine Technical Standards and Testing Strategy on 29 January 2025, published responses to the Autumn 2023 consultation on 4 February 2025 and 26 March 2025, and launched a supplementary consultation regarding the Remote Technical Standards on 6 March 2025. Additionally, on 25 February 2025, statutory instruments for online slots stake limits and the statutory levy were signed into law.

One constant over the past year is the notable lack of progress in respect of the voluntary creation of a non-statutory Gambling Ombudsman, one of the cornerstone proposals of the White Paper. The Gambling Ombudsman is intended to be an independent, free to use, non-statutory body that will handle social responsibility complaints from consumers and was due to start taking claims from summer 2024.

Key 2024 – 2025 highlights for White Paper proposals at the time of writing are:

The Gambling Commission’s response to its Summer Consultation on 1 May 2024, which set out requirements for many White Paper proposals relating to financial vulnerability checks, remote game design, direct marketing requirements, land-based age verification, and changes to requirements to hold a personal management licence.

The introduction of financial vulnerability checks on 30 August 2024. As the most controversial White Paper proposal, the introduction of such checks is a milestone for the industry. The light-touch financial vulnerability checks involving the assessment of publicly available data came into force at £500 a month to ease introduction. The trigger was reduced to £150 a month from 28 February 2025.

The passing of a Statutory Instrument on 25 February 2025, introducing the statutory levy under The Gambling Levy Regulations 2025 (“The Levy Regulations”), which came into effect on 6 April 2025. The regulations require licensees to pay a mandated levy to the Gambling Commission, unless the amount of that levy is £10 or less. The Gambling Commission published supplementary guidance on 7 April 2025.

The passing of a Statutory Instrument on 25 February 2025, under The Gambling Act (Operating Licence Conditions) (Amendments) Regulations 2025. This introduced online slots stake limits at £5 for those aged 25 and over (applicable from 9 April 2025), and £2 for those aged 18-24 years old (applicable from 21 May 2025). The Gambling Commission published supplementary guidance on 30 January 2025.

April 2024 – April 2025 timeline for the White Paper proposals

1 May 2024 – The Gambling Commission published its response to its Summer 2023 Consultation. Its response confirmed (a) the introduction of light-touch financial vulnerability checks for gambling customers with a net deposit of more than £150 a month, (b) the launch of a pilot scheme to test how enhanced financial risk assessments will work in practice, (c) new remote game design requirements to extend the requirements that already apply to slots to other online products, resulting in publication of new remote technical standards, (d) changes to direct marketing requirements obliging online gambling businesses to provide options to opt-in to product types and channels, (e) requirements for all land-based licensees to carry out age verification test-purchasing, (f) changes to the LCCP to confirm that best practice for land-based operators is “Think 25”, and (g) extension of the management roles expected to hold a personal management licence.

1 May 2024 – The Betting and Gaming Council published the Industry Voluntary Code on Customer Checks and Documentation Requests Based on Spend (the “Code”). The Code was developed jointly between members of the Betting and Gaming Council and the Gambling Commission, and is a voluntary interim scheme intended to bring “consistency across the regulated sector for operators who adopt it – until the frictionless financial risk assessments set out in the Government’s White Paper can be developed, tested and implemented”.

15 May 2024 – Progression of the Criminal Justice Bill, setting out new powers for the Gambling Commission to more effectively take action against illegal online gambling, to the report stage.

16 May 2024 – DCMS published its response to its consultation on Measures relating to the land-based gambling sector. The response outlined the proposed implementation of measures to: relax casino rules for 1968 Act casinos, increase gaming machine entitlement ratios in arcades and bingo halls, accept cashless payments on gaming machines, introduce a legal age limit of 18 for Category D slot style machines, and increase local authority fees. The majority of land-based reforms require legislation to be implemented.

1 July 2024 – Quarterly regulatory returns reporting introduced. This change was originally proposed in the Gambling Commission’s Autumn 2023 Consultation, and was confirmed in its consultation response published on 27 March 2024.

4 July 2024 – UK General Election.

25 July 2024 – The Gambling Commission published the new Gambling Survey of Great Britain (the “GSGB”), collecting data from 20,000 respondents each year and set to establish a new baseline for understanding gambling behaviour in Great Britain. The GSGB publication caused widespread concern in the industry about the accuracy and reliability of the data, that it will be misused and that it will give the new Labour government a reason to depart from what was already proposed in the White Paper, and have a longer term adverse impact on gambling policy.

30 August 2024 – Introduction of new social responsibility code provision (“SRCP”) 3.4.4, which sets out requirements for light-touch financial vulnerability checks at an initial threshold of £500 a month. The pilot for financial risk assessments was also launched and is expected to run until April 2025.

30 August 2024 – Introduction of new age-verification requirements, under SRCP 3.2.1, 3.2.3(8), 3.2.5(7) and 3.2.7(9) of the LCCP. The requirements oblige all land-based gambling licensees to conduct test purchasing and change from “Think 21” to “Think 25”.

27 November 2024 – DCMS published its initial response to the Consultation on the structure, distribution and governance of the statutory levy on gambling operators. The initial response committed to having the levy in place by summer 2025, with 50% going to the NHS, 30% to gambling harm prevention, and 20% to develop bespoke research programmes on gambling.

29 November 2024 – New requirements under licence condition 1.2.1(2) of the LCCP introduced. The requirements extend the ‘specified management offices’ to include the Chair of the Board, money laundering compliance officer and money laundering reporting officer, and confirm that the individual responsible for the overall management and direction of the licensee’s business or affairs is likely to be the CEO, Managing Director or equivalent. Holders of specified management offices are required to hold a personal management licence (“PML”).

5 December 2024 – DCMS announced its Gambling Act Review evaluation plan. DCMS expect the evaluation to be reported in 2026.

17 January 2025 – The revised Remote gambling and software technical standards (RTS) came into force extending the requirements that apply to slots to other online products.

29 January 2025 – The Gambling Commission launched its January 2025 consultation which sets out proposed changes to the Gaming Machine Technical Standards, the Gaming Machine Testing Strategy, and the LCCP. The proposals relate to consolidating and updating the existing 12 gaming machine technical standards into a single standard, and introducing five new standards, a licence condition and social responsibility code provision in respect of safe use of gaming machines. The consultation closes on 20 May 2025 and is a serious cause for concern for the land-based industry. We would encourage clients to respond and provide evidence as to: the disproportionate cost of the proposals and the adverse impact upon business relative to any reduction of gambling harm, whether the proposals are even necessary given existing safer gambling measures in their venues, and the huge impact on the enjoyment of gaming machines by the overwhelming majority of consumers.

30 January 2025 – The Gambling Commission published its online slots stake limit guidance on the Statutory Instrument, which clarifies the stake limits and implementation dates, and provides example scenarios.

4 February 2025 – The Gambling Commission published its response to its Autumn 2023 consultation. Its response confirmed (a) new requirements for customer led tools to give consumers more effective ways to manage their gambling by making it easier to set and maintain deposit limits on their online accounts, (b) the requirement that operators whose customer funds are ‘not protected’ in the event of insolvency must actively remind customers once every six months that their funds are not protected, and (c) the removal of the requirement to make annual financial contributions to a list of research, prevention and treatment organisations to pave the way for the new statutory levy by 31 March 2025.

10 February 2025 – The Gambling Commission published an update on the financial risk assessment pilot, which outlined the findings from Stage 1 of the three-stage pilot, identified the issues relating to data quality and implementation, and explained what can be expected with Stages 2 and 3.

25 February 2025 –Statutory Instrument, The Gambling Act 2005 (Operating Licence Conditions) (Amendment) Regulations 2025, signed into law, adding a new licence condition to all remote casino operating licences which introduces a maximum stake limit for online slots games in Great Britain. The total amount which an individual may stake in relation to any game cycle may not exceed (a) £2, where the individual is less than 25 years old, and (b) £5, where the individual is 25 years old or over.

25 February 2025 –Statutory Instrument, The Levy Regulations, signed into law, requiring all operating licence holders in Great Britain to pay a mandated levy to the Gambling Commission. The Levy Regulations came into force on 6 April 2025.

28 February 2025 – The requirement set out in SRCP 3.4.4(7) of the LCCP for financial vulnerability checks at £500 a month reduced to £150 a month, as set out in SRCP 3.4.4(6).

6 March 2025 – The Gambling Commission launched a supplementary consultation setting out its proposals for clarifying the definition of financial limits in the Remote Gambling and Software Technical Standards, to ensure there is a differentiation between “deposit limits and “loss limits”. The consultation closed on 30 April 2025.

26 March 2025 – The Gambling Commission published a response to its Autumn 2023 consultation. Its response confirmed (a) a ban on operators offering mixed product promotional offers which provide bonuses on the condition the consumer plays different gambling products, such as betting and playing slots, (b) a requirement to cap the wagering requirement of promotional offers to 10, and (c) rewording SRCP 5.1.1 (Rewards and Bonuses) of the LCCP to ensure clarity of the Gambling Commission’s expectations of operators around socially responsible incentives. Requirements to come into force on 19 December 2025.

31 March 2025 – The removal of SRCP 3.1.1(2) of the LCCP requiring licensees to make annual financial contributions to a list of research, prevention and treatment organisations.

6 April 2025 – The Levy Regulations came into force. The first invoices will be issued on 1 September 2025, with payment required on or before 1 October 2025.

7 April 2025 –The Gambling Commission published its statutory levy guidance to accompany the Levy Regulations, including details of who will collect the levy, who must pay the levy, how the levy is calculated, when licensees need to pay, how to pay the levy, and the consequences of not paying the levy.

9 April 2025 – The Statutory Instrument adding a new licence condition to all remote casino operating licences which introduces a maximum stake limit for online slots games in Great Britain came into force.

What can we expect next?

Changes which will be implemented in 2025:

1 May 2025 – New direct marketing requirements come into force.
21 May 2025 – £2 stake limit for online slots for those aged 18-24 years old to come into force.
31 October 2025 – New customer led tools and requirements regarding the protection of customer funds in the event of insolvency, and further updates to RTS in relation to financial limits come into force.
19 December 2025 – New requirements for socially responsible incentives come into force.

Other areas which will likely progress in the next year at varying speeds:

Establishment of the Gambling Ombudsman.
The publication of the Gambling Commission’s response to its December 2023 Consultation, which closed on 15 March 2024, relating to the criteria for imposing a financial penalty and penalty calculation methodology, and changes to financial key event reporting.
Implementation of the new land-based measures as set out in DCMS’s consultation response of 16 May 2024.
Progress with the Criminal Justice Bill in Parliament and extension of the Gambling Commission’s powers to tackle illegal gambling.
DCMS’s consultation on Gambling Commission fees.

The second year of the White Paper saw a number of the proposals “ticked off” with their implementation having now taken place, or lined up to take place soon. The overwhelming list of proposals has shortened, and the gambling industry is now gradually transitioning to the post-White Paper era. We look forward to seeing where things stand by the time of the three-year anniversary.

Please sign up to our blog to receive insight and commentary on the continued journey of the White Paper.

10Mar

White Paper Series: Supplementary consultation published calling for views on deposit limits

10th March 2025 Harris Hagan 214

The Gambling Commission is calling for views on how to achieve consistency and clarity for consumers that choose to set deposit limits.

The supplementary consultation, published on 6 March 2025, calls for views from interested parties on new rules aimed at increasing consumer control over deposit limits, which will come into force on 31 October 2025 and which we discussed in our blog: White Paper Series: New rules on customer led tools, customer funds and statutory levy. In this new supplementary consultation, the Gambling Commission is seeking opinions on how deposit limits should be defined and communicated to customers, with the aim of achieving consistency and clarity across the industry.

This is the fourth Gambling Commission consultation linked to the White Paper.

Why is a supplementary consultation needed?

The Gambling Commission acknowledges that typically, ‘deposit limits’ have worked as a simple limit on the amount a customer can deposit over a specific time period (for example, if a customer chooses to set a £20 weekly deposit limit, they can deposit a maximum of £20 into their account in that week). However, they have recently observed some operators offering ‘net deposit limits’, whereby withdrawals are also taken into account.

“For example, if a customer chooses to set a £20 weekly deposit limit but then withdraws £10 then the total amount they can deposit that week goes up to £30. This can be confusing for customers, especially if the descriptions for the different types of limit are similar.”

The Gambling Commission considers that financial limits termed ‘net’ deposit limits would not meet the definition of ‘deposit limits’ proposed in its initial consultation. It is concerned that the introduction of ‘net’ deposit limits has created inconsistency in how deposit limits work, which prevents the customer being able to make a proactive and informed choice as to what financial limits are right for them – limiting consumer empowerment and choice.

To ensure clarity, rather than implement the initial consultation and ‘pursue this as a compliance matter’, the Gambling Commission has chosen to consult further on this issue. The supplementary consultation therefore sets out proposals to:

revise the remote gambling and software technical standards (”RTS”) relating to financial limits to make clear that, as a minimum and default, ‘gross’ deposit limits must be offered to customers;
ensure that the term ‘deposit limit’ is used consistently by operators, i.e. only to describe ‘gross’ and not ‘net’ limits;
provide increased consumer choice by amending the implementation guidance for the RTS to allow for ‘net’ limits to be set in addition to other types of limits, should the customer choose.

The Gambling Commission’s view is that offering a default type of deposit limit across all operators will be beneficial for consumers in terms of improving understanding of how limits work and would enable consumers to use the same type of limit across more than one account.

Next steps

The supplementary consultation is open until 30 April 2025.

The changes on customer led tools and the protection of customer funds will come into force on 31 October 2025.

Please get in touch with us if you would like our assistance preparing a response to the supplementary consultation or if you have any questions about these upcoming changes.

UK Gambling Law