UK Gambling Laws 2026: Complete Player
The industry argued this would prevent a scenario in which two casino venues of different sizes, located close to each other, could have vastly different gaming machines allowances. The ratio of machines to tables in 2005 Act Small casinos has forced operators to provide redundant tables which, alongside the locations to which the licences were allocated in 2007, has contributed to making them commercially unattractive for development. We received a cross-industry submission from the Cashless Group, made up of casino, adult gaming centre and bingo sector operators and trade bodies, in response to Question 40 on harms and benefits of cashless gambling. A central premise of the Gambling Act 2005 was to regulate gambling and manage gambling-related risks through controls which included restricting the number and location of gambling products, in particular gaming machines.
Betting in 1968 Act casinos
The financial regulation of gambling is set out mostly in the British Finance Acts and provides for various levels of duty upon different types of gambling. Not regarded as gambling where the element of chance is no more than de minimis. Free-to-enter draws and betting competitions may be exempt if they meet conditions for free draws or prize competitions.
The Social Market Foundation reported that research by Morgan Stanley estimated that a flat £2 stake limit for all non-slot casino products would reduce GGY from those products in the licensed sector by 92%. Furthermore, stake size can have a more direct functional role in non-slot gameplay compared to slots, for instance in roulette where a higher stakes bet can be divided between different areas, modifying the rate of return to the player and the risk of losses. On that basis, we will also consult on measures to give greater protections for 18 to 24-year-olds who the evidence suggests may be a particularly vulnerable cohort. However, taking an equitable approach to product regulation should take account of the wider system of protections in place online. Given wider forthcoming changes to the account-based protections considered above, we do not consider that such customer segmentation is yet a sufficiently established safeguard to control access to higher stakes. Operators which heavily weight their risk score by stake size were deliberately excluded from the analysis to avoid giving a false impression of a positive linear correlation.
Therefore, when Parliamentary time allows, we plan to give the Gambling Commission increased powers to support disruption and enforcement activity, such as to pursue court orders which require internet service and payment providers to take down or block access to illegal gambling sites. It is also intended that more regulatory data, suitably anonymised, will be made available in due course to support independent research. We also welcome the commitment from governing bodies across the sport sector to develop a cross-sport gambling sponsorship code, with rules to make sure all sponsorship deals are socially responsible. This should reduce children’s incidental exposure to gambling logos while watching football and particularly via products such as stickers and video games, as well as the direct association with star players. Advertising rules have changed to prohibit prominent sportspeople, in particular Premier League footballers, from appearing in gambling adverts, on the grounds of their strong appeal to children.
Electronic terminals in casinos
The Gambling Commission raised concerns that arcade and bingo venues have sought to maximise their number of Category B machines under the current rules by providing Category C and D gaming on tablets and in-fill machines. As outlined in the white paper, we strongly encourage operators to continue to improve player safety controls on Category B3 machines. In addition, we noted that some player safety improvements have been made to modern Category B3 machines which cannot easily be replicated on older machines, and that customers can and do play at lower stakes than the maximum on Category B3 machines. As above, 1968 Act casinos will retain the option of continuing to operate under the existing regime should they not wish to increase their machine allocations. Premises licence fees are collected by licensing authorities for applications and annual renewals to cover the cost of administration of their gambling duties and gambling enforcement. Currently, annual fees for 1968 Act casinos are between 65% and 90% of the annual fees that 2005 Act casinos in the equivalent fee category are required to pay.
- Where processing of special category data or criminal offence data is required for the purposes of compliance with their licence obligations, licensees will wish to identify a legal basis which allows such processing.
- Licensed bingo premises include a range of establishments such as retail bingo clubs, high street arcades (which have a smaller bingo offer via bingo machines), and bingo venues in holiday parks.
- Remote licences are, in fact, a legal requirement for any business, wherever located, to offer facilities for gambling to British residents.
Without greater control for consumers, the negative impacts range from nuisance to casual players to exacerbating harm for those struggling with their gambling, who feel ‘bombarded’ by calls to action from operators. Considering the inherent risks of gambling, we believe there is a case to ensure that operators present bonuses in the most transparent language possible. Responses to our call for evidence which called for restrictions on bonuses were chiefly concerned by the risks posed by online bonusing and schemes. For high-end casinos, rewards can take the form of personal concierge services, including dinners, hospitality and events. To prevent individuals showing strong indicators of harm from being encouraged to gamble, the Gambling Commission recently published new requirements on customer interaction which require operators to prevent these customers from receiving any direct marketing or taking up new bonus offers. Measures to drive future research, including greater use of industry data, are outlined at Section 3.5.
Most major consumer banks offer opt-in gambling blocking tools which prevent card payments to gambling firms based on their merchant category code. Similar conclusions were drawn in a separate review, looking holistically at gambling policy and the evidence base around gambling harm reduction strategies. Online operators must already provide customers with limit setting tools, so using these to better effect can be a low cost and scalable intervention to help prevent harm from occurring. Similarly to seatbelts, normalising the use of deposit limits, activity statements or other tools should leave those gambling within their chosen budget unaffected while mitigating the risk of harm in cases where people have lost track or control. Platform design has also been identified as a relevant factor and a recent audit of popular online operators found promotional offers were sometimes advertised alongside the gambling management webpage. However, a number of treatment providers, charities and individuals with personal experience of gambling harms emphasised in their evidence that there are limits to the role that measures reliant on personal responsibility can play in tackling harm for those suffering from a gambling addiction.
The UK gambling industry requires strict licenses to ensure a safe and secure gaming environment. Age verification standards now extend beyond remote gambling to land-based premises. Operators must obtain separate permissions for each product category (e.g., casino, sports betting, bingo) and communication channel (e.g., email, SMS, phone). Clients trust Wiggin to navigate a broad range of legal matters, including obtaining and maintaining licences, international expansion, business acquisitions and sales, intellectual property protection, data security, dispute resolution and regulatory compliance.
The exemption for these casinos will apply from 16 May 2024 (the date on which the consultation response was published) and take account of any already submitted expansion plans. The government proposes that venues will be required to comply with all specified sliding scale requirements in order to access the enhanced gaming machine entitlement. When asked about the proposed minimum gambling area, table gaming area and non-gambling area requirements, the table gaming element received one-third less support than the other 2 requirements.
The number of gaming machines a casino may host depends on its classification. Under Section 20 of the Gambling Act 2005, the Commission replaced the Gaming Board for Great Britain and now has jurisdiction over arcades, betting, bingo, casinos, slot machines, and lotteries. It allowed larger casino establishments to operate with more gaming machines and granted patrons easier access. Benefits to business non gamstop sites are increased gross gambling yield for casinos and unquantified benefits to gaming machine suppliers and manufacturers. The Commission has become aware that in some instances, operators who hold a combined non-remote casino licence and betting operating licence, have looked into converting part of their casino premises to betting premises. In Scotland the licensing boards are licensing authorities and continue to have responsibilities for granting permissions for casinos in the form of premises licences.
Player protection checks
Evidence we have received indicates that there could be serious financial impacts, particularly for sports and leagues outside the Premier League, including at grassroots level, if gambling sponsorship were removed without an alternative source of funding in place. As gambling operators are held responsible for their affiliates and third parties they were in clear breach of CAP’s rules and Licence Conditions and/or Codes of Practice imposed by the Gambling Commission, with West Ham’s sponsor Betway incurring a £400,000 penalty as a result. As with advertising more broadly, it appears that while sponsorship is rarely the factor causing the development of harmful gambling, it can still exacerbate impacts for those who are already suffering harms. This is also reflected in polling commissioned by a major operator, which found that only around 20% of past-month gamblers would view a gambling sponsor for their team negatively, and that they were perceived slightly more positively than other possible partners, such as airlines or lager brands. In addition, research by Steve Sharman and others looking at matchday programmes in English football found that the industry of the sponsor was a significant factor in the proportion of pages containing adverts. It did not find any correlation between exposure to gambling sponsorship and participation in 11 to 18-year-olds, or significantly higher levels of betting participation from fans of a club or league with betting sponsorship.
To support our consideration of this issue, the Gambling Commission issued a data request to industry in April 2021 to understand real world play with online slots. Where industry respondents recognised that stake limits could help reduce harm, some argued these should be a tailored intervention, based on an individual’s circumstances, while others reported having already implemented universal limits. One operator pointed out that 41% of its customers that were flagged by its algorithm as at higher risk of suffering harm had an average slots stake of less than £0.25. Given this evidence of particular risk, there was significant discussion in responses to our call for evidence on the case for a stake limit on online slots.
The more recent data from the Gambling Commission’s quarterly telephone surveys suggests that in the year to December 2022, 44% of surveyed adults had taken part in at least one gambling activity in the previous four weeks (29% excluding those who only played the National Lottery). As well as commissioning analyses of Health Survey data and a wider programme of research, the Commission conducts a quarterly telephone survey on participation and prevalence to track trends, but this is less robust than the full Health Surveys. In addition, the Gambling Commission collects regular data on the extent and impact of gambling in Great Britain. Each nation in Great Britain conducts its own annual Health Survey to gather authoritative data on physical and mental health, and these periodically include gambling questions.
How much funding do you estimate is needed for administration and the enforcement of licences annually? If you are a local authority/ licensing board, do you currently charge the maximum fees as set out in the Gambling Act 2005? However, given the relatively low level of annual fees per premises at present, we consider this to be unlikely.
Following the publication of the independent Football Index report, we also committed to looking at whether gambling companies should do more to demonstrate their ability to cover liabilities arising from long term bets, especially if they make up a large proportion of their business. These changes provide greater clarity to applicants that gambling products that could be mistaken for an investment are unlikely to be licensed by the Commission. In response to the recommendations, the Gambling Commission has updated its framework for how it assesses risk so that product novelty is fully considered. Both regulators have taken a number of steps to address points identified in the review, including agreeing to a strengthened Memorandum of Understanding which includes new escalation routes to make sure regulatory impasses and overlaps are identified and quickly overcome. The review set out a range of recommendations for the Gambling Commission and the FCA, including on how they worked together. The review provided a detailed and objective account of the regulatory circumstances around the granting of a licence to BetIndex Ltd, its subsequent suspension and the company’s ultimate financial failure.
We believe these to be of a smaller magnitude than the effects considered above, and expect forthcoming policy-specific consultations will broaden the evidence base to support detailed impact assessment. We recognise that our proposals also involve additional friction and/or reduced incentivisation for some people who are spending at high levels which they can afford and who are not being harmed. As part of the consultation, we will strongly encourage licensing authorities to consider the range of resources required for comprehensive monitoring and enforcement, such as IT and analytical capability, which may not have been a necessary or proportionate requirement when the fees were originally set.
In the meantime, the Betting and Gaming Council (BGC) has provided us with an informal evaluation of some of the measures which were voluntarily adopted by most operators in September 2020. While we cannot preempt the outcomes of the Gambling Commission’s review, strengthening the verification procedures for gambling accounts (for instance by matching payment information) should bring benefits for all parties. For instance, we welcome the steps taken by some operators to introduce enhanced security measures, such as multi-factor authentication. With new payment regulations now in force, the Commission can reassess this issue and determine whether new requirements for licensees might be justified to address the risks identified above. SCA has now come fully into force, so card-based e-commerce transactions that are non-compliant should now be declined.
Gaming machines must also have suitable characteristics to mitigate against the risk of gambling-related harm, and these characteristics will be in place for any additional gaming machines. In this instance, a casino with 3 premises licences could theoretically site a maximum of 240 gaming machines, which would not be the policy intention. The introduction of direct forms of cashless payments on gaming machines, subject to suitable safeguards, therefore represents an opportunity to future-proof the land-based gambling industry. These changes would only come into effect if 1968 Act casinos elect to make more than 20 gaming machines (including at least one Category B machine) available to the customer.
We think that behavioural science provides valuable insights around how the design of platforms and processes can be improved to better empower consumers and reduce the risk of harm. The ICO stressed the importance of licensed operators upholding the information rights of data subjects. Gamblers commonly resort to self-exclusion as a way to close a gambling account, with evidence suggesting this as a motivating factor for 37% of self-exclusions. Stakeholders also had concerns that there is rarely a simple way to close an online gambling account without speaking to a customer service representative. There are no specific provisions relating to how information is presented on screen, but where a product carries an underlying risk of harm, it is in the best interests of the consumer that material information is as easy as possible to access and understand. Licensed operators should be transparent with customers, both at the start of the relationship and throughout, about how, when and why an account might be restricted, and ensure customers are aware of any restrictions prior to placing a bet.
Firstly, it would split family groups, requiring adults who wish to play these machines to leave the group playing on non-gambling products. For example, Bacta commented that ‘cash-out’ Category D slot-style machines are substantially different from harder gambling slot machines, and are better described as fruit machines or amusement with prizes machines. These responses highlighted the low-risk nature of these machines. Concerns were also expressed that the exposure of these machines to children may normalise gambling behaviour. However, we will not mandate that these machines be moved into age-restricted areas as we do not believe that it is proportionate, considering the lower risk posed by these types of machines.
The Commission’s ambitious change to its enforcement approach, coupled with amendments to its investigatory powers, will ensure that it is in a strong position to be able to monitor the industry and take action against operators who fail to meet the required standards. There are currently no products which are regulated both by the Commission and FCA but two operators are separately regulated by both organisations because they offer both spread betting and fixed odds betting products. Due to a range of factors, including the impact of COVID-19 and the suspension of football in March 2020, Football Index collapsed in March 2021 and its licence was suspended.
We will work with the relevant trade bodies and operators to understand the feasibility of this proposal and the frequency of any reporting to DCMS. We also propose that industry fund, conduct, and, crucially, report on the outcomes of voluntary test purchasing to DCMS. In addition, operating costs have risen significantly over this period, especially as a result of rising energy costs, which have increased by over 225% for some operators. This is in addition to improvements in monitoring and staff supervision of customers. The characteristics of land-based products have substantially improved since the introduction of the Gambling Act 2005.
