Gaming Law 2025 Comparisons

The White Paper and Recent Changes

In April 2023, the government published its long-awaited White Paper, “High Stakes: Gambling Reform for the Digital Age” (the “White Paper”). The highly anticipated White Paper formed part of the review of the Gambling Act 2005 that was launched by the UK government in December 2020 and designed to “protect vulnerable users in [a] smartphone era” by striking a better balance between consumer freedoms and the protection of the vulnerable.

The White Paper detailed more than 60 proposals. Since publication, significant progress has been made with a number of White Paper proposals coming into effect through a combination of primary and secondary legislation, changes to the Licence Conditions and Codes of Practice (LCCP), and voluntary commitments.

Key changes that have been implemented further to the White Paper include the following.

• Statutory levy – a new mandatory statutory levy has been introduced to fund research, education, and treatment of gambling harms, replacing the current voluntary system. The Gambling Levy Regulations 2005 were signed into law in February 2025 and came into effect on 6 April 2025. The levy is calculated at a set rate ranging from 0.1% to 1.1% (depending on licensed product) based on the amount reported in a licensee’s regulatory returns within the previous 12-month period beginning on April 1st annually. The first invoices were issued on 1 September 2025 with payment due before October 1st each year.   
• Financial vulnerability checks – following the Gambling Commission’s consultation response of 1 May 2024, financial vulnerability checks must be conducted on customers pursuant to a new social responsibility code provision (SRCP) 3.4.4, which came into effect on 30 August 2024. From 28 February 2025, remote licensees are required to undertake checks on customers with a net deposit of GPB150 a month. Financial vulnerability checks require licensees to check public record information for significant indicators of potential financial vulnerability. The checks can be frictionless, but must include whether the customer is subject to a bankruptcy order, a county court judgment, or an individual voluntary agreement (or similar); proportionate action must be taken by the licensee based on the result.
• Online game design rules – amendments to the Remote Gambling and Software Technical Standards (“the RTS”) were implemented on 17 January 2025. The changes extended requirements that already applied to slots to other online products. Notably, this includes a ban on speed features such as “turbos” or “slam stops”, a ban on game cycles of less than five seconds on casino products, the prohibition of autoplay functions, a ban on celebrations of returns less than or equal to the stake, and a ban on the facilitation of playing multiple simultaneous products. Further updates were made to the RTS on 31 October 2025, requiring operators to prompt their customers to set a financial limit on their accounts.
• Direct marketing – a new social responsibility code provision came into force on 1 May 2025, requiring online gambling businesses to provide customers with options to opt in to the product type they are interested in, as well as the channels through which they wish to receive marketing.
• Land-based reforms – following the UK government’s consultation response on 16 May 2024, a series of statutory instruments came into effect on 22 July 2025 permitting casino premises licences originally issued under the Gaming Act 1968 to access new entitlements. Entitlements include increased gaming machine entitlements of up to 80 machines on a sliding scale (if certain conditions are met) and offering sports betting. The UK government opened a consultation on 15 October 2025 in respect of the categorisations of Category D gaming machines and proposing an age limit on “cash out” slot-style Category D gaming machines. At the time of writing, the consultation is open and is due to close on 9 January 2026.
• Online stake limits – the Gambling Act 2005 (Operating Licence Conditions) (Amendment) Regulations 2025 were signed into law on 25 February 2025, introducing online slots stake limits for remote operators. On 9 April 2025, the online slots stake limits were introduced at GBP5 per spin for those aged 25 years and above, and a GBP2 limit per spin for those aged under 25 was introduced on the 21 May 2025.
• Calculation of financial penalties – following the Gambling Commission’s response to its 2023 consultation, on 10 October 2025, its Statement of Principles for Determining Financial Penalties was updated to bring greater clarity and transparency to how the Gambling Commission calculates financial penalties.

Upcoming changes emanating from the White Paper

At the time of writing (November 2025), the following changes are scheduled.

• Bonus and wagering requirements – from 19 January 2026, changes will be made to SRCP 5.1.1, which will ban licensees from offering incentives that include more than one type of gambling product. Licensees will also be required to cap wagering requirements of bonus funds to a maximum of ten times.
• Deposit limits – following its response to a supplementary consultation on deposit limits, the Gambling Commission has confirmed further changes to the RTS to clarify the definition of “deposit limits” and other financial limits that can be set by customers. The changes are due to take effect on 30 June 2026.

Awaited changes

Several proposals were made in the White Paper that are still awaiting progress. These include the following.

• Gambling ombudsman – the creation of a non-statutory gambling ombudsman to handle social responsibility complaints from consumers. The UK government’s clear expectation was that this body would be industry-led and accepting complaints by summer 2024. This was not achieved and, at the time of writing, the position of the new government is unclear.
• Gambling Commission fees – at the time of writing, the UK government’s consultation on the Gambling Commission’s fees is awaited. This is expected during 2026, along with an increase in fees.
• Financial key event reporting – at the time of writing, the Gambling Commission’s outstanding response to its December 2023 consultation is awaited. The consultation related to proposed changes to financial key event reporting (in particular, to raise the current 3% reporting threshold to 5% in line with requirements of other regulators and jurisdictions). The Gambling Commission’s response is expected to be published before the end of 2025.
• Financial risk assessments – the Gambling Commission conducted a three-stage pilot to establish how financial risk assessments will work in practice and assess appropriate thresholds. At the time of writing, the outcome of the Gambling Commission’s pilot is awaited.

AML

In the past year, changes have been made to AML legislation impacting the AML/CFT obligations of licensees. The Proceeds of Crime Act 2002 (POCA) was updated in July 2025 by separate legislation to increase the threshold amount for submitting a defence against money laundering to GBP3,000.

In April 2025 and October 2025, the Gambling Commission published emerging risk updates, identifying emerging money laundering and terrorist financing risks in the gambling industry. The risks identified include:

• risks associated with pre-paid payment methods;
• the use of AI to bypass customer due diligence;
• money being exchanged for personal details and gambling accounts;
• licensed software providers’ games being available on websites not licensed by the Gambling Commission;
• crypto-assets;
• changes to customer demographics in the non-remote sector;
• terminals being used to facilitate customer deposits into non-remote casinos;
• increased availability of crash games; and
• use of application registration cards as a form of identity documentation.

The emerging risks are expected to be considered by operators when conducting their money laundering, terrorist and proliferation financing risk assessments. In July 2025, HM Treasury published an updated National Risk Assessment, which – notably – increased the money laundering risk of casinos from “low” to “medium”.

In October 2025, the Gambling Commission updated its casino AML guidance to include changes to The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and changes to POCA, as well as the Gambling Commission’s expectation that operators must give due consideration to money-laundering risks posed by their business-to-business relationships.

Tax

The Labour government’s budget announced on 30 October 2024 did not increase UK gambling taxes. However, the government plans to reform, consolidate and simplify the current structure for remote gambling. At the time of writing, it is expected that the Labour government’s Autumn Budget (to be delivered on 26 November 2025) will increase UK gambling taxes.

Personal  Accountability of Management

On 29 November 2024, Licence Condition 1.2.1 of the LCCP was amended to clarify and increase personal management licence (PML) coverage. The changes include:

• adding wording to state that the individual who holds responsibility for the overall management and direction of the licensee’s business is likely the CEO, managing director, or equivalent;
• the chairperson of the board (where applicable) must hold a PML; and
• the person responsible for the licensee’s AML/CFT function as head of that department must hold a PML.

The following online sectors are regulated in Great Britain:

• betting (live, in-play, fixed-odds and pari-mutuel, betting exchanges, and intermediaries);
• bingo;
• casino;
• fantasy sports;
• gaming machines;
• gambling software;
• lotteries; and
• poker.

Free-to-play social gaming is not regulated. The Gambling Commission concluded, following a scoping review in 2015, that the sector did not require regulation but would continue to be monitored by the Gambling Commission for any potential risks.

Please refer to 2.2 Land-Based Gambling for product definitions.

The following land-based sectors are regulated in Great Britain.

• Arcades – for arcades, each arcade category can offer a specific subcategory of gaming machine. Those under 18 years of age may not be allowed access to the adult-only section of a licensed family entertainment centre or an adult gaming centre. Arcades can be divided into three categories:
1. adult gaming centres;
2. licensed family entertainment centres; and
3. unlicensed family entertainment centres.
• Betting (live, in-play, fixed-odds and pari-mutuel, betting exchanges, and intermediaries) – see 3.2 Definition of Gambling for a definition of betting.
• Bingo – this is not defined in UK legislation; however, the Gambling Commission has published guidance stating that bingo constitutes “equal chance” gaming. For further guidance, please refer to the Gambling Commission’s website.
• Casino – this constitutes arrangements providing people an opportunity to participate in one or more casino games. “Casino game” means a game of chance that is not equal-chance gaming.
• Fantasy sports – this is not defined in the 2005 Act, but the Gambling Commission has issued guidance on its website regarding this product.
• Gaming machine – this means a machine that is designed or adapted for use by individuals to gamble (whether or not it can also be used for other purposes).
• Gambling software – this is defined as computer software used in connection with online gambling, which does not include software used solely in connection with a gaming machine. Given the complexity of this term, the Gambling Commission issued an advice note in June 2014 on what constitutes gambling software.
• Lotteries (raffles), excluding commercial lotteries – please refer to 3.2 Definition of Gambling for a definition of lotteries.
• Poker – in spite of the skill element, the chance element that the deal of a card introduces means that poker falls within the definition of gaming. Please refer to 3.2 Definition of Gambling for a definition of gaming.

The key legislation applicable to the gambling sector is as follows:

• the Gambling Act 2005;
• the Gambling (Licensing and Advertising) Act 2014;
• the National Lottery Act of 1993 (as amended by the National Lottery Act of 2006);
• the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017;
• the Fifth Anti-Money Laundering Directive;
• POCA (Part 7); and
• the Terrorism Act 2000 (“TACT”).

The Gambling Act 2005 is set out as follows:

• Part 1 interprets key concepts and contains definitions of important terms;
• Part 2 establishes the Gambling Commission’s powers and duties;
• Part 3 deals with offences;
• Part 4 addresses the protection of children and young persons; and
• Parts 5, 6, 7 and 8 deal with various types of licences.

The LCCP is issued under Section 24 of the Gambling Act 2005 and is, in the authors’ opinion, the key reference document with which all licence holders should familiarise themselves.

Gambling, per the Gambling Act 2005, means gaming, betting or participating in a lottery.

Gaming means “playing a game of chance for a prize”, including games where the chance element can be eliminated by superlative skill. “Prize” constitutes money or money’s worth and “playing” means a chance of winning, irrespective of whether there is a risk of any loss.

Betting means the making of, or acceptance of, bets on:

• the outcome of an event;
• the likelihood of anything occurring or not; or
• whether anything is true or not.

Subcategories of betting include:

• real-event betting (ie, fixed-odds betting);
• virtual-event betting (based on a random number generator);
• betting intermediary (peer-to-peer); and
• pool betting.

Lotteries are classed as “simple” or “complex” and they cannot be run for private or commercial gain. Lotteries are “simple” if:

• payment is required to participate;
• one or more prizes are allocated to one or more members of a class; and
• the allocation of prizes relies wholly on chance.

Complex lotteries differ on the point of prize allocation, whereby prizes are allocated by a series of processes – the first of which relies wholly on chance.

Subcategories of lotteries include:

• society lotteries (small and large);
• local authority lotteries;
• incidental lotteries;
• private lotteries;
• customer lotteries; and
• the National Lottery (subject to separate legislation).

The Gambling Act 2005 also addresses the following cross-category activities in the event that products satisfy more than one of the above-mentioned definitions of gambling:

• betting and gaming;
• lotteries and gaming; and
• lotteries and betting.

Land-based gambling is not specifically defined under the Gambling Act 2005.

Online gambling is referred to as “remote gambling” and means “gambling in which persons participate by the use of remote communication”. Remote communication includes:

• the internet;
• telephone;
• television;
• radio; or
• any other kind of electronic or other technology for facilitating communication.

Part 3 of the Gambling Act 2005 covers all offences; however, one of the key offences is providing facilities for gambling (Section 33 of the Gambling Act 2005, Section 33):

1. without authorisation from the Gambling Commission, whether through a licence or acting in the course of another’s business who holds a licence; or
2. in a manner not in accordance with the terms and conditions of any licence held either by the licence holder or in the course of another’s business who holds such licence.

“Providing facilities for gambling” occurs where a person either:

• invites others to gamble in accordance with arrangements made by them;
• provides, operates or administers arrangements for gambling by others; or
• participates in the operation or administration of gambling by others.

Other key offences of note include:

• inviting, causing or permitting a child (under the age of 16) or young person (not a child, but under the age of 18) to gamble (Section 46 of the Gambling Act 2005);
• manufacturing, supplying, installing or adapting gambling software, in the course of business, without an operating licence while physically located in the UK (Section 41 of the Gambling Act 2005); and
• cheating at gambling or doing anything to enable or assist another person to cheat at gambling (Section 42 of the Gambling Act 2005).

As part of its focus on tackling unlicensed gambling, the Gambling Commission will be given new powers to disrupt illegal gambling. For further details, please see 9.5 Sanctions/Penalties for advertising sanctions and penalties and the UK Trends and Developments chapter.

The penalties for the key offences listed in 3.5 Key Offences and 9.5 Sanctions/Penalties are a maximum of 51 weeks’ imprisonment and/or an unlimited fine.

The Gambling Commission and various licensing authorities enforce the Gambling Act 2005. Under Part 2 of the Gambling Act 2005, the Gambling Commission’s primary functions include:

• issuing operating licences;
• issuing personal licences;
• specifying general licence conditions for each type of licence and any individual licence conditions that it considers appropriate;
• issuing codes of practice concerning the way in which facilities for gambling are to be provided;
• regulating licence holders;
• investigating and prosecuting illegal gambling and other offences under the Gambling Act 2005;
• issuing guidance to local authorities on their role; and
• advising the Secretary of State on the incidence of gambling, how it is carried out, its effects and its regulation.

The Advertising Standards Authority (ASA) regulates gambling advertising in the UK. For further details, see 11. Enforcement.

The Gambling Commission’s approach to regulation is risk-based, with the aim of continuing to raise standards. The Gambling Commission indicated in its three-year corporate strategy for 2024–27 that its five strategic focus areas are:

• using data and analytics to make gambling regulation more effective;
• enhancing its core operational functions;
• setting clear, evidence-based requirements for licensees;
• being proactive and addressing issues at the earliest opportunity; and
• regulating a successful National Lottery.

The types of licences are:

• generally, for companies – operating licences and, if applicable, premises licences; and
• for individuals – personal licences (see 4.10 Personal Licensing).

Generally, the operating licence types are:

• non-remote for land-based activities (these will require an accompanying premises licence, as detailed later in this section); or
• remote for online activities.

The Gambling Act 2005 enables the Gambling Commission to authorise all regulated land-based and online activities outlined in 2.1 OnlineGambling and 2.2 Land-Based Gambling, including gambling software. Licences authorising multiple licensable activities (for instance, bingo and casino) are classed as a “combined operating licence”. Subject to exceptions, licences are also amenable to “umbrella” arrangements for those acting in the course of another’s business. “Umbrella” arrangements are approved at the Gambling Commission’s discretion following a review of various factors, including:

• consolidation of company accounts;
• ownership structure;
• responsibility for compliance; and
• governance arrangements.

See also 6. Online Gambling.

Premises Licences

Premises licences – issued by the relevant licensing authority (not the Gambling Commission) – are available, authorising the following activities:

• casinos;
• bingo;
• an adult gaming centre for making Category B gaming machines available for use;
• a family entertainment centre, for Category C gaming machines; and
• betting.

See 5.1 Premises Licensing for requirements.

Operating licences and personal licences are readily available, subject to the fulfilment of application criteria and the payment of the application fee.

Land-based casino premises licences are subcategorised into “small”, “large”, “converted” and “extended converted”. Converted casino premises licences were awarded under the repealed Gaming Act 1968. They may be moved to alternative premises within the same licensing authority area, but there are no new licences available. Extended converted casinos premises licences apply to converted casinos that have exercised their rights to extended entitlements set out in Schedule 4 of the Gambling Act 2005 (Commencement No 6 and Transitional Provisions) Order 2006 (amended by the Gambling Act 2005 (Commencement No 6 and Transitional Provisions) (Amendment) Order 2025). Sixteen “small” and “large” casino premises licences were issued under the Gambling Act 2005 and awarded by the relevant licensing authority area following a public competition. To date, four of the large casino premises licences have been awarded, with one casino since closing. The White Paper proposes to reallocate any unused Gambling Act 2005 casino premises licences to other local authority areas (see 4.3 Types of Licences (Premises Licences)).

Pursuant to Section 110 of the Gambling Act 2005, operating licences are indefinite in duration, subject to the payment of annual fees and compliance with licence terms and conditions.

Key Application Requirements for Operators

Operating licence applications must be submitted to the Gambling Commission, which will conduct an extensive investigation (having regard to the licensing objectives) in order to determine the applicant’s suitability to carry out the licensed activities. The Gambling Commission broadly uses the following principles of suitability to assess any application:

• identity and ownership;
• finances;
• integrity;
• competence; and
• criminality.

Section 69(2) of the Gambling Act 2005 requires that operating licence applications:

• specify the activities to be authorised by the licence;
• specify a UK correspondence address;
• be made in the form and manner decided by the Gambling Commission (applications must now be made via the Gambling Commission’s online system);
• disclose any relevant offences;
• include documents and information requested by the Gambling Commission; and
• be accompanied by the prescribed fee.

Currently, there are no server location or data storage obligations.

Furthermore, the Gambling Commission introduced a strict policy in April 2018 to reject incomplete applications.

Key Differences Between Application Requirements for Land-Based and Online Operators

Land-based casinos are generally considered to be a high-impact activity in terms of the Gambling Commission’s work, which means that applications may attract a high level of scrutiny and interest. In addition, non-remote casino operating licence applications must be accompanied by a casino premises licence application, which must be submitted to the licensing authority of the area in which the premises are situated.

Subject to full information being provided, Gambling Commission guidance indicates that operating licence applications take approximately 16 weeks to process – although the Gambling Commission acknowledges on its website that applications may take longer. These timescales may be affected by the quality and complexity of the application, suitability of the applicant or those relevant to the application, demand and caseworker availability, links to other applications, and links to any existing licence reviews.

In 2024–25, 156 new operating licence applications were submitted and 75% were processed within 16 weeks.

Application fees for operating licences are determined by the types of activities and financial projections for the first year. These can be calculated using the Gambling Commission’s online fees calculator. As announced in the White Paper, fees are expected to increase. At the time of writing (November 2025), a consultation is awaited and likely to take place in 2026.

Annual fees are determined in the same way as application fees (outlined in 4.8 Application Fees). Annual fees may be found on the Gambling Commission’s website or may be calculated using the online fees calculator.

Types of Authorisations and Licences

Personal Licences

Personal licences are issued by the Gambling Commission under Section 80 and Part 6 of the Gambling Act 2005 and governed by Part 3 of the LCCP. They allow the Gambling Commission to regulate individuals occupying specific roles and/or responsible for certain activities, and to hold them to account for failings, including any inadvertent or deliberate breaches of the LCCP committed by a gambling business.

The two types of personal licences are:

• a personal management licence (PML); and
• a personal functional licence (PFL).

At the time of writing, the LCCP requires persons with responsibility for any of the following specified management offices – as listed in Licence Condition 1.2.1 of the LCCP – to hold a PML:

• overall strategy and delivery of gambling operations (this is likely to be the CEO, managing director or equivalent);
• chairperson of the board (where the licensee has such a body), unless that person only holds the position on a transient and short-term basis;
• financial planning, control and budgeting;
• marketing and commercial development;
• regulatory compliance;
• gambling-related IT provision and security;
• the AML/CFT function, as head of that department;
• oversight of the day-to-day management of licensed activities at a number of premises licensed under Part 8 of the Gambling Act 2005 or across an identified geographical area; and
• for casino and bingo licences only, oversight of the day-to-day management of a single set of premises licensed under Part 8 of the Gambling Act 2005.

The Gambling Commission will also assess, on a case-by-case basis, whether CEOs and directors of “parent companies or subsidiaries in the group” need to hold PMLs.

Key individuals for small-scale operators (SSOs) may be exempt from this requirement to hold a PML and instead may continue to apply to hold an Annex A authorisation.

Individuals working in a casino who perform any function that enables to influence the outcome of gambling, or who are handling cash (eg, croupiers, dealers and cashiers), must hold a PFL. Under Section 133 of the Gambling Act 2005, personal licences may not be issued to individuals who already hold such a licence, but may authorise the performance of more than one function.

Annex A authorisation

Annex As are a type of Gambling Commission approval or authorisation. Individuals who are in management positions at SSOs, or who are representatives taking bets on behalf of an operator at the tracks, or who are controllers (generally, with 10% or more equity and/or voting rights in an existing or proposed licensee or in its parent company) must apply for an Annex A authorisation from the Gambling Commission. Subject to the Gambling Commission’s discretion, operators meeting the SSO exemption may hold Annex As instead of PMLs.

Application Process

Personal licence and Annex A applications must be submitted to the Gambling Commission, which will assess the application according to the same suitability criteria as for operating licences.

The requirements for personal licence applications and Annex A applications are broadly the same, but the specific requirements may vary depending on the particular circumstances. Generally speaking, applications require:

• identity documentation;
• address history;
• employment history and training information;
• a police report;
• a credit report; and
• statement of assets and liabilities (depending on the circumstances of the application).

At the time of writing, application fees for personal licences are GBP370. There is no application cost for Annex A applications.

The Gambling Commission’s standard service time for processing personal applications is eight weeks. In 2024–25, 3,491 personal licence applications were submitted, and 95% were processed within eight weeks.

Ongoing Annual Fees

Personal licences are subject to mandatory maintenance every five years by providing updated personal information and paying a fee of GBP370. Failure to maintain the licence will result in revocation.

There are no ongoing fees for Annex As.

Ongoing Requirements

General conditions for licences, as stipulated by Section 75 of the Gambling Act 2005, are listed under Part 3 of the LCCP. Notably, Licence Condition 1(3) of the LCCP requires personal licence holders to notify the Gambling Commission within ten working days of any personal key events, which include:

• the personal licence holder’s subjection to any criminal investigation that is listed under Schedule 7 (Relevant Offences) of the Gambling Act 2005;
• the personal licence holder’s conviction of any offence listed under Schedule 7 (Relevant Offences) of the Gambling Act 2005;
• any current or pending investigation by a professional, statutory, regulatory or government body in Great Britain or abroad;
• the imposition of any sanction or penalty against the personal licence holder following an investigation by any professional, statutory, regulatory or government body in Great Britain or abroad;
• the imposition of a disciplinary sanction against the personal licence holder (including dismissal) for gross misconduct;
• the personal licence holder’s resignation (from a position for which a personal licence is required) following commencement of disciplinary proceedings in respect of gross misconduct;
• the personal licence holder’s disqualification from acting as a company director;
• the presentation of a petition for the personal licence holder’s bankruptcy or sequestration, or the personal licence holder entering into an individual voluntary agreement; and
• a change in the personal licence holder’s name or address.

Personal Sanctions

Following the review of a personal licence, the Gambling Commission may impose:

• a warning;
• additional licence conditions or amending of existing ones;
• a financial penalty (only if a licence condition has been breached);
• suspension; and/or
• revocation.

To date, the Gambling Commission has not imposed a financial penalty or reached a payment in lieu of a financial penalty (as part of a regulatory settlement) in respect of a personal licence. The Gambling Commission keeps a regulatory sanctions register, which contains details of sanctions imposed on personal licence holders following licence reviews.

The requirements for a premises licence are:

• that the premises licence must be held, or applied for, in conjunction with an operating licence authorising the activity for which the premises are to be used;
• the right to occupy the premises (freehold, leasehold or tenancy); and
• that only one premises licence can apply to particular premises at a time (subject to exceptions).

Historically, remote operating licences did not reflect the distinction between B2B and B2C business models. B2B operators hosting games through B2C websites required a licence authorising remote casino, bingo, betting (virtual events) or betting (real events) – in addition to gambling software – as hosting games constitutes providing facilities for gambling.

However, new legislation introduced in April 2017 – namely, the Gambling (Operating Licence and Single-Machine Permit Fees) Regulations 2017 (SI 2017 No 303) – created the following B2B-specific “host” subcategories:

• casinos (game host);
• bingo (game host);
• general betting (host) (real events); and
• general betting (host) (virtual events).

Nonetheless, these licences are subject to various requirements, including that:

• the company must hold a gambling software operating licence; and
• the company must not contract with players directly.

See 6.1 B2C Licences.

Affiliates are not regulated by the Gambling Commission, as companies only providing advertising services or branding to a gambling operator do not require an operating licence. SRCP 1.1.2 provides that responsibility for third-party compliance lies squarely with the licence holder, who must ensure that third parties “conduct themselves in so far as they carry out activities on behalf of the licensee as if they were bound by the same licence conditions and subject to the same codes of practice as the licensee”. SRCP 1.1.3 provides that remote licensees must ensure that third-party user interfaces comply with the RTS. This positive obligation on licensees was confirmed in the White Paper and by the current Gambling Commission’s deputy CEO, Sarah Gardner, who reiterated the obligation on licensees by stating on 15 June 2023 that “many operators” should check “whether appropriate oversight of affiliates is in place”.

See 6.3 Affiliates. The Gambling Commission also provided guidance on how it expects licence holders to conduct white-label partnerships in Section 7 of its Compliance and Enforcement Report 2019–20.

There are no technical measures in place regarding consumer protection (other than as set out in the RTS and the LCCP) and the Gambling Commission does not have direct powers to enforce either payment or website blocking. However, the Gambling Commission seeks to protect consumers’ rights, through its powers under the Gambling Act 2005 for seeking enforcement action. As part of the White Paper proposals, the Gambling Commission will be given new powers to disrupt illegal gambling, including powers to block IP addresses. For further details, please refer to the UK Trends and Development chapter.

Responsible gambling – now termed “safer gambling” by the Gambling Commission – remains one of the Gambling Commission’s biggest areas of focus, spanning licensing, compliance and enforcement. Its oversight and requirements are broad, meaning they cannot be summarised in this chapter. The focus, which stems from the third licensing objective (protecting children and other vulnerable persons from being harmed or exploited by gambling), is proper identification and engagement with those who may be at risk of, or experiencing, harm, ensuring that terms and conditions are clear, fair and straightforward for consumers and do not target vulnerable or self-excluded customers.

There have been repeated examples of customers being allowed to gamble significant sums of money in short timeframes, considerably beyond their personal affordability, and without any intervention from the operator.

Key SG requirements include:

• preventing underage gambling and utilising age verification measures;
• detailed requirements regarding customer interaction, including taking into account the Gambling Commission’s remote customer interaction guidance under SRCP 3.4.3 and the Gambling Commission’s Guidance for premises-based operators under SRCP 3.4.1;
• the provision of gambling management tools (see 7.2 Gambling Management Tools);
• that licensees must, as soon as practicable, take all reasonable steps to prevent any marketing material being sent to a self-excluded customer;
• that, at the end of any self-exclusion period chosen by the customer, self-exclusion remains in place for a further six months (unless the customer takes positive action to gamble again);
• that, notwithstanding the expiry of the period of self-exclusion chosen by a customer, no marketing material should be sent to them unless and until they have asked for – or agreed to accept – such material; and
• that licensees must undertake a financial vulnerability check for customers who meet certain thresholds and that such check must include a customer-specified public record information check for significant indicators of potential financial vulnerability.

Operators are encouraged by the Gambling Commission to participate in GamProtect’s single customer view scheme, which is a mechanism through which participating operators share information of customers at risk of gambling-related harms. The scheme was facilitated by the Betting and Gaming Council and is supported by the Gambling Commission and the UK government.

As explained in 1.1 Current Outlook and Recent Changes, the White Paper proposed the creation of a non-statutory gambling ombudsman to handle social responsibility complaints from consumers. However, at the time of writing, the position of the new government on the gambling ombudsman is unclear.

Gambling management tools include:

• making information readily available to customers on how to gamble responsibly and how to access information about – and help in respect of – problem gambling;
• self-exclusion (operator and national), with a minimum of six months (up to 12 months);
• financial limits (deposit, spend or loss);
• timers;
• reality checks; and
• timeouts (24 hours, one week, one month or such period as reasonably requested by the customer, up to six weeks).

The Multi-Operator Self-Exclusion Scheme (MOSES) assists land-based operators with identifying at-risk gamblers. GAMSTOP is the online equivalent, initiated by the Gambling Commission and led by the Remote Gambling Association. Since 31 March 2020, all online gambling operators have been required – under the LCCP – to join GAMSTOP. Since 1 April 2024, this requirement extends to all gambling operators that make and accept bets by telephone and email.

The current primary legislation is the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (implementing the Fifth Anti-Money Laundering Directive). This was amended in January 2024 by various regulations to update the meaning of a “high-risk third country” and address the treatment of politically exposed persons (PEPs) who are entrusted with prominent public functions in the UK (“domestic PEPs”).

Money-laundering offences are outlined in POCA and TACT. The exemption threshold for paying away funds when exiting a relationship with a customer was increased from GBP1,000 to GBP3,000 in July 2025.

The Gambling Commission has also issued guidance for casinos – and, separately, for non-casinos – regarding their duties and responsibilities under POCA. The Gambling Commission most recently updated its guidance for casinos in October 2025 to incorporate:

• requirements concerning the treatment of domestic PEPs;
• changes to the list of high-risk third countries;
• updates to POCA; and
• the requirement for operators to give consideration to money-laundering risks posed by their business relations.

See 8.1 AML Legislation. The AML requirements are complex and cannot be adequately summarised here, particularly given the Gambling Commission’s ongoing focus and extensive casework in this area. Generally, the Gambling Commission expects licensees to comply fully with the terms of their licence in relation to AML and CFT and to pay close attention to the various guidance documents it issues.

Compliance and enforcement activity continue to reveal that operators’ AML policies, procedures and controls are not fit for purpose and, in many cases, customers are allowed to gamble using the proceeds of criminal activity. The Gambling Commission has warned the industry that “a failure to digest [its] guidance and implement the legislative requirements applicable to Great Britain... must change, for these are not just regulatory matters but breaches of UK law” and that “[t]hose failing to learn these lessons will face further draconian action”.

The ASA regulates UK advertising and, therefore, gambling advertising. However, it does not carry any enforcement powers. Instead, and given that the LCCP has specific rules on advertising, any gambling advertising breaches by a licence holder may lead to enforcement action by the Gambling Commission. This includes seeking criminal prosecution, as breach of a licence condition is a criminal offence under Section 33 of the Gambling Act 2005.

“Advertising” is widely defined under Section 327 of the Gambling Act 2005 and generally encompasses any action that encourages one or more persons, either directly or through an agent, to engage in facilities for gambling. This covers most forms of advertising, including online content and emails to consumers.

See 9.2 Definition of Advertising. Advertising must be socially responsible and comply with the LCCP – in particular, SRCP 5.1.6. The key LCCP advertising provisions are that:

• all advertising of gambling products and services should be undertaken in a socially responsible manner;
• operators should comply with the UK Code of Non-Broadcast Advertising, Sales Promotion and Direct Marketing (the “CAP Code”), the UK Code of Broadcast Advertising (the “BCAP Code”) and the Gambling Industry Code for Socially Responsible Advertising (the “Industry Code”);
• adverts must not include a child or young person, and no one who is, or seems to be, under 25 may be featured participating in gambling;
• operators must satisfy themselves that their adverts are not misleading;
• operators must comply with any provisions of the CAP and BCAP Codes in relation to free bet and bonus offers, including by stating significant terms and directing customers to the full terms, which should be no further than one click away;
• no adverts should appear on any web page that provides advice or information on responsible gambling;
• operators must not place adverts on websites providing unauthorised access to copyrighted content and must take all reasonable steps to ensure that third parties (eg, affiliates) do not do so;
• operators must be able to terminate contracts with third parties that breach this provision;
• operators must not contact consumers with direct electronic marketing without their informed and specified consent; and
• operators must provide customers with options to opt in to direct marketing on a per product and per channel basis.

The following codes are also applicable:

• all UK gambling advertising – the Industry Code, administered by the Betting and Gaming Council;
• broadcast advertising – the BCAP Code, administered by the ASA; and
• non-broadcast advertising – the CAP Code, administered by the ASA.

The ASA website includes a number of guidance documents, including:

• “Gambling advertising: protecting children and young people” (April 2019);
• “Social media marketing of gambling on eSports” (April 2020);
• “Gambling advertising: responsibility and problem gambling” (November 2021);
• “Guidance on depiction of under-25s in lottery ads” (July 2023);
• “Advertising Guidance – Age-restricted ads online” (September 2025); and
• “Gambling and lotteries guidance – protecting under-18s (October 2025)”.

The Gambling Commission’s web page “Advertising/marketing rules and regulations” provides an overview covering the various LCCP and industry regulations.

See 9.3 Key Legal, Regulatory and Licensing Provisions. In addition, since 1 November 2014, gambling operators wishing to advertise in the UK must hold a Gambling Commission operating licence pertaining to the type of activity advertised. Separately, the Gambling Commission has made clear that advertising-only licences will not be granted.

Since August 2019, a voluntary “whistle-to-whistle” sports-betting advertising ban initiated by the UK betting sector (including a ban on all TV betting adverts during pre-watershed live sport) has been effective.

In relation to online search activity, from 1 October 2020, the industry introduced a list of negative keywords against which no online gambling advertising should be served. This is a voluntary measure that was introduced in the Industry Code.

In 2022, the Committee of Advertising Practice (CAP) announced the introduction of tough new rules for gambling advertisements. The new rules (effective as of 1 October 2022) comprise a strong appeal test, which prohibits advertisements that are “likely to be of strong appeal to children or young persons, especially by reflecting or being associated with youth culture” – meaning that sportspeople, social media influencers and other celebrities who are prominent in youth culture are prohibited from being featured in gambling advertisements. On 14 September 2025, the CAP updated its guidance to further strengthen and clarify rules related to strong appeal.

From 1 September 2025, the scope of the CAP Code was extended to apply to non-paid-for online marketing communications (content marketing such as social media posts) aimed at UK customers by advertisers who are subject to licensing conditions imposed by a UK public authority or UK public body that require compliance with the CAP Code. The authors understand that the Department for Culture, Media and Sport is reviewing UK football sponsorship intended to target foreign audiences.

The White Paper did not materially restrict gambling advertising. However, it proposed that additional protections be required relating to cross-selling, free bets and bonuses, as well as the need to strengthen safer gambling messaging.

In April 2023, the Premier League made a voluntary commitment to banning advertising on the front of football shirts, commencing at the end of the 2025–26 season. Following the White Paper commitment to developing a cross-sport gambling sponsorship code, a number of major sports’ governing bodies also agreed to Codes of Conduct for Gambling-Related Agreements, which was announced in August 2024.

The following constitute criminal offences and attract up to 51 weeks’ imprisonment and/or an unlimited fine:

• inviting another person under 18 to gamble (Section 46 of the Gambling Act 2005); and
• advertising unlawful gambling (Section 330 of the Gambling Act 2005) – with the exception of lottery promotion, advertised gambling is held to be unlawful if:
1. the gambling advertised requires a licence, notice, permit or registration and, at the time of advertising, these arrangements have not been completed; or
2. arrangements for the advertised gambling are not such as to ensure that any exceptions to the offence apply.

The Gambling Commission also has the power to take regulatory enforcement action for breaches, including seeking to prosecute offenders.

Disclosure of a change of control of gaming and gambling companies to the Gambling Commission – via a key event notification using the Gambling Commission’s eServices, an online portal – is required as soon as reasonably practicable and, in any event, within five working days after the licensee becomes aware of the change of control.

Separately, a change of control application providing detailed information and the appropriate fee must be submitted to the Gambling Commission for assessment of the suitability of the new controller(s) to uphold the licensing objectives contained in the existing licence. The application or notification of licence surrender must be provided within five weeks of the change occurring; otherwise, the licence will be revoked.

Subject to the Gambling Commission’s assessment of all necessary information, the existing licence will either be granted continuance under the new controller(s) or will be revoked. Applications generally take much longer than the advertised 12 weeks.

Under Section 103 of the Gambling Act 2005, advance applications for persons or entities expected to become a controller can also be made prior to the change occurring. The Gambling Commission will make a determination, based on the information submitted, that – if the change were to occur – the Gambling Commission is either “minded to grant” continuance of the existing licence or “minded to revoke” the existing licence.

A change of corporate control is defined in Section 102 of the Gambling Act 2005 and occurs when a person or legal entity becomes a new “controller” (as derived from Section 422 of the Financial Services and Markets Act 2000). This is a complex definition, and needs to be considered in detail, but is generally broken down as:

• 10% or more of the shares in the licensee or in a parent undertaking of the licensee;
• 10% or more of the voting power in the licensee or in a parent undertaking of the licensee;
• 10% or more of the rights to profits/dividends (if the licensee does not have share capital); or
• less than 10%, but with the ability to exercise significant control over management of the licensee.

The same requirements as previously stated in 10. Acquisitions and Changes of Control apply, as there are no exemptions for passive investors.

Under Part 2 of the Gambling Act 2005, the Gambling Commission has the power to investigate and prosecute offences directly. Its regulatory powers also include calling licences for review and initiating investigations in the following circumstances:

• to establish whether its conditions are being complied with;
• where it fears a licensee has been convicted of a relevant criminal offence;
• where it considers a licensee to be unsuitable to continue holding a licence; and
• generally, where a review is deemed appropriate.

The Gambling Commission’s regulatory powers include:

• giving advice as to conduct;
• issuing a warning to a licence holder;
• attaching an additional condition to a licence;
• removing or amending a condition to a licence;
• suspending a licence;
• revoking a licence; and
• imposing a financial penalty following breach of a licence condition.

The Gambling Commission also has the power to commence a criminal prosecution. Where serious failings are revealed by a compliance assessment, the Gambling Commission may place a licensee in “special measures”, which requires the licensee to prepare, submit and agree to an action plan to remedy the identified failings.

The Gambling Commission’s approach to enforcement is currently set out in three key documents:

• the Statement of Principles for Licensing and Regulation;
• the Licensing, Compliance and Enforcement Policy Statement; and
• the Statement of Principles for Determining Financial Penalties.

Contravention of the Gambling Act 2005, including the LCCP (issued under the Gambling Act 2005), results in criminal liability. In August 2017, the Gambling Commission set out its “new vision” for its enforcement, emphasising its focus on putting consumers first. The key changes proposed included:

• putting all regulatory tools, including licence review (both of the operator and personal management licences), on an equal footing by removing the then-current bias in favour of settlement;
• introducing higher penalties for breach, particularly where systemic and repeated failings were seen; and
• using time-limited discounts to create better incentives for early settlement.

In recent years, the Gambling Commission has garnered a reputation for taking enforcement against its licensees. In certain cases, a “regulatory settlement” is reached, meaning that it is not a sanction and stops short of a formal licence review. This is subject to the Gambling Commission’s discretion and will only be considered if various factors are met, including:

• the licensee being open and transparent in its dealings with the Gambling Commission;
• the licensee being able to demonstrate insight into apparent failings;
• a timely disclosure of material facts;
• preparedness to agree to the publication of a public statement setting out the failings in order to deter future non-compliance by others and/or to share learning;
• preparedness to make a divestment of any amount accrued as a result of the failing;
• preparedness to follow advice and implement procedures to ensure there is no repetition of failings;
• preparedness to contribute to the direct costs to the Gambling Commission of investigating the matter in respect of which regulatory settlement is sought; and
• preparedness to volunteer a payment in lieu of the financial penalty the Gambling Commission might otherwise impose for breach of a licence condition.

The regulatory settlements and licence reviews are detailed in numerous public decisions or public statements issued on the Gambling Commission’s website and usually include a financial penalty. The record penalty package remains GBP19.2 million issued to William Hill Group in March 2023. Recent financial penalties imposed by the Gambling Commission include a GBP10 million fine against Platinum Gaming Limited in October 2025, a GBP1 million fine against ProgressPlay Limited in August 2025, and a GBP2 million fine against Spreadex Limited in May 2025. The fines were issued as a result of numerous social responsibility and AML failures.

A financial penalty imposed by the Gambling Commission will usually consist of two elements:

• an amount to reflect any detriment suffered by consumers and/or remove any financial gain made by the licensee as a result of the contravention or failure; and
• an amount that reflects the seriousness of the contravention or failure, the impact on the licensing objectives, and the need for deterrence.

The Gambling Commission will take into account all material circumstances of the case, such as:

• the seriousness and duration of the breach;
• whether it is a first-time offence;
• the involvement of management;
• the level of any financial gain from the breach; and
• the extent of steps taken to remedy the breach.

From October 2025, the Gambling Commission will ordinarily approach the quantum of a financial penalty by following a seven-step process set out in its updated Statement of Principles for Determining Financial Penalties. Following the seven-step process, the Gambling Commission will ordinarily further consider:

• any aggravating or mitigating factors;
• the need to increase the penal element of a fine to ensure it is a sufficient deterrent (“deterrence uplift”);
• the application of a discount to the penal element of a fine where an early resolution has been reached;
• an adjustment of the total penalty to ensure it is affordable; and
• an adjustment of the total penalty to ensure it is proportionate to the circumstances of the case.

It is worth noting that the financial elements of regulatory settlement, which are not sanctions, are calculated differently. The Gambling Commission also has the power to impose a financial penalty without carrying out a licence review.

The Gambling Commission is responsible for issuing and enforcing financial penalties regarding any LCCP breaches. Any contravention of the Gambling Act 2005 is a criminal offence in itself and will trigger a potentially unlimited fine, enforced by the courts, and imprisonment for up to 51 weeks (see 3.6 Penalties for Unlawful Gambling and 9.5 Sanctions/Penalties).

It is worth noting that any payment made as part of a regulatory settlement is not a financial penalty (as it is not a sanction) and is a payment made in lieu of a financial penalty. These regulatory settlements are treated differently by the Gambling Commission and could, theoretically, be enforced by recommencing the licence review.

The following gambling tax rates are effective from 1 April 2022 and are applicable at the time of writing (November 2025). These are expected to materially increase in the Autumn Budget of 26 November 2025, with remote gaming duty and machine gaming duty expected to increase the most.

• Bingo – the bingo duty due will be 10% of bingo promotion profits for each promoting period.
• Betting – the duty rates depend on the type of bet, as follows:
1. 15% of “net stake receipts” for fixed-odds bets, totalisator bets on horse or dog races, and bets taken on betting exchanges;
2. 3% of “net stake receipts” for financial spread bets;
3. 10% of “net stake receipts” for all other spread bets; and
4. 15% of the commission charges charged by betting exchanges.
• Casino (“gaming duty”) – the current casino gaming duty rates are tiered based on gross gaming yield, as follows:
1. 15% of gross gaming yield for the first GBP2.686 million;
2. 20% of gross gaming yield for the next GBP1.852 million;
3. 30% of gross gaming yield for the next GBP3.243 million;
4. 40% of gross gaming yield for the next GBP6.845 million; and
5. 50% of any remaining gross gaming yield.
• Lottery – the lottery duty is 12% of the price paid or payable on taking a ticket or chance in a lottery.
• Machine gaming duty – the rates of machine gaming duty differ based on the charge to play the machine game and the maximum cash prize available, as follows:
1. 5% of net takings from dutiable machine games with a maximum charge to play of not more than GBP0.20 and a maximum cash prize of not more than GBP10;
2. 20% of net takings from dutiable machine games with a maximum charge to play of not less than GBP0.21 and not more than GBP5, and a maximum cash prize of more than GBP11; and
3. 25% of net takings from all other dutiable machine games with a maximum charge to play of more than GBP5.
• Remote gaming duty (RGD) – RGD is charged at a rate of 21% on gross gaming revenues from all remote gaming transactions with customers whose usual place of residence is in the UK.

Please note, the majority of gambling activities are exempt from VAT.