From Stake to TGP: What you need to know about advertising unlicensed gambling

The Gambling Commission (the “Commission”) has been paying closer attention to gambling sponsorships in English football, especially those involving overseas operators using white-label partnerships. This increased scrutiny follows public criticism and a regulatory investigation that led to TGP Europe (“TGP”) exiting the UK market. This raises important considerations for football clubs and their sponsors concerning gambling advertising and licensing requirements.

When is a licence needed?

Pursuant to section 33^[1] of the Gambling Act 2005 (the “Act”), save where limited exceptions apply, it is a criminal offence to “provide facilities for gambling” in Great Britain without a licence from the Commission.

In the case of remote gambling (i.e. gambling via remote means, such as the internet), section 36^[2] of the Act sets out the territorial scope of the section 33 offence. A licence will be required if:

• the gambling facilities are used in Great Britain (for example, if bets are accepted from customers located in Great Britain); and/or
• “remote gambling equipment” is located in Great Britain, even if the facilities are not used in Great Britain. This includes servers or systems used to store gambling-related data, present virtual events, determine outcomes, or store results, as defined under section 36(4)^[3].

If either of these conditions is fulfilled, the operator must hold a licence with the Commission. Without such a licence, any advertising of the operator’s gambling services would be considered “unlawful gambling”. Section 330^[4] of the Act prohibits the advertising of unlawful gambling, including by way of sponsorship arrangements.

For many years (since the introduction of the point of consumption licensing regime brought into force by the Gambling (Licensing and Advertising) Act 2014)^[5], the Commission has maintained that overseas gambling companies sponsoring UK football clubs or other sports teams or bodies should hold a licence with the Commission. They did, however, make it clear that they would not grant a licence to a gambling company purely for advertising purposes (i.e. they had to be actively providing gambling services to customers in Great Britain).

The Commission’s stance meant that many companies that were typically only interested in advertising to players in their local markets who were watching UK football, were forced to offer their services to customers in Great Britain. To do this in a way which did not require them to set up all of the infrastructure required to offer gambling to British players, many foreign operators entered into white-label agreements with Commission licensees, such as TGP. Under such arrangements, the licensee offered gambling facilities in Great Britain under the foreign operator’s brand but relying on its own Commission licence, therefore avoiding the need for the overseas operator to obtain a Commission licence.

What changed? Stake, Everton, and the Commission’s crackdown

This model attracted growing attention from campaign groups and media outlets, who raised concerns about the visibility of gambling sponsorships in football. Stake.com, one of TGP’s white-label partners, had entered a sponsorship agreement with Everton FC but later faced criticism for promotional material which included content considered sexually suggestive.

Following this, the Commission launched an investigation into Stake.com and increased its scrutiny of the broader use of white-label arrangements that facilitated sponsorship deals. As a result of the Commission’s action, Stake ended its relationship with TGP and restricted access to its gambling services from within Great Britain.

In response to criticism surrounding gambling sponsorships in football, the Commission issued warnings to Everton and other clubs. These warnings reminded the clubs of the potential offence under section 330 of the Act, which prohibits advertising of gambling services deemed “unlawful” if the sponsoring operator does not hold a licence with the Commission. In response, Everton stated that it would continue the partnership, but confirmed that Stake’s platform was no longer accessible from Great Britain. This meant that the operator was not providing gambling facilities within the jurisdiction, did not require a licence from the Commission and Everton could not, therefore, be advertising unlawful gambling.

TGP’s exit from the UK market

On 16 May 2025, the Commission officially announced that TGP had voluntarily surrendered its licence in the wake of its regulatory investigation. The company faced a substantial £3.3 million penalty and was required to completely overhaul its compliance systems to continue operating within Great Britain.

The Commission’s investigation uncovered that TGP had failed to conduct proper due diligence on its white-label partners. This lack of oversight raised concerns about the integrity of the sponsorships and the potential for unlawful gambling advertising. Faced with a hefty penalty and the need for extensive compliance reforms, TGP ultimately decided to withdraw from the UK market altogether.

Looking ahead

With TGP no longer holding a licence with the Commission, football clubs and their sponsors should carefully review any active sponsorship agreements involving overseas gambling brands who previously operated under TGP’s licence. The key consideration is whether the operator is providing facilities for gambling to customers in Great Britain. If access is properly restricted and services remain outside the jurisdiction, these sponsorship agreements will comply with the requirements of the Act and, despite the Commission’s threatening notice^[6], the sponsored club is not at risk of committing a criminal offence.

^[1] s.33 of the Gambling Act 2005

^[2] s.36 of the Gambling Act 2005

^[3] s.36(4) of the Gambling Act 2005

^[4] s.330 of the Gambling Act 2005

^[5] Gambling (Licensing and Advertising) Act 2014 

^[6] TGP Europe leaves GB market following Commission investigation