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Gambling Law Reform Tracker

Welcome to CMS’ interactive gambling law reform tracker. With the UK Government finally publishing its long-awaited White Paper (‘High stakes: gambling reform for the digital age’) and the process of bringing the reforms into force now starting in earnest, we’ve collated resources, links and up-to-date information on the current state of play. We’ll be regularly updating this content as the Government’s proposals are implemented.  

Timeline

Reforms Tracker

Set out below are the key steps that have been undertaken so far in implementing the UK Government’s gambling law reform proposals:

 

Summary of proposalDeliveryResponsibilityStatus
Financial risk checks: Introduction of rules on financial risk / affordability checksGambling Commission powersGambling CommissionGambling Commission consultation closed on 18 October 2023. Awaiting publication of consultation response
Online slots stake limits: Introduction of maximum stake limits for online slots gamesSecondary legislationGovernment / DCMSDCMS consultation closed on 4 October 2023 and the response was published on 23 February 2024. Stake limits for online slot games to be introduced from September 2024
Online game design rules: Review of online game design rules, including requirements in respect of game speedsGambling Commission powersGambling CommissionGambling Commission consultation closed on 18 October 2023. Awaiting publication of consultation response
Changes to customer-led tools: Changes to improve uptake of customer-led tools (such as deposit limits)Gambling Commission powersGambling CommissionGambling Commission consultation closed on 21 February 2024.  Awaiting publication of consultation response
Bonuses: Introduction of restrictions on bonuses and other incentivesGambling Commission powersGambling CommissionGambling Commission consultation closed on 21 February 2024.  Awaiting publication of consultation response
Direct marketing: Introduction of additional requirements in respect of opting-in to direct marketingGambling Commission powersGambling CommissionGambling Commission consultation closed on 18 October 2023.  Awaiting publication of consultation response

Age verification on premises:

Removal of exemption from carrying out age verification test purchasing for smallest gambling premises

Gambling Commission powersGambling CommissionGambling Commission consultation closed on 18 October 2023.  Awaiting publication of consultation response.
One customer view / data sharing: Introduction of requirement for mandatory data sharing between online operators on high-risk customersGambling Commission powersGambling CommissionGambling Commission consultation closed on 18 October 2023.  Awaiting publication of consultation response.
Risk messaging: Improvements in respect of messaging on gambling-related risksGovernment actionGovernment / DCMSGovernment working group to commence.
Football shirt sponsorship: Premier League to end front-of-shirt sponsorships by gambling firmsVoluntary commitment (Premier League policy to implement a ban)Premier LeagueImplementation to commence from the end of the 2025/2026 football season
Gambling Commission Fees: Review of Gambling Commission licence fees to ensure the Commission has the necessary resources to make more use of data in active enforcement and deliver commitments in the White PaperPrimary legislation and secondary legislationGovernment / DCMSDCMS consultation on reviewing fees due to take place in 2024
Statutory levy: Introduction of a statutory levy paid by gambling operators to fund research, education and treatment of gambling harmsSecondary legislationGovernment / DCMS

DCMS consultation closed on 14 December 2023.  Awaiting publication of consultation response

 

 

Gambling Ombudsman: Introduction of a new Gambling Ombudsman to deal with disputes and provide redress where a customer suffers losses due to operators’ social responsibility failureVoluntary commitment with legislation if neededTBCThe process for appointment was due to commence in spring/ summer 2023 with the expectation for the Ombudsman to be accepting complaints within a year. Awaiting update
Transparency of customer funds protection: Introduction of new requirement for gambling businesses to remind customers that their funds are not protected in the event of insolvencyGambling Commission powersGambling CommissionGambling Commission consultation closed on 21 February 2024.  Awaiting publication of consultation response
Frequency of regulatory returns: Changes so that all regulatory returns would have to be submitted to quarterly (as opposed to annually)Gambling Commission powersGambling CommissionGambling Commission consultation closed on 21 February 2024 and response was published on 27 March 2024. All licensees to submit returns quarterly from 1 July 2024
Category D machine age limits: Introduction of age limit to play category D machines which mirror the mechanics of adult-only gaming machines (such as fruit machines) to 18Primary legislationGovernment / DCMSDCMS consultation closed on 4 October 2023.  Awaiting publication of consultation response.
Principles for determining financial penalties: Changes to the criteria for the Gambling Commission imposing a financial penalty and the methodology for determining the amount of a penaltyGambling Commission powersGambling CommissionGambling Commission consultation closed on 15 March 2024.  Awaiting publication of consultation response.
Financial key event reporting: Changes to existing, and addition of new, key reporting requirements in respect of changes to finances, ownership and interests within gambling licenseesGambling Commission powersGambling CommissionGambling Commission consultation closed on 15 March 2024.  Awaiting publication of consultation response.
Land-based casino licensing: Changes to increase gaming machine allowances for 1968 Act casinos; (ii) change the machine-to-table ratio for 1968 Act and 2005 Act Small casinos; (iii) change the size requirements for 1968 Act and 2005 Act Small casinos; and (iv) permit real event betting in 1968 Act casinos Primary legislation and secondary legislationGovernment / DCMSDCMS consultation closed on 4 October 2023.  Awaiting publication of consultation response.
Cashless payments on gaming machines: Introduction of player protections, including account holder authorisation, a cashless maximum transaction value, minimum transaction times, bespoke safer gambling messaging, as well as the display of net position and session timeSecondary legislation and Gambling Commission powersGovernment / DCMS and Gambling CommissionDCMS consultation closed on 4 October 2023.  Awaiting publication of consultation response.
Machine allowances in arcades and bingo halls: Modifying the 80/20 machine rule ratio to 50/50Secondary legislationGovernment / DCMSDCMS consultation closed on 4 October 2023.  Awaiting publication of consultation response.
Licensing authority fees: A review of the fee caps for premises licences for local authoritiesPrimary legislation and secondary legislation by introducing new powers to conduct cumulative impact assessments.Government / DCMSDCMS consultation closed on 4 October 2023.  Awaiting publication of consultation response.
Horserace Betting Levy: Beginning the review of the Horserace Betting Levy to ensure the appropriate level of funding for horse racing is maintainedReview outcomes will dictateGovernment / DCMS (but they have encouraged the betting and racing industries to work together on a voluntary deal)Due to be reviewed in 2024.

Frequently asked questions

What is a White Paper?

White Papers are policy documents produced by the Government that set out their detailed proposals for future reforms, providing a basis for further consultation, discussion and/or implementation.

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What happens next now the gambling White Paper has been published?

Now the White Paper has been published, the process of implementing the Government’s various proposed reforms begins. What is striking about the White Paper is that the means by which this will be achieved varies from proposal to proposal.  Certain changes will require primary legislation, whilst others may be implemented through secondary legislation (in the form of statutory instruments). Secondary legislation is made by a person or body under authority contained in primary legislation. In this case, the Secretary of State has the power to pass secondary legislation in respect of certain matters under the Gambling Act 2005. Other measures, it is proposed, would be achieved be regulatory reform by the Gambling Commission via changes to its Licence Conditions and Codes of Practice.   And in some cases the Government is looking simply for voluntary action from the industry.

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How will the Gambling Commission’s consultation process operate?

Prior to making any changes to the Licence Conditions and Codes of Practice, the Gambling Commission must put forward its proposals as part of a consultation, inviting responses from stakeholders. Following this it will publish a response and implement the relevant changes. All Gambling Commission consultations can be accessed here.

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I have more questions about the gambling law reforms, who can I contact?

The CMS team are available to answer your questions and help you navigate through the changes to the UK’s gambling regulatory landscape. Click the Contact Us box below to get in contact.

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Expertise

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