CMS Insights
CMS Articles
Prize draws and competitions in the spotlight: A voluntary code or future regulation?
The results of a report commissioned by the Department of Culture, Media and Sport (DCMS) into the prize draws and competitions (PDC) market were published on 26 June 2025. DCMS commissioned London Economics in August 2023 ... Read more
Gambling Commission introduces ban on mixed product promotional offers and cap on wagering requirements
On 26 March 2025, the Gambling Commission published its response to its consultation on socially responsible incentives, confirming that it will introduce a ban on mixed product promotional offers and a cap on wagering requirements... Read more
UK Government’s 2025 Statutory Levy on Gambling Operators
The UK government has published its response to the consultation on the structure, distribution, and governance of the statutory levy on gambling operators... Read more
Gambling Commission publishes update to new direct marketing requirements
In May 2024, the Commission published its response to a consultation (the “Consultation”) on proposed changes to the Licence Conditions and Codes of Practice (the “LCCP”) requirements...Read more
UK football and horseracing bodies implement new codes for responsible gambling sponsorships
The Betting and Gaming Council (“BGC”), working with various sports bodies, has developed the "Codes of Conduct for Gambling-Related Agreements" framework, with each body creating a code tailored to its sport...Read more
Land-based Gambling: DCMS Consultation Response
Following its consultation on “measures relating to the land-based gambling sector”, DCMS published its response on 16 May 2024, broadly proceeding as planned with its proposed reforms... Read more
Keeping the Wolf from the Door: Reducing the Black Market
Ever since the Review of the Gambling Act 2005 commenced (and for some time before), the gambling industry has raised the spectre that enhanced measures to identify and protect those at risk from gambling harm will only serve to drive players to the black market... Read more
Gambling White Paper Consultations: The Commission’s First Responses
In July 2023, the Gambling Commission (GC) published its first set of consultations on the Gambling White Paper ‘High stakes: gambling reform for the digital age’. Having received 3,113 responses from stakeholders to the consultations, the GC has now published its response to each of these consultations... Read more
Gambling White Paper Consultations: The Commission’s Response on Financial Risk and Vulnerability Checks
The Gambling Commission (GC) has now published its response to its latest consultation on financial vulnerability and financial risk (which was published in July 2023 and discussed in our article). The response states that the GC is working towards a new... Read more
Gambling Commission Consultation: Financial Penalties and Financial Key Event Reporting Introduction
The Gambling Commission has opened a consultation on proposed changes relating to financial penalties and financial key event reporting. The proposed changes to financial penalties would be effected through a revised Statement of Principles for Determining Financial Penalties... Read more
Gambling White Paper Consultations: Consumer-led tools
On the 29 November 2023, the Gambling Commission (“GC”) released its second set of consultations on the Gambling White Paper which covers five key areas. This article focuses on customer-led tools... Read more
Gambling White Paper: Socially responsible incentives
On the 29 November 2023, the Gambling Commission (“GC”) released its second set of consultations on the Gambling White Paper which covers five key areas. This note focuses on socially responsible incentives... Read more
Gambling White Paper Consultation on changes to the frequency of regulatory returns submissions
On the 29 November 2023, the Gambling Commission (“GC”) released its second set of consultations on the Gambling White Paper which covers five key areas. This note focuses on changes to the frequency of regulatory returns submissions... Read more
Gambling White Paper: Improved transparency on customer funds in the event of insolvency
On the 29 November 2023, the Gambling Commission (“GC”) released its second set of consultations on the Gambling White Paper which covers five key areas. This note focuses on improved transparency on customer funds in the event of insolvency... Read more
Gambling White Paper: Embracing the Future with a Statutory Levy
On the 29 November 2023, the Gambling Commission (“GC”) released its second set of consultations on the Gambling White Paper which covers five key areas. This article focuses on removing obsolete Commission requirements due to the government’s upcoming statutory levy (LCCP RET list)... Read more
Gambling White Paper Consultations: Land-based gambling
On 26 July 2023, the Department for Culture, Media & Sport (DMCS) published a consultation on ‘measures relating to the land-based gambling sector’ (Consultation). This Consultation directly followed on from the Gambling White Paper published in April 2023, which set out the government’s plans... Read more
Gambling Commission White Paper Consultations: Regulatory Panels
On 26 July 2023, the Gambling Commission published its first set of a consultations in response to the White Paper published by the government in April 2023 which set out a plan for reform of gambling regulation following the review of the Gambling Act 2005... Read more
BGC extends IGRG Code to digital media
On 27 September 2023, The Betting and Gaming Council (BGC), which represents the UK regulated betting and gaming industry, has announced that it is updating the safer gambling requirements it requires its members to comply with... Read more
Gambling White Paper Consultations: Remote Game Design
On 26 July 2023, the Gambling Commission (GC) published their first set of consultations on the Gambling White Paper, which cover four key areas... Read more
Gambling White Paper Consultations: Improving Consumer Choice on Direct Marketing
On 26 July 2023, the Gambling Commission (GC) published their first set of consultations on the Gambling White Paper, which cover four key areas... Read more
Gambling White Paper Consultations: Strengthening Age Verification
On 26 July 2023, the Gambling Commission (GC) published their first set of consultations on the Gambling White Paper, which cover four key areas... Read more
Gambling White Paper Consultations: Financial Risk Checks
On 26 July 2023, the Gambling Commission (GC) published their first set of consultations in respect of reforms proposed in the Gambling White Paper, covering four key areas... Read more
Gambling White Paper Review
On 5 June 2023 we held the CMS Gambling White Paper Webinar, with special guests Tim Miller (Executive Director, Gambling Commission), John O’Reilly (Chief Executive Officer, The Rank Group plc), Brigid Simmonds (Chair, Betting and Gaming Council), Dan Waugh (Partner, Regulus Partners), and Joanne Whittaker (Chief Executive, BetFred)... Read more
Gambling Commission evaluates Online Games Design changes
On 8 June 2023, the Gambling Commission published its assessment of the online game design changes that were introduced in October 2021. The Commission’s changes focused on online slot games and included limiting the speed of spins, prohibiting features that accelerate gameplay and banning auto-play... Read more
The Gambling Review White Paper: Financial Risk Checks (AKA affordability checks) for online operators
One of the issues which prompted the most debate in the lead up to the White Paper has been the notion of ‘affordability checks’ for online operators i.e. whether – and the extent to which – gambling companies should be required to satisfy themselves that their customers can afford to spend... Read more
Gambling White Paper: Online Protections – stake limits, design standards, single customer view, and much more
Accompanying its proposals in respect of affordability checks in the White Paper (on which we will shortly be publishing a dedicated article), the Government has set out a raft of additional “online protection” initiatives designed to better protect customers when gambling online... Read more
The Gambling Review White Paper – the devil will be in the consultations
On 27 April 2023, approaching 2½ years following the Government’s launch of its review of the Gambling Act 2005, the Government has published its White Paper outlining its proposed reforms. The delay in publication may, in part, be explained by the 16,000 submissions to its Call for Evidence but... Read more
The Gambling Act Review – what do we know so far?
Following the announcement on 8 December 2020 that the Government has launched its review of the Gambling Act 2005, the Terms of Reference and Call for Evidence have now been published, together with the Government Response to the House of Lords Gambling Industry Committee Report: Social and Economic Impact of the Gambling Industry... Read more
Gambling laws in Great Britain – The review begins
This morning (8 December 2020), the UK Government launched its “major and wide-ranging” and long-awaited review of gambling laws in Great Britain. A call for evidence will run for 16 weeks and will close on 31 March 2021. The Department for Digital, Culture, Media and Sport (DCMS) has said its review will include consideration of... Read more
The Gambling Review White Paper: Land-based gambling “levelling-up”?
The Government takes a noticeably different approach in respect of land-based gambling, to that of online gambling, in the proposals for gambling regulatory reform put forward in its White Paper. Whilst it largely seeks to tighten regulations relevant to the online space, with respect to land-based gambling... Read more
CMS videos and podcasts
CMS Partners David Zeffman and Anna Soilleux-Mills were joined by a panel of industry experts to discuss key takeaways from the recently published Gambling White Paper.
Tamsin Blow, Partner at CMS and David Williams, Director of Public Affairs at Rank Group consider the three main process that govern customer interaction and affordability: the LCCP, guidance from the Gambling Commission and enforcement actions. They discuss what challenges the proposals for thresholds for affordability checks pose for the sector, including a discussion on what the customer wants and needs. There are concerns that customers will step away from providing more documentation and whether this is the most effective way to protect the most vulnerable.
Dan Waugh, Partner at Regulus Partners, explores the ongoing conversation surrounding gambling reform in Great Britain amidst White Paper delays. Dan moderates the discussion between Lee Fenton, CEO at Bally’s Corporation, Conor Grant, CEO at Flutter UK & Ireland, Lord Mendelsohn, Chairman of 888, Brigid Simmons, Chairman of the Betting and Gaming Council, and Joanne Whittaker, CEO at Betfred. The group navigate the package proposed and the balance to be struck between affordability, privacy and public health. The session ends with a debate around where and with who responsibility should lie for measuring harm, and the importance of adopting a risk-based approach that evolves alongside the sector.
