On 15 July 2026, the Department for Culture, Media and Sport launched a consultation on proposals to ban gambling operators that are not licensed by the Gambling Commission of Great Britain from entering into sponsorship or advertising arrangements in Great Britain.
The consultation follows the Government’s earlier indication that it intended to consult on a ban on unlicensed sponsorship in the sport sector (see our article on the announcement here). However, the proposal now goes further: the Government intends to apply the ban to all sectors. In their words this is “to avoid other sectors replacing sport as an alternative vehicle for unlicensed sponsorship”.
What is the current law?
Section 33 of the Gambling Act 2005 makes it a criminal offence to provide facilities for gambling without a licence, but s.36 of the Act provides that s.33 only applies to remote gambling (e.g. via the internet) if: (a) the gambling facilities are used in Great Britain (for example, if bets are accepted from customers located in Great Britain); and/or (b) “remote gambling equipment” (e.g. servers or systems used to store gambling-related data, present virtual events, determine outcomes, or store results) are located in Great Britain, even if the facilities are not used in Great Britain.
Section 330 of the Act makes it an offence to advertise, including by means of entering into a sponsorship arrangement, “unlawful gambling” (essentially gambling for which a licence is required under the Act but where such a licence is not held).
The combined effect of the above is that – as the law currently stands - so long as an operator is not accepting bets from end users in Great Britain and does not have any remote gambling equipment located in the jurisdiction, the operator does not require a licence from the Commission, and any person it is sponsoring would not, therefore, be advertising unlawful gambling.
Overseas operators have also previously sought to advertise in Britain without holding a licence with the Commission by means of entering into a white label arrangement with a licensed operator. In such circumstances, the overseas operator licenses its brand to a Commission-licensed operator which then accepts bets relying on its Commission licence.
Why is the Government proposing to change the law?
The Government argues that the current position “undermines the gambling licensing and advertising regulatory frameworks, which aim to protect consumers in Great Britain and reduce the risk of money-laundering and crime”. The consultation identifies three core objectives behind the proposed change:
“(1) to protect consumers, especially young people and those who are vulnerable, from unregulated platforms that may not offer adequate player protections or fraud recourse;
(2) to defend the integrity of our domestic market by ensuring advertising footprints are exclusive to operators who are required to adhere to the Gambling Commission's Licence Conditions and Codes of Practice (LCCP); and
(3) in the sport sector, to eliminate money laundering vulnerabilities within football clubs and agents that have been flagged within our National Risk Assessment.”
A key theme of the consultation is that sponsorship and advertising with high-profile clubs and competitions may give unlicensed operators an “implicit stamp of legitimacy”. The consultation notes that consumers may fail to distinguish between licensed and unlicensed operators, and may therefore incorrectly assume that unlicensed sites are regulated by the Gambling Commission and subject to associated consumer protections.
What is being proposed?
The Government intends to ban anyone, including sports clubs and bodies, from entering into a sponsorship or advertising arrangement with a gambling provider that is not licensed by the Gambling Commission. The consultation states that the Government intends to implement the ban by secondary legislation, using section 328 of the Gambling Act 2005, which gives the Secretary of State power to make regulations controlling the advertising of gambling, subject to Parliamentary approval.
Once the ban is in force, continuing to advertise or maintain a sponsorship deal with an unlicensed sponsor would be a criminal offence. Any person involved in a sponsorship or advertising arrangement that amounts to advertising gambling, as defined in s.327, would commit a criminal offence.
What will be caught?
Importantly, the proposed ban relates only to physical advertising assets. It would apply across all sectors and at all levels (including grassroots), covering “all sponsorship and advertising displayed at and associated with sporting and other cultural events such as kit and equipment sponsorships, event paraphernalia such as programmes, ground and field advertising, venue infrastructure, and naming of leagues, events and venues”.
The Government states: “We believe the primary issue of unlicensed operators sponsoring sport comes from in-stadium advertising. We are able to make these changes using secondary legislation, which will allow the Government to move faster on this issue, including expanding a ban beyond sport”.
As the Government points out, further legislative changes to include online and digital gambling advertising would require primary legislation to implement. This is something the Government suggests it may consider pursuing in the future if there is sufficient evidence to do so.
The Government does not anticipate extending the ban to gambling operators in white label agreements. However, it notes that it will work with the Gambling Commission to determine whether any further action is required to ensure white label agreements are sufficiently monitored and that enforcement action is taken where needed.
Timing
The Government is looking to introduce the ban as quickly as possible, while limiting the financial impact on sports by allowing time for replacement deals to be found where necessary. Its preferred option is to implement the ban from a fixed date in August 2027, ahead of the 2027/28 football season. The consultation states that this should “minimise commercial disruption and allow time to secure legitimate replacements”. The second proposed, but less favourable, option is for the ban to only apply to new arrangements, with any pre-existing contracts being allowed to run their term (provided this ends before August 2028).
The Government is seeking evidence from stakeholders to understand the potential impact of the ban, including on the financial viability of sports, clubs, leagues, events and other sectors, and whether the ban could create any unintended risks.
A significant change?
The consultation – in theory - represents a significant shift from the Government’s previous proposal, extending the ban on the advertising of unlicensed operators beyond sports and to all sectors. However, from a practical perspective, the difference will likely be negligible. As the Government acknowledges: “we are not aware of any sponsorships or advertising with unlicensed operators in other sectors besides sport, but they are theoretically possible”.
However, as per the Government’s original proposal, assuming the ban comes into force, there will be a significant shift from what is currently legally permissible. This has been welcomed throughout the regulated sector.
Whilst the ban currently only applies to physical advertising assets, it would not be surprising to see the Government take further action in the future to expand this to digital as well. As the consultation itself acknowledges, according to Frontier Economics, social media and adverts on social media are the most impactful driver of market awareness of illegal operators (22%). Put in context of the level of advertising spend by the unlicensed sector (with recent analysis from marketing intelligence firm WARC claimed accounts for close to 50% of UK gambling advertising spend), and fact that this is focused on digital channels, it would seem unlikely that further action will not eventually be taken.
