Withdrawn Changes to the regulatory framework for land-based casinos: draft secondary legislation
1968 Act casinos will move to the new regime once they elect to increase their enhanced entitlement to gaming machines, becoming subject to the mandatory premises licence conditions and fee scales of a 2005 Act casino. Depending on the type of casino licence an operator holds, they are able to site a different number of gaming machines, and may be bound by other restrictions including a maximum machine-to-table ratio and limitations on their size and non-gambling area. Subsections (3) to (5) of section 172 of the Act make provision as to the number of gaming machines which may be made available for use in a casino by the holders of different types of casino premises licences issued under the Act.
- Retail bingo clubs have highlighted that recovery from the COVID-19 pandemic has been slow and fragile due to the vulnerability of many of their customers and that the proposals set out by the sector could allow clubs to modernise and extend their offer to customers.
- The proposed measure will allow venues to remove unused Category C and D machines and save on the costs of maintaining and powering them.
- However, even when accounting for device type (i.e. cabinet, in-fill or tablet), the responses suggest that Category C and D gaming machines generate less GGY than Category B machines.
- It has also been overtaken by the development of digital Category B machines with improved player protections in comparison to older Category C and D machines, although we recognise there is scope to make further improvements.
Figure 1: Proposed sliding scale for 1968 Act casinos
Betting is permitted in 2005 Act casinos, which represent seven of the 122 casino premises open across Britain’s casino estate. As the Gambling Commission’s advice underlines, as a minimum, operators must be able to implement age verification and customer interaction, and maintain self-exclusion effectively regardless of the number of machines they are permitted to offer. This data was collected by the Gambling Commission from over 80% of the land-based casino sector. Notably, these rates are below the at-risk and problem gambling rates for casino table games (31.5% and 6.4% respectively). • Each separate area comprising the non-gambling area, other than the lobby areas and toilet facilities, must contain recreational facilities that are available for use by customers on the premises.
In addition, the current GGY derived from betting in casinos where it is permitted, is very small. However, at this stage we do not know precisely what these costs will be, as we do not have any evidence on how casinos will respond to this. All casinos to be permitted to offer sports betting. We would not permit betting in Scottish 1968 Act casinos until Scottish Ministers have had the opportunity to consider what (if any) restrictions or protections they would like to put in place by way of amendments to the Mandatory and Default Conditions Regulations. While permitting betting in 1968 Act casinos is not a reserved matter, as outlined above, we intend to impose a limit on the number of SSBTs that can be made available in a casino.
As set out in section 151 of the 2005 Act and in the Gambling Act 2005 (Premises Licences and Provisional Statements) Regulations 2007, the operator will also need to submit an up-to-date plan showing their table gaming area, other gambling areas and non-gambling areas. Respondents pointed to the need for authorities to undertake appropriate licence checks, and therefore it is essential that operators are transparent about any changes of circumstances. This will enable casinos to meet customer demand and bring Great Britain’s casino product offering more in line with international jurisdictions. They did however indicate that the presence of sports betting in venues would likely lead to an increase in revenue from non-gambling products such as sports bars.
Licensed gambling premises should be tightly controlled environments with adequate supervision to protect young and vulnerable people. We therefore do not think there is a justification for split-screen bingo and B3 machine games on tablets in bingo venues, due to the potential for harm with simultaneous play products. It also called for updates to licence conditions to allow flexibility to extend their default playing hours, to allow for split-screen functionality to enable simultaneous playing of bingo and B3 machine games on tablets in venues, and to allow more freedom to offer bingo outdoors or through social media. In response to the call for evidence, the bingo sector put forward a number of proposals for changes to rules which they argued could balance consumer freedoms with prevention of harm to vulnerable groups and wider communities. As set out in section 5.3 above, we acknowledge that some British Beer and Pub Association members are taking more measures to prevent the underage use of Category C machines in pubs. Given the excess supply of Category C and D machines, this should reduce energy costs without materially reducing GGY.
Cash-only gambling was assumed to give players more control by providing natural interruptions in play to obtain more cash, helping players play within budget limits. Please outline any other proposals relating to machine allowances in arcades and bingo halls that you think that we should consider. We welcome further evidence on this in the consultation response.
Online gaming products too have changed as the sector has matured, with rapid, stimulating and intense random number generator powered games like online slots becoming increasingly popular and making up a larger portion of operator profits over time. This has largely been driven by a channel shift from land-based gambling, where participation has fallen from 24.7% to 19.5% of adults in the same period (excluding the National Lottery). Online gambling overtook land-based gambling by GGY – the total value of funds staked minus any winnings or prizes paid out – in September 2019 and continues to grow. The Gambling Commission will consolidate and reinforce expectations for operators on contracting with third parties, including white labels. ‘White label’ describes a commercial arrangement whereby a licensee offers remote gambling under a brand provided by a third party which does not itself hold a remote gambling licence.
Where the Commission agrees a payment in lieu of a fine (a regulatory settlement), this is typically used for socially responsible purposes connected with gambling, in line with the Commission’s Statement of Principles for Determining Financial Penalties and most usually to address gambling-related harm. For gambling specifically, the Commission must approve all providers and has set specific supplementary standards for ADR in its guidance, including a further definition of what counts as a dispute and heightened expectations regarding independence, transparency, customer service and reporting requirements. Non-payment of winnings, account closures and misleading promotions and adverts were the main areas of complaint shown across ADR, Resolver, the online dispute resolution platform, and the Commission’s Contact Centre data. Data from the Gambling Commission’s quarterly online survey (June 2021) showed that 8% of respondents said they had ever complained directly to a gambling operator. Subject to industry delivering a credible scheme, where the government and the Gambling Commission are satisfied with its scope and independence, we will explore how best to require that all licensees ensure their customers have effective access to the ombudsman for social responsibility complaints.
The information that an ombudsman collates through complaints will assist the Gambling Commission in planning its enforcement activity and help industry to improve processes and support vulnerable consumers. This means customers seeking personal redress in these areas currently have no choice but to pursue potentially costly and uncertain court action. This aims to build capacity and start filling the key evidence gaps identified by PHE’s evidence review. Government will also co-host workshops with UK Research and Innovation (UKRI), the umbrella body for the UK research councils, Innovate UK and Research England, to stimulate interest and investment in gambling research.
Although it is withdrawing from commissioning research except where it directly relates to prevention and treatment, GambleAware is providing funding for a new, first of its kind Gambling Harms Research Centre to broaden the range of academic disciplines engaged with gambling harms research in Great Britain. Following a review of its fees in 2024, the Commission will also take an enhanced role in directly commissioning research to inform regulation based on its ongoing assessment of regulatory priorities to prevent harm. The government, including both DCMS and DHSC, will work with UKRI to build interest, capacity and investment in the gambling harms research field in Great Britain and identify research priorities. We welcome the significant contributions industry has made to RET since the introduction of the Gambling Act, and the substantial increase in funding the largest gambling operators have made available for treatment in recent years.
Casinos that do not site more than 20 machines
A further key component of the online advertising landscape is social media, which has been found to have a particular impact on children and young people, and accounts for an increasingly large proportion of their gambling ad exposure. This means it is likely that the minority experiencing serious harm from their gambling are not only seeing more gambling adverts than others, but are also more likely to spend money as a result of seeing them. Evidence submitted by a major charity found that even occasional gambling substantially increased online advertising exposure, with around 40% of those who gambled once a month reportedly being served 4 or more ads a day. Adverts such as TV, radio and online banner ads tend to influence a lower percentage of viewers to begin or increase gambling than those on social media. It is clear that the risks posed by gambling advertising are not uniform across the population, and that people respond to different types of adverts in different ways.
Bacta estimates that the removal of each Category C and D machine could save on average up to £21 per week, or £1,092 per annum, depending on trading hours. Industry responses argue that the current 80/20 ratio creates a disincentive to modernise older analogue Category C cabinets as they lack customer demand, yet operators are required to maintain them to meet the ratio. We have received estimates from the bingo club sector which show that the average weekly GGY produced per tablet machine is c.£3.80. In the bingo sector, for the equivalent machine we received estimated weekly GGY per machine to be c.£500. We did not receive GGY estimates for the arcade sector, however, industry responses indicated that they anticipated greater GGY returns under Option 3 than under Option 1.
Responses to the call for evidence also set out further background to the current gap and issues that will need to be considered in addressing it. Increasingly, technological solutions are also geared to maximising the learning from complaints data and making access to resolution and redress easier. Dispute Resolution Ombudsman, the operator of both the Rail Ombudsman and Furniture Ombudsman, provides additional data analysis to its members directly, equipping them to identify, respond to and track issues and themes in customer complaints and business practice.
As mentioned above, the existing regulations prohibit the use of debit cards for direct payments to gaming machines, and prohibit any use of credit cards. Over this same period, the weighted average weekly income from gaming machines for Landlord & Tenant pubs fell from around £215 to approximately £190, whilst for Managed pubs this fell from around £230 to approximately £180. Between 2019 and 2021, there was a decrease in the percentage of Landlord & Tenant pubs with gaming machines (from 60% to just over 40%), as well as a decrease in the percentage of Managed pubs with gaming machines (from 80% to around 65%).
The evidence provided by this operator projected that under Option 2(a), no further increases in Category B machines could be made, although 5% to 10% of Category C machines and up to 80% of Category D machines could be removed. We received a number of responses from large UK arcade operators who provided projections on how their gaming machine offer would change under Option 2(a) and 2(b) by comparison to the current situation. Based on the evidence provided, we believe that these machines have little customer appeal and are primarily made available as a space saving means of meeting the current 80/20 ratio.
UKGC licence is current, the responsible-gambling tools are properly integrated, and the affordability checks kick in at the regulated thresholds without making routine play feel surveilled. UKGC licence is current, GAMSTOP is integrated, and the responsible-gambling controls are properly placed. UKGC licence is current and the responsible-gambling tools are properly integrated.
However, given these enhanced protections and the experience of 2005 Act casinos since the Act was introduced, we consider it would be justified to bring greater coherence to the licence system by applying the same principles to casinos of a certain size. The Gambling Commission’s advice on land-based gambling sets out four main recommendations, together with commentary on specific issues explored in, and raised in response to, the government’s call for evidence. The Gambling Commission found that there was no distinction between the casinos licensed under the 2005 Act and those licensed under the 1968 Act in terms of its enforcement and compliance work on anti-money laundering and safer gambling issues. Operators told us that there are few places where demand for casinos is not currently met, but that there should be a mechanism for allocating licences to these areas in future. This strand of the Review set out to consider whether the current rules and protections outlined above are still relevant and provide the right protections for customers, taking into account the emergence of online gambling, and the changes in technology and society since 2005. Within those dedicated premises, the 2005 Act envisaged a hierarchy where the highest risk activities (such as certain gambling products, or having alcohol and gambling available at the same time) were confined to establishments with more controls.
£4 million of seed funding will be given over three years to the University of Bristol to build and diversify research capability in the gambling harms field. As the regulator, the Gambling Commission plays an important role in our understanding of gambling-related harms. The government and key partners, including UKRI and the third sector, will bring forward a range of initiatives which will increase the amount of high-quality independent research into gambling. GambleAware is an independent charity and has had no industry trustees since October 2018 and the industry has no role in commissioning decisions. Work on the development of the strategy is now underway and will consider the link between suicide and issues such as harmful gambling. Wider work led by the Department for Health and Social Care (DHSC) with regard to mental health and suicide prevention also takes gambling harm into account.
Medium protection
These checks use public data to spot signs of serious financial distress without requiring you to send in documents. It also pushes the market toward a more consistent baseline, where limit-setting feels normal across regulated brands rather than something only a handful of operators promote. From 2025, maximum stakes for online slots in Great Britain were capped at £5 per spin for adults aged 25+ non gamestop casino (implemented on 9 April 2025) and £2 per spin for adults aged 18–24 (implemented on 21 May 2025).
Given likely diminishing marginal returns when a casino already has at least 20 machines, we estimate that the extra machines could increase GGY by £25 million to £65 million (14% to 36% of casino Category B machine GGY). However, gambling space in the average casino is 784m2 (3.1 times larger than the 10 smallest casinos). We used the Gambling Commission data request to operators in April 2021 (validated against previous 2018 data from a report commissioned by GambleAware) to determine current staking patterns. Our approach to modelling the GGY reduction from an online stake limit (section 1.3), including data used and key assumptions, is set out below. We are confident overall that the majority of customers, especially the majority who spend at lower levels, are unlikely to be negatively impacted by the changes we propose to help prevent gambling-related harm.
However, in recent years there has been a proliferation of space-saving in-fill and tablet gaming machines in arcade and bingo venues. How, if at all, would the approaches taken in Options 1, 2 and 3 impact the ability of business to meet customer demand for gaming machines? This would also apply for in-fill and tablet gaming machines. Our objective in reforming the ratio of Category C and D to Category B gaming machines is to support a sector which has experienced significant commercial challenges in recent years through increased flexibility over their gaming machine offer.
The vast majority of submissions to the call for evidence from outside of industry supported a substantial increase in the Gambling Commission’s fees, and an increase in flexibility, to enhance its effective regulation of the gambling industry. Submissions from industry and campaign groups differed on whether there is currently a significant black market for gambling or a risk of one emerging. The government hopes that this approach will raise standards across the industry and therefore ensure that customers are protected adequately and that gambling is free from crime. In a market where the largest companies account for a large proportion of gambling, the Commission will also explore options for an enhanced account-based compliance approach that will include dedicated team members assigned to the largest operators on a permanent basis. This will include more active oversight of operators beyond the Commission’s current approach, which requires operators to report key information on a regular basis but targets compliance activity and checks on a risk-based and intelligence-led basis. We also note that compliance with voluntary codes may be relevant in deciding operators’ suitability to hold a gambling licence during Gambling Commission enforcement action.
No income or capital gains tax applies to prizes from casinos, sports betting, bingo, or online gambling, a rule in place since 2001 when taxation shifted to operators. This change aligns online slot limits with those of land-based casinos, with £5 matching B1 machines and £2 for younger adults, due to their higher vulnerability and lower income. Otherwise, payment processing per se is not licensable under British gambling law and the main restrictions are that land-based bingo and casinos may not offer credit for wagers and remote gambling operators may not accept credit card payments (including through money services providers). As well as an operating licence, an operator wishing to make gambling facilities available in a land-based environment (e.g., casino, betting shop, bingo hall or arcade centre) will also need to apply for a premises licence authorising that activity from the relevant local authority.
This should ensure that consumers, particularly those who are vulnerable, are better protected from illegal operators which are unlikely to offer the same safeguards that exist on legal sites. As outlined in the consultation which preceded the uplift, some of the increase in income has been devoted to more staff that are able to both identify the scale of the black market and take action to tackle illegal operators. The Commission will need to specify to the court the operator that it would like to disrupt, evidence that it is acting illegally and explain the requirements that it would like to be imposed on the ancillary service (for example, for a payment provider to remove their payment services). These are helpful and positive steps which should make it more difficult for people to access these types of harmful websites. Google has now removed paid-for Google Ads promoting ‘Not on GAMSTOP’ affiliate sites which pose a risk to vulnerable consumers. Similarly, operators licensed in Britain could face action by the Commission if they were found to have operated illegally in the jurisdiction of one of the Commission’s international partners.
Following evaluation later this year, the intention is to expand the system to consider customers who are showing other indicators of harm with one operator which might necessitate coordinated action with other operators. The live trial which started this month is based on operators sharing information on individuals who have had their accounts closed because of disclosures about suffering serious harm. An industry-led trial with GAMSTOP as the delivery partner is now proceeding, having been supported by the ICO’s sandbox process, and focusing on high risk customers. We are pleased progress has been made on these after the Information Commissioner’s Office confirmed that, subject to certain controls, operators can share customer data for harm prevention purposes in compliance with existing data protection requirements. Their concern is that not only are those being harmed by gambling unlikely to be helped by such a measure, but also that many of those who were not being harmed would nonetheless be driven away from licensed operators. The precise impact of these changes will depend on the details which the Gambling Commission will consult on shortly, including how operators are required to conduct the checks and how they respond to certain findings on customers’ financial circumstances.