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10 June 2022 | Comment | Article by Martin Jones

Change is coming in the gambling sector | National Licensing Week 2022

For the second day of National Licensing Week, Trainee Solicitor, Caius Mills, and Partner, Martin Jones, look into gambling licensing requirements and the penalties for non-compliance.

The law relating to gambling in Great Britain is likely to be subject to significant change in the near future. A government review was commenced in December 2020 and proposals for change (in the form of a White Paper) are expected imminently.

With very few exceptions, businesses which provide gambling facilities to customers in England, Scotland or Wales need an operating licence. The activities which amount to the provision of gambling include:

  • running amusement arcades
  • bookmaking (through betting shops, on-course pitches or on-line)
  • operating a bingo hall, bingo nights or online bingo
  • offering casino games online
  • providing gaming machines for others to use
  • providing gambling software (this can include software which has an indirect link to the gambling operation)
  • running or managing a lottery.

Internet businesses based outside Great Britain still need a licence if they offer services to those living here. And sometimes, businesses in other sectors will stray into the provision of gambling, for instance when operating sales promotions.

Do you need a licence?

Working out whether a licence is needed and, if it is, identifying which kind of licence is required can be a complex undertaking. The existing boundaries between activities that need a licence and those which do not may be about to change as a result of the government review. Change is also in the air for those who already hold an operating licence.

Compliance with licence conditions

In addition to the significant changes which are likely to arise from the government review, the application of the existing law is changing. Ensuring compliance with licence conditions and the Gambling Commission’s Codes of Practice has always been vital. But there is a renewed emphasis on compliance currently and any breaches can have very serious implications. For example, in March 2022, the Gambling Commission imposed a £3.15m fine on Camelot UK Limited for failures discovered with its mobile app.

Andrew Rhodes, who was recently confirmed as the Gambling Commission’s permanent Chief Executive, commented “any operator failing to comply with their licence requirements will be investigated by the Commission and we will not hesitate to issue fines if requirements are breached.”

The Gambling Commission is bringing in stronger and more prescriptive rules for operators to follow. They come into force on 12 September 2022 and guidance will be published by the Gambling Commission later this month. The rules are intended to ensure that operators take “fast, proportionate and effective action” to identify and protect customers at risk of harm.

The Gambling Commission expects operators to take steps to check their ability to meet the new rules and is placing a greater emphasis on external auditing of compliance.

The Government’s proposals for wider reform have not emerged in time for National Licensing Week but we will be publishing a series of articles once the White Paper is published, covering both the changes to the boundaries of licensing regulation and the implications for existing operators.

How can we help?

At Hugh James we have a wealth of experience in assisting our clients to:

  • identify whether they need a licence;
  • obtain the licences they need; and
  • ensure compliance with Gambling Commission requirements, including by way of independent audit.

We would welcome the opportunity to help your business to navigate the coming changes. If you have any specific enquires about your business, get in touch with our dedicated Licensing team, using the button below.

Author bio

Martin Jones


As the Head of the Regulatory Department, Martin acts in a wide-range of regulatory crime and professional regulation matters. Martin has built up over 20 years of experience and a wealth of specialist knowledge.

He leads the firm’s cross-departmental alcohol and gaming licensing teams. Additionally Martin manages the teams providing a range of outsourced services to local authorities, including court representation of local authorities Adult and Children’s Services Departments.

Disclaimer: The information on the Hugh James website is for general information only and reflects the position at the date of publication. It does not constitute legal advice and should not be treated as such. If you would like to ensure the commentary reflects current legislation, case law or best practice, please contact the blog author.


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