Guidance to licensing authorities
Removing the test purchasing exemption on small business will result in additional minor costs for smaller gambling operators. Making ‘Think 25’ an ordinary code expectation for Gambling Commission licensees will introduce consistency across the sector, discourage children from trying to take part illegally in gambling activities and reduce potential harm that might be caused by early exposure to age-restricted gambling products. We will continue to monitor industry’s progress on this issue and will legislate to make provisions within the Gambling Commission’s code of practice for alcohol licensed premises binding when Parliamentary time allows. sites not on gamstop Pre-2020 test purchasing pass rates were also very low for gambling in alcohol licensed premises (Figure 19).
In practice, operators elect to site Category B machines and typically have an offering of 20 Category B1 machines. Without intervention, there is a risk that machines could become obsolete as we move towards a “cashless” society. The white paper proposed to reform the 80/20 rule in response to evidence that the current rule does not allow operators to adequately meet consumer demand, while still providing a balanced product offer to customers. Arcades and bingo premises are subject to an 80/20 rule which governs the balance of Category B (maximum £2 stake) and Category C or D machines in these venues (up to a maximum £1 stake). The size of Britain’s land-based casino sector has remained relatively flat in recent years, in contrast to an expanding online market.
A further 25 casinos have multiple licences within one premises, allowing them to supply 40 or 60 machines. The current estimate is that 90 out of 122 casinos are limited to 20 gaming machines, regardless of overall size. Only 4 of the 8 Small casino licences have been developed, one has since closed, and none offer the maximum allowance of 80 gaming machines as it would be impractical to site the necessary tables. Currently, no more than 20% of the total number of gaming machines on these premises can be Category B; the remaining machines must be of a lower category (i.e. C or D). Outdated and overly restrictive rules on gaming machines will be reformed so casinos and arcades can have more machines.
With regard to casinos that currently operate with a gambling area of 1500sqm or more, these casinos will be permitted to remain open with their current gambling area. When asked about the reduction in minimum table gaming area in Small 2005 Act casinos from 500sqm to 250sqm, more respondents were in favour of this being applied than opposed. A fairly even number of respondents were for and against the 12.5% rule applying for 1968 Act casinos, whereby any table gaming area would only count towards the minimum table gaming area if it constitutes 12.5% or more of the total table gaming area in the venue. Any 1968 Act casinos that wish to remain on the existing regime will be able to do so and are not required to adjust their product offering (unless they decide to take up the opportunity to offer facilities for betting). Feedback from engagement with operators has indicated that the sliding scale as proposed would benefit the majority of casinos, with over 80% of casinos estimated to benefit depending on how floor space is reconfigured.
People aged 18 to 24 years old can be particularly vulnerable to gambling- related harm due to their financial or personal circumstances and continuing brain development resulting in generally lower impulsivity control. The Commission will also consult on extending the duty in LCCP to require test purchasing by small operators in fee categories A and B, to ensure all land-based venues are subject to the same age assurance processes. We will legislate to strengthen licensing authorities’ powers in alcohol licensed premises by making provisions within the Gambling Commission’s code of practice binding, when Parliamentary time allows. To further support effective age verification processes, the Gambling Commission will consult on moving from ‘Think 21’ to ‘Think 25’ in their ordinary code for all land-based licence holders. This will create a clear distinction between gambling products for adults and lower risk products for children (such as crane grabbers or coin pushers) which have non-cash prizes or operate completely differently. We will legislate to increase the minimum age to play cash-payout Category D slot machines to 18 years, reinforcing The British Amusement Catering Trade Association’s (Bacta) voluntary commitment.
As the SI sets out, all games which meet the definition of an online slots game will be subject to a maximum stake per game cycle. “game cycle” means, for an online slots game, the period beginning with the initiation of a game by the individual and ending at the point at which all money staked during the game has been lost or all money won during the game has been delivered to or made available for collection by the individual as the case may be. (2) The condition is that, for an online slots game, the total amount which an individual may stake in relation to any game cycle may not exceed— We can also assess a licensee’s ongoing suitability to hold a relevant license, particularly if there is evidence of misconduct abroad and that does include in Northern Ireland. Added link to 2026 edition of the Gambling Commission’s Money laundering and terrorist financing risk assessment. Read our guidance for information on operator LCCP requirements, including how these can be implemented in practice.
The primary benefit of this measure is increased GGY for casinos that take up additional gaming machines. Gambling operators must ensure that their supervision and monitoring of gaming machines enables them to meet the requirements of the Act and conditions of their licence. Data from the National Gambling Treatment Service shows that a relatively small proportion of patients report participating in gaming machines in casinos. Taken together, the three measures will determine the maximum number of gaming machines that casinos will be entitled to. The sector views an increase to this ratio as essential in order to ensure these casinos’ long term viability by allowing them to site more gaming machines, and this conclusion was reflected in the white paper. It has also meant that none of these casinos are able in practice to satisfy the current conditions which would allow them to offer the maximum number of gaming machines due to the amount of space they take up.
We will also permit casinos of all sizes to offer sports betting in addition to other gambling activities and will take steps to reallocate unused 2005 Act casino licences to other local authorities. We will allow smaller casinos to benefit from more machines on a pro rata basis commensurate with their size and non-gambling space, subject to the same table to machine ratios and other conditions. The 2005 Act sets out a range of restrictions for land-based gambling based on the assumption that restrictions on supply (for example casino numbers and gaming machine availability) are an important protection.
As part of the arrangements for allocating existing 2005 Act licences, where more than one operator wanted to develop a casino, local authorities were able to take into account the financial contribution of operators towards regeneration and harm prevention. Increased machine allowances across the casino estate will bring commercial benefits to casino operators, and allow them to compete on a more equitable footing with online operators. We estimate around 50 casinos smaller than the 2005 Act Small casino would also be able to benefit from increased machine allowances, proportionate to their size and non-gambling space. 1968 Act casinos which do not meet these size requirements will also be able to benefit from extra machines on a pro rata basis commensurate with their size.
Additionally, foreign operators from whitelisted gambling jurisdictions were required to pay a 15% point-of-consumption (POC) tax on gross profits. They can be classified as Category A, B, C, or D, and under Section 236 of the Gambling Act 2005, Category B machines are further divided into subcategories. Casino games are a specific subset of games of chance that may be offered only in casino premises; they are distinct from equal-chance games. All casino operators must obtain a license from the Gambling Commission, and their profits are subject to taxation depending on the type of game they offer.
- Therefore, this option would need to be accompanied by a requirement that Category B3 machines in these venues would have certain player safety controls, such as staff alerts where a player meets spend or time limits.
- Industry has recognised the concerns around slot style machines and in March 2021, Bacta members updated their Social Responsibility Charter and Code of Practice to voluntarily implement a ban on under 18s using cash out slot style machines.
- This will include options of a £2 stake limit per spin; a £4 stake limit per spin; or an approach based on individual risk.
- The UKGC’s October 2025 report (updated March 2026) describes a concrete toolkit for disrupting illegal operators serving Great Britain.
- However, we want to avoid any regulation that would allow table gaming areas to be placed in obscure or less accessible areas for customers so that a genuinely mixed offering of products remains in the casino.
Some organisations concerned about the normalisation of gambling for children wanted to see the minimum age for all commercial gambling, including Category D machines, raised to 18. The activities with the highest participation over that period were arcade gaming machines such as penny pusher or claw grab machines (22%), placing a bet for money between friends or family (15%) and playing cards with friends or family for money (5%). Low stake Category D gaming machines have no minimum age for play, although members of the main trade association voluntarily restrict play to adults only on slot style or ‘fruit’ machines which pay out cash (see Annex C for a full breakdown of machine categories).
Other evidence suggests adolescents have a greater risk tolerance compared to older adults and this may be reflected in their attitudes towards gambling specifically. PHE’s evidence review highlights a higher problem gambling and at risk rate among younger age groups than older age groups. Making the Gambling Commission’s code of practice for alcohol licensed premises binding would provide licensing authorities with greater powers on underage gambling in premises, but we do not expect it to create an additional burden for them. In their submissions to the review, representatives of the pub sector outlined a number of steps they are taking to address this, including regular staff training and building age verification into the machines themselves to reduce the reliance on staff supervision. However, due to the exemption, the Gambling Commission currently has an incomplete picture of the risks from underage gambling in premises run by smaller licensees. There have been calls from both industry and campaign groups to introduce ‘Think 25’ as standard for all land-based gambling, a position shared by the Advisory Board for Safer Gambling (ABSG) in its 2018 report which pointed to findings from the retail alcohol industry.
We also welcome international evidence. If you cannot access the link, please send responses to in a document format like PDF or Microsoft Word. Is any of the information you have provided confidential, commercially sensitive or otherwise unsuitable for publication (including in anonymised)? Which of the following best describes your interest in gambling policy (select up to two options)?
Consultation description
It suggests that many smaller operators already undertake test purchasing voluntarily or through membership of a trade body, and while there is a financial cost to each test purchase, this is normally low (under £50). The Gambling Commission’s ordinary code says that all land-based licensees should require their staff to check the age of any customer who appears to them to be under the age of 21, also known as ‘Think 21’. While low test purchasing rates demonstrate serious failures of process at venues, this does not necessarily mean that significant numbers of children are illegally accessing gambling. For instance, the Gambling Commission’s Young People and Gambling Survey (2019) found a higher proportion of children than adults reported having visited a casino in the last 7 days. Increasing the age limit to play Category D cash payout slots to 18 years — moving it from a voluntary to a legal footing to include all operators — will break the link between cash payouts and slot-style adult play for children.
The high-end casinos are not distinct in legislation, and all have licences based on the 1968 Act; but their business model is very distinct in practice from that of most casinos in Great Britain and gaming machines contribute just 1% of their GGY compared with 20% to 30% in mainstream casinos. In support of its case for additional machines, the industry provided evidence that the current low availability of machines can in fact increase the risk of gambling-related harm, as customers play for longer on machines due to fear of losing their place. Gaming machines are permitted in a variety of locations, including casinos, licensed betting offices, licensed bingo premises, adult gaming centres and family entertainment centres and members clubs. Alcohol licensed premises, including pubs, are also able to offer two Category C and D gaming machines in reliance on their alcohol licence, or more if they apply to the licensing authority. Where casinos whose licence originates in the Gaming Act 1968 meet the requirements of a 2005 Act Small casino, including for size and non-gambling space, they will be eligible for the same gaming machine allowance and we will align fees and mandatory premises licence conditions as appropriate.
There were mixed views on casinos’ ability to hold multiple licences at the same physical location. More respondents were opposed than in favour, but this largely stemmed from those who are opposed to any increases in the supply of gambling opportunities, rather than operators and industry stakeholders. It was proposed that the requirements would form part of a new regime that operators would have the option of moving onto, taking up a new gaming machine entitlement under the new rules. Subsequent discussions with industry have indicated that this would equate to the majority of casinos in practice.
The Review has not seen data which robustly quantifies behavioural nudges or barriers in the online gambling sector, so it is difficult to estimate how much they may drive consumer spending/ revenue that would not have otherwise happened, or the impact of any changes. For instance, a recent audit of online operator platforms by the Behavioural Insights team found 8 of the top 10 GB operators stated a minimum account balance was required for customers to withdraw their funds. This approach assumes that those using self-exclusion facilities do so to manage harmful gambling, as opposed to things like marketing and / or data processing preferences. Several specific areas of concern were identified in responses, including how the design of online gambling platforms (the so called ‘choice architecture’) can make it difficult to access tools or information intended to support consumers to make informed and safer decisions about their gambling.
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With a background in business analytics and certification in responsible gambling practices, he brings a data-driven, compliance-focused approach to every review. Illegal activities encompass unlicensed offshore sites targeting UK players, private betting operations, and any gambling services provided to under-18 individuals. Legal and illegal gambling activities in the UK are clearly defined by the law to regulate the industry and protect players.
Calculation of table gambling areas and non-gambling areas
In April 2019, the Commission strengthened the rules, requiring online operators to verify a customer’s age and identity before allowing them to deposit funds, play free-to-play games or gamble with their own or bonus funds. The new requirements will include provisions to ensure any consumer data is effectively protected and only used for the purposes of harm prevention. The intention is for this to be done through the Gambling Commission updating the licence conditions and codes of practice on all remote operators, but if necessary we would consider legislation. Work to commence real-world trials of a SCV solution has been progressing alongside this Review through the ICO’s sandbox process and the sharing of real high-risk player data has now started. Given the privacy implications for the majority who gamble with no ill effect, we do not think the creation of such a system including a national database of all gamblers (even if anonymised) is justified at this time.
In 2019, members of the Bacta trade association decided to take voluntary action to ban under-16s from playing ‘cash-out’ slot-style machines while unaccompanied by an adult on their premises. Currently, Category D machines have no age restrictions nor area restrictions in licensed/permitted premises. In order to help customers make informed decisions and keep track of spending, the government considers that the display of session time and session net position (£) should be mandatory on machines that accept direct cashless payments. This will include assessing the role of session limits across Category B and C machines alongside safer gambling tools. Default limits for machines in betting shops are £150 being inserted as credit since session start or 20 minutes of machine play (both leading to a 30 second cooling-off period when triggered). However, there is no uniformity across land-based machines as a whole.
This relates to ensuring that casinos which share the same building, or adjoin or are adjacent to another casino, are wholly distinct and separate from one another. ” and “can the premises only be accessed from any other gambling premises? However, there must be some degree of physical separation between the licensed premises in order for the operation of these separate licences to be permitted. Further detail on the different gambling and table gaming space requirements are outlined later in this chapter. Ensuring that regulation of land-based and online sectors is more equitable will assist recovery and enable the sector to remain viable. Evidence suggests that this can make customers who have secured a machine reluctant to take a break as they may be unable to play again.
