Regulatory Influencer: UK Gambling Market Heralds New Era of Regulation

In April 2023, under the Sunak Conservative government, Lucy Frazer, the then secretary of state for culture, media and sport, finally published the long-awaited gambling white paper, ushering in a new era of regulation in the UK gambling market. What has followed is a series of extensive consultations, launched by both the Department for Digital, Culture, Media & Sport (DCMS) and the UK Gambling Commission, on a slew of proposals touching on key issues such as social responsibility, marketing and technical standards, pertaining to both online and land-based operations.

The authorities have taken their fair share of time in finalising those proposals and it was only during the second half of 2024 that some of them took effect. 

2025 is the year when a lot more of those white paper proposals will enter into force.

The Bigger Picture

The principal legislation governing gambling in UK is the Gambling Act 2005, with the Gambling Commission sitting at the helm of regulating the industry. To say that the gambling landscape has changed significantly during the last couple of decades would be an understatement. 

Advancements in information technology have enabled gambling businesses to provide services to their customers that they can engage with from almost anywhere and at any time of day or night. With the advent of the internet, there have been major advancements and innovations to the way in which the gambling industry operates, be it in the form of new game offerings, new verticals or new payment methods. And like every other development, gambling innovations have brought with them increased risks to players, both in terms of addiction issues and data privacy. Similarly, land-based gambling also finds itself in a glaringly different place.

The white paper aims to ensure that gambling regulation meets the current and upcoming challenges, while also seizing the accompanying opportunities. Hence the title, “High stakes: gambling reform for the digital age”. The government has addressed a host of issues pertaining to online protection of players, marketing, dispute resolution and consumer redressal, protection of minors, land-based operations and enhanced powers and resources for the Gambling Commission. 

Since the publishing of the white paper, the DCMS has consulted on the following proposals:

• Measures relating to the land-based gambling sector (July 2023)
• Proposal to introduce a maximum limit for online slot games (July 2023)
• Requirement for a statutory levy on gambling operators (October 2023)

Simultaneously, the Gambling Commission has consulted on a raft of proposals introducing amendments to the Licence Conditions and Codes of Practice (LCCP) and technical standards:

• Changes to Licence Conditions and Codes of Practice (LCCP), Remote Gambling and Software Technical Standards (RTS), and arrangements for Regulatory Panels (July 2023)
• Second set of proposed changes to Licence Conditions and Codes of Practice  and Remote Gambling and Software Technical Standards (November 2023)
• Changes to financial penalties and key event reporting (December 2023)
• Changes to the Gaming Machine Technical Standards (GMTS), Gaming Machine Testing Strategy and Licence Conditions and Codes of Practice (January 2025)
• Proposals for clarifying the definition of “deposit limits” and other financial limits in Remote Gambling and Software Technical Standards (March 2025)

Why Should You Care?

The changes proposed by the government and the Gambling Commission via their respective consultations have imposed numerous requirements on gambling businesses. Although some of those requirements already came into force during the back-end of last year, a lot more of them are due to take effect this year. Therefore, it is important for gambling businesses to incorporate them into their operations as and when they happen, to ensure they can remain compliant, thereby avoiding enforcement actions, but also giving them the competitive advantage.

The following requirements are already effective:

• Requirement to submit quarterly regulatory returns (July 1, 2024): Licence condition 15.3.1, requiring all licensees to submit regulatory returns on a quarterly basis, which came into effect on July 1, 2024. Within 28 days of the end of each quarterly period licensees must submit an accurate regulatory return to the commission. The submission of the first set of regulatory returns following the new requirement was due by October  31, 2024.
• Requirement for financial vulnerability checks (August 30, 2024): Social Responsibility (SR) Code 3.4.4, which is applicable to all remote gambling licensees (except for remote lottery licence holders who do not provide facilities for participation in instant win or high frequency lotteries, remote gaming machine technical licensees, gambling software licensees, remote betting intermediary (trading rooms only), remote general betting limited licensees, and ancillary licensees), requires operators to conduct light-touch financial vulnerability checks for those customers with a net deposit of more than £500 in a rolling 30-day period. Since February 28, 2025, the relevant threshold has been reduced to net deposits of £150 in a rolling 30-day period.
• Strengthened age verification in gambling premises (August 30, 2024): Amendments to SR Code 3.2 remove the exemption from carrying out age verification test purchasing for Category A and B licensees, including betting, bingo, family entertainment centres (FECs) and adult gaming centres (AGCs).
• Extending personal management licence requirements (November 29, 2024):  Personal management licence requirements have been extended to the CEO, managing director or equivalent, under Licence Condition 1.2.1 (2)(a), the person responsible or chairing the board of an organisation under Condition 1.2.1(2)(b) and the head of the licensee’s anti-money laundering and counter-terrorist financing function.
• Changes to remote technical standards (RTS) (January 17, 2025): The new game design requirements have been introduced to the remote gambling and software technical standards (RTS). The requirements pertain to provisions such as bans on turbo, quick spin and slam stops, which enable a customer to reduce the time until the game result is given; a minimum five-second spin speed for non-slot titles; prohibition on autoplay for all online gambling products; requirements for all casino games to not "celebrate" a return that is less than or equal to the total stake gambled; requirement for elapsed time and net position to be provided for all casino products other than peer-to peer poker.

The following requirements take effect this year:

• Online slots stake limits: The £5 stake limit for online slots, applicable to people aged 25 and over, takes effect on April 9, 2025, while the £2 stake limit, applicable to people aged 18-24 years, will be effective from May 21, 2025.
• Improved customer choice on direct marketing (May 1, 2025): A new SR Code 5.1.12 will be introduced, requiring licensees to provide customers with options to opt-in to direct marketing on a per-product and per-channel basis.
• New rules for customer empowerment and operator transparency (October 31, 2025): Operators will be required to inform their customers about setting a financial limit prior to them making their first deposit, and allowing them to review or change those limits at any point thereafter. Additionally, operators shall remind their customers to review their account and transaction information, every six months. Another requirement will mandate operators to actively remind those customers whose funds are not protected in the event of insolvency. The level of protection must be described as either “not protected – no segregation”, “not protected – segregation of customer funds”, “medium protection” or “high protection”.
• A statutory levy on gross gambling yield: In November 2024, the UK government announced plans to impose a levy of up to 1.1 percent on gross gambling yield, with the levy to vary between 0.1 and 1.1 percent depending on the gambling sector. The statutory levy replaces the current voluntary levy, by amending the SR Code 3.1.1. The statutory requirement takes effect on April 6, with the first payments being due on October 1, 2025.
• New rules increasing the safety and simplicity of consumer promotional offers(December 19, 2025): The commission has announced the following new rules to increase the safety of consumer promotional offers:
  • Mixed product promotion ban: Gambling businesses will be banned from offering potentially harmful offers involving consumers having to carry out two or more types of gambling, such as betting and playing slots.
  • Limiting bonus wagering requirements to ten: The requirements will limit the number of times bonus funds must be re-staked before the consumer can withdraw winnings from the bonus. Limiting the wagering requirement to ten shall reduce the likelihood of harm, complexity and improve the transparency, while maintaining consumer choice.

In addition to the aforementioned requirements, in February 2025, the Gambling Commission published an update on the ongoing pilot of financial risk assessments, reiterating that the assessments have been proposed to identify and support high-spending online gambling customers exhibiting signs of financial distress. These risk assessments differ from the “light-touch” financial vulnerability checks, which have been in force since August 30, 2024.

The UK is widely seen as a world leader in the oversight of gambling. Therefore, the Gambling Commission continues to ensure strict compliance with the regulatory framework, placing prime importance on safer gambling in this digital era. Non-compliance by operators has invited the commission’s unmitigated attention, as can be observed in its recent enforcement actions against social responsibility and anti-money laundering breaches by various licensees (as many as five financial penalties, totalling £3.5m have been handed out in 2025, at the time of writing). Keeping up with these developments can go a long way in helping gambling businesses ensure compliance with these extensive requirements and provide their customers with the best offerings, while safeguarding them against any gambling-related harm.

Key actions to remain compliant?

 To navigate the evolving UK landscape, gambling businesses should consider taking the following proactive steps:

• Review Financial Risk Procedures - Ensure your systems can comply with the requirements and thresholds of the new financial vulnerability checks. Start by auditing current customer risk monitoring processes.
• Prepare for statutory levy - With the voluntary system being replaced, assess your financial obligations and budget accordingly for the mandatory levy. Engage with legal and compliance teams to understand potential cost implications.
• Ensure compliance with the technical standards - With additional provisions now stipulated under the remote gambling and software technical standards, assess your games and other gambling software to incorporate the changes and comply with the testing requirements.
• Implement responsible gambling controls - Adjust stake limits for online slots to reflect the £2 cap for younger players and £5 for older groups. Strengthen age verification processes for both online and land-based gambling.
• Enhance transparency and customer communication - Update terms and conditions, marketing strategies and player protection measures to align with new advertising and direct marketing opt-in requirements based on the product and the channel.
• Quarterly regulatory reporting - Ensure internal teams and reporting structures are ready to meet new data submission obligations. Conduct internal reviews to identify any potential compliance gaps before they become enforcement risks.

By implementing such measures, operators can stay ahead of regulatory changes, reduce risk exposure and strengthen player protections in an increasingly scrutinised market. Proactive adaptation will support both business sustainability and a responsible gambling environment.