Types of faults and how to identify them

 We are not concerned with issues that affect the user experience or playability of a game, issues that do not affect the fairness/return to player (RTP) of games should instead be reported under the existing 'any of matters of impact' event.

 Whilst not exhaustive, the list below gives some common examples of faults which may impact on the RTP of remote games:

* incorrect maths design or software flaw resulting in a different prize frequency or amount than intended/advertised
* implementation issue, such as a configuration parameter or build process, that causes the game to operate in a different way to the design or rules of the game
* software vulnerability exploited by a player, player hacks into the game
* incorrect prizes displayed.

###  Game faults can be identified in a variety of ways:

* post implementation reviews of newly installed software identifies an error in the game-s configuration (if this is identified and corrected before the game was in live operation then reporting would not be required)
* proactively identified by the operator during required game performance monitoring
* investigation of player complaints or operator feedback results in a fault being discovered
* updates to games or development of new games might result in developers discovering errors in the existing code base which affect RTP/fairness.


 We do not expect every suspected game fault to be reported to us straight away. However once a fault, resulting in an under or overpaying game is confirmed, reporting would be required within five days.  Confirmation of a game fault would usually coincide with an operator-s decision to disable the faulty game from operation. If the game was not disabled pending the outcome of the investigation it must be taken down whilst the fault is fixed and retested.

 We understand that the time involved to fully ascertain all the particulars of an error can vary depending on the complexity, number of parties involved and the length of time the error existed. This should not hold up the reporting of the incident. You must provide as much information as is known at the time of reporting outlining any areas where further investigation is required to confirm more details.

 All RTP faults should be reported. A number of ‘small- faults may indicate a wider systematic issue within an operator-s or test house-s processes. This would not be identified if only ‘significant- faults are reported.

 A game under or overpayment issue, even an apparently minor one, represents a failure in design, build, testing or deployment of a gambling product and is therefore of interest to us.

 Prompt identification, game deactivation and notification of faults increases confidence that you are properly monitoring your products to ensure they are operating in a fair and open way.

 Detecting minor variances using your monitoring processes would demonstrate you have very effective processes in place.


 You should provide sufficient information to describe the incident that has occurred, how it was identified, the cause, number of players/financial amount involved and the remedial action planned and performed.

 When submitting your report include:

* the nature of the incident and how it was detected
* dates when the game/version was released, when the fault occurred, how long it was active for
* how the fault occurred and how it passed internal and external testing
* the amount of players affected, including the financial amount along with the calculations used to determine this
* difference in expected/actual RTP due to the fault
* if a B2B is reporting, how many B2Cs were offering the game and whether all were affected
* what remedial action has/will be taken - both to prevent a similar reoccurrence and to remedy any fairness issues for consumers.


Considerations regarding how to remedy a fault

 You should not benefit from a fault. You should endeavour to return the money to customers in a timely manner. If the individuals affected cannot be identified, you are encouraged to make efforts to repay the money to the group of consumers most likely to contain those affected. The money should be repaid in a way that would not incentivise additional gambling and is not based on a minimum-spend requirement or threshold.

 We expect consumers to be informed of steps taken and the reason for this only after all the money has been returned, and not during this period. This will avoid operators being able to benefit through promotion or advertising, which is unacceptable.

 If you cannot return the money to consumers in line with these aims, you should divest yourselves of the profits and this should be paid to a responsible gambling charity.


Calculating the financial amount involved

 The first step is to establish the financial amount and number of players affected by the fault. The complexity of this will vary depending on the nature of the fault, for example a one-off jackpot failure will have one player and one amount involved. Whereas a more subtle design or game fault that reduces RTP might affect numerous prizes and players depending on how long it was in operation for.

 The default and expected remedy is to directly reimburse the affected players.

 The amount to reimburse would either be the exact amount (if the transactions are available to calculate) or if the transactions required are not available then the approximate amount based on the formula (turnover generated during the fault period times the defective RTP%).

###  Approach A:

 Calculate using the exact transactions. For example, if a jackpot should have paid X but it instead paid a quarter of X, the amount involved and players affected is easy to determine.

###  Approach B:

 Where exact transactions or hits aren-t available, or are too difficult to calculate, then the following formula is typically used to calculate the theoretical difference between the expected and actual results.

 For example, if a frequently occurring prize should have paid £500 but instead paid £100 or if a prize wasn-t being awarded at all due to a fault then determine how much that discrepancy reduces the overall RTP (each prize contributes an exact portion of the overall RTP).

 If it was 0.5% then multiply that times the amount of turnover (£) which occurred under fault conditions. That is the amount of underpaid winnings.

 We recognise that each game fault could be unique and how you deal with reimbursing players might change on a case by case basis. Whilst every attempt should be exhausted to directly reimburse affected players, if this is not possible any alternative should take into account the following principles:

* You should not benefit from a fault. The effort of reimbursing funds should itself act as a disincentive for producing faulty games.
* The affected consumers should be treated fairly and with priority.
* Adequate disclosure accompanies any approach.


 !  **Warning  This reporting requirement applies to holders of all operating licences.**  Breaches must be reported as key events as soon as reasonably practicable and in any event within five working days of becoming aware of the event-s occurrence.

 All key events are to be reported to us via the key event part of the  [eServices digital service (opens in a new tab)](https://secure.gamblingcommission.gov.uk/EServices/Account/Login?ReturnUrl=%2feservices)  .

 You must select the following type when entering this key event on eServices:

* Key Event: Gaming system fault.

 [Previous page
 Protecting customer funds](/licensees-and-businesses/guide/page/protecting-customer-funds)

---

 Last updated: 13 April 2021

 Show updates to this content  No changes to show.


Notify the Commission of a change of corporate control

>  Changes of control must be reported as a  [key event](/licensees-and-businesses/guide/key-events-for-operators)  as soon as possible and not later than within 5 working days.
>
>

 Within 5 weeks of the change occurring you must either surrender the licence or apply for the licence to continue to have effect or it will be revoked.

 If you want to apply for the licence to continue to have effect, you must complete a  [Change of Corporate Control form](#nCJsRldlCoVu39KHX42se)  , and pay the appropriate fee. You must email the completed form and supporting documents to  [licensing@gamblingcommission.gov.uk](mailto:licensing@gamblingcommission.gov.uk)  . Do not post them to us and do not email them to a Licensing team member email address.

 Incoming individuals who have or are expected to become controller of the licensed operator, if not already approved by the Commission will be required to submit an  [Annex A](/licensees-and-businesses/guide/annex-a-declaration)  or  [Personal Management Licence](/licensees-and-businesses/guide/personal-management-licence)  (PML) application.

 Make sure you read the guidance notes on this page before you start to fill out the form.

 Change of corporate control applications typically take around 12 weeks to process, providing full information is submitted.

 [Previous page
 Change of corporate control](/licensees-and-businesses/guide/change-of-corporate-control)  [Next page
 What you need to send us with your application](/licensees-and-businesses/guide/page/what-you-need-to-send-us-with-your-application)

---

 Last updated: 23 December 2022

 Show updates to this content  Formatting changes


* [Remote linked licences gaming machine technical](/licensees-and-businesses/licences-and-fees/remote-linked-licences-gaming-machine-technical)
* [Non-remote linked licences gaming machine technical](/licensees-and-businesses/licences-and-fees/non-remote-linked-licences-gaming-machine-technical)
* [Remote linked licences gambling software](/licensees-and-businesses/licences-and-fees/remote-linked-licences-gambling-software)
* [Non-remote linked licences gambling software](/licensees-and-businesses/licences-and-fees/non-remote-linked-licences-gambling-software)
* [Remote external lottery manager operating licence](/licensees-and-businesses/licences-and-fees/remote-external-lottery-manager-operating-licence)
* [Non-remote external lottery manager operating licence](/licensees-and-businesses/licences-and-fees/non-remote-external-lottery-manager-operating-licence)
* [Remote society lottery licence](/licensees-and-businesses/licences-and-fees/remote-society-lottery-licence)
* [Non-remote society lottery operating licence](/licensees-and-businesses/licences-and-fees/non-remote-society-lottery-operating-licence)
* [Remote gaming machine technical – software operating licence](/licensees-and-businesses/licences-and-fees/remote-gaming-machine-technical-software-operating-licence)
* [Remote gaming machine technical – supplier operating licence](/licensees-and-businesses/licences-and-fees/remote-gaming-machine-technical-supplier-licence)
* [Remote gaming machine technical - full licence](/licensees-and-businesses/licences-and-fees/remote-gaming-machine-technical-full-licence)
* [Remote betting host real events licence](/licensees-and-businesses/licences-and-fees/remote-betting-host-real-events-licence)
* [Remote betting host virtual events licence](/licensees-and-businesses/licences-and-fees/remote-betting-host-virtual-events-licence)
* [Remote general betting limited licence](/licensees-and-businesses/licences-and-fees/remote-general-betting-limited-licence)
* [Non-remote 2005 Act casino operating licence](/licensees-and-businesses/licences-and-fees/non-remote-2005-act-casino-operating-licence)
* [Remote casino game host operating licence](/licensees-and-businesses/licences-and-fees/remote-casino-game-host-operating-licence)
* [Non-remote gambling software licence](/licensees-and-businesses/licences-and-fees/non-remote-gambling-software-licence)
* [Non-remote gaming machine technical - full licence](/licensees-and-businesses/licences-and-fees/non-remote-gaming-machine-technical-full-licence)
* [Non-remote gaming machine technical – software operating licence](/licensees-and-businesses/licences-and-fees/non-remote-gaming-machine-technical-software-operating-licence)
* [Non-remote gaming machine technical – supplier operating licence](/licensees-and-businesses/licences-and-fees/non-remote-gaming-machine-technical-supplier-licence)
* [Remote gambling software licence](/licensees-and-businesses/licences-and-fees/remote-gambling-software-licence)
* [Remote casino operating licence](/licensees-and-businesses/licences-and-fees/remote-casino-operating-licence)
* [Non-remote 1968 Act casino operating licence](/licensees-and-businesses/licences-and-fees/non-remote-1968-act-casino-operating-licence)
* [Remote bingo game host operating licence](/licensees-and-businesses/licences-and-fees/remote-bingo-game-host-operating-licence)
* [Remote bingo operating licence](/licensees-and-businesses/licences-and-fees/remote-bingo)
* [Non-remote bingo operating licence](/licensees-and-businesses/licences-and-fees/non-remote-bingo)
* [Remote pool betting licence](/licensees-and-businesses/licences-and-fees/remote-pool-betting-licence)
* [Remote betting intermediary trading rooms only licence](/licensees-and-businesses/licences-and-fees/remote-betting-intermediary-trading-rooms-operating-licence)
* [Remote betting intermediary operating licence](/licensees-and-businesses/licences-and-fees/remote-betting-intermediary-operating-licence)
* [Remote general betting standard virtual events licence](/licensees-and-businesses/licences-and-fees/remote-general-betting-standard-virtual-events-licence)
* [Remote general betting standard real events licence](/licensees-and-businesses/licences-and-fees/remote-general-betting-standard-real-events-licence)
* [Non-remote pool betting operating licence](/licensees-and-businesses/licences-and-fees/non-remote-pool-betting-operating-licence)
* [Non-remote betting intermediary licence](/licensees-and-businesses/licences-and-fees/non-remote-betting-intermediary-operating-licence)
* [Non-remote general betting limited operating licence](/licensees-and-businesses/licences-and-fees/non-remote-general-betting-limited-operating-licence)
* [Non-remote general betting standard operating licence](/licensees-and-businesses/licences-and-fees/non-remote-general-betting-standard-operating-licence)
* [Family entertainment centre](/licensees-and-businesses/licences-and-fees/family-entertainment-centre)
* [Adult gaming centre](/licensees-and-businesses/licences-and-fees/adult-gaming-centre)


 Applies to:

 All non-remote casino, adult gaming centre, bingo, family entertainment centre, betting and remote betting intermediary (trading room only) licences, except non-remote general betting (limited) and betting intermediary licences.

 **Social responsibility code**  Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator-s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.

1. Licensees must assess the local risks to the licensing objectives posed by the provision of gambling facilities at each of their premises, and have policies, procedures and control measures to mitigate those risks. In making risk assessments, licensees must take into account relevant matters identified in the licensing authority-s statement of licensing policy  [1](#1011-1)  .
2. Licensees must review (and update as necessary) their local risk assessments:

- to take account of significant changes in local circumstances, including those identified in a licensing authority-s statement of licensing policy;
- when there are significant changes at a licensee-s premises that may affect their mitigation of local risks;
- when applying for a variation of a premises licence; and
- in any case, undertake a local risk assessment when applying for a new premises licence.
##  References


1  This is the statement of licensing policy under the Gambling Act 2005.


 Applies to:

 All non-remote casino, adult gaming centre, bingo, family entertainment centre, betting and remote betting intermediary (trading room only) licences, except non-remote general betting (limited) and betting intermediary licences

 **Ordinary code**  These do not have the status of operator licence conditions but set out good practice. Operators may adopt alternative approaches to those set out in ordinary code provisions if they have actively taken account of the ordinary code provision and can demonstrate that an alternative approach is reasonable in the operator's particular circumstances; or that to take an alternative approach would be acting in a similarly effective manner. Ordinary codes of practice are admissible in evidence in criminal or civil proceedings and must be taken into account in any case in which the court or tribunal think them relevant, and by the Commission in the exercise of its functions; any departure from ordinary code provisions by an operator may be taken into account by the Commission on a licence review, but cannot lead to imposition of a financial penalty.

1. Licensees should share their risk assessment with licensing authorities when applying for a premises licence or applying for a variation to existing licensed premises, or otherwise on request.


 You can apply for an operating licence using the apply for an operating licence service.

 You will need to pay a fee to submit your application. You can read about the  [fees you need to pay and when](/licensees-and-businesses/page/fees-you-need-to-pay-and-when)  and  [how to pay your fees](/licensees-and-businesses/page/paying-fees)  .

##  Apply online

 [Previous page
 Operating licences](/licensees-and-businesses/guide/operating-licences)  [Next page
 How we assess operating licence applications](/licensees-and-businesses/guide/page/how-we-assess-operating-licence-applications)

---

 Last updated: 7 June 2021

 Show updates to this content  No changes to show.


 Apply for an operating licence online.

 [Start](/service/apply-for-an-operating-licence)


Appeal against a decision made about your licence or application

 If we make a decision about your licence or an application for a licence, we will let you know the reasons why and the steps you can take to appeal if you are unhappy with our decision.

 You can appeal against a decision about your gambling licence if:

* your application for a licence is turned down
* your licence is suspended or revoked
* you receive a fine or warning
* there are changes to your licence conditions.

 You normally have to  [pay a fee to appeal (opens in a new tab)](https://www.gov.uk/guidance/gambling-licence-decisions-appeal-to-a-tribunal#fee)  . This fee will be refunded if you win your case.

 If we have given you a final decision and you are not satisfied with it, you can  [appeal to the HM Courts & Tribunals Service (opens in a new tab)](https://www.gov.uk/guidance/gambling-licence-decisions-appeal-to-a-tribunal)  , which is an independent body.

 [Previous page
 How we assess operating licence applications](/licensees-and-businesses/guide/page/how-we-assess-operating-licence-applications)

---

 Last updated: 7 June 2021

 Show updates to this content  No changes to show.


5.1.7 - Compliance with advertising codes (lotteries)

 Applies to:

 All lottery licences

 **Social responsibility code**  Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator-s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.

1. All marketing of gambling products and services must be undertaken in a socially responsible manner.
2. In particular, Licensees must comply with the advertising codes of practice issued by the Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP) as applicable. For media not explicitly covered, licensees should have regard to the principles included in these codes of practice as if they were explicitly covered.


 On  [Pool betting licensing arrangements](/licensees-and-businesses/guide/pool-betting-licensing-arrangements)  we acknowledged that operators are using a number of models to provide facilities for pool betting, or what at first sight appears to be pool betting, to consumers in Great Britain (GB).

 Dependent upon the arrangements in place some betting contracts are struck in reliance of a pool betting licence whilst others are struck in reliance of a general betting standard licence.

>  Transparency is key in protecting the interests of consumers.
>
>

 Information must be readily accessible and meaningful to allow consumers to understand the products they are using and we expect operators to provide clear, accessible and concise information on their arrangements for dispute resolution and redress.

 Specifically, in relation to pool betting or what at first sight appears to be pool betting, our expectation is that customers are provided with information that identifies:

* who their betting contract is with
* who is responsible for paying out any winnings and where their funds are being held
* how to make a complaint in relation to a bet
* rules in relation to bet settlement and deduction levels (for more information see code provisions 4.2.6 and 4.2.9)
* on-course, through a public display system, relevant information such as units staked on open markets, minimum stakes and winning dividends (for more information on our expectations here please see on-course pool betting display requirements.

---

 Last updated: 26 February 2021

 Show updates to this content  No changes to show.


3.3.1 - Responsible gambling information

 Applies to:

 All licences, except gaming machine technical, gambling software, host, ancillary remote bingo, ancillary remote casino and remote betting (remote platform) licences

 **Social responsibility code**  Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator-s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.

1. Licensees must make information readily available to their customers on how to gamble responsibly and how to access information about, and help in respect of, problem gambling.
2. The information must cover:

- any measures provided by the licensee to help individuals monitor or control their gambling, such as restricting the duration of a gambling session or the amount of money they can spend
- timers or other forms of reminders or ‘reality checks- where available
- self-exclusion options
- information about the availability of further help or advice.

- The information must be directed to all customers whether or not licensees also make available material which is directed specifically at customers who may be ‘problem gamblers-.
- For gambling premises, information must be available in all areas where gambling facilities are provided and adjacent to ATMs. Information must be displayed prominently using methods appropriate to the size and layout of the premises. These methods may include the use of posters, the provision of information on gambling products, or the use of screens or other facilities in the gambling premises. Information must also be available in a form that may be taken away and may also be made available through the use of links to be accessed online or using smart technology. Licensees must take all reasonable steps to ensure that this information is also readily accessible in locations which enable the customer to obtain it discreetly.


How to calculate your Gross Gambling Yield (GGY) for pool betting

 On  [Pool betting licensing arrangements](/licensees-and-businesses/guide/pool-betting-licensing-arrangements)  we acknowledge that operators are using a number of models to provide facilities for pool betting, or what at first sight appears to be pool betting, to consumers in Great Britain (GB).

 Dependent upon the arrangements in place some betting contracts are struck in reliance of a pool betting licence whilst others are struck in reliance of a general betting standard licence.

 Whenever an operator accepts a bet in reliance of its own licence, the Gross Gambling Yield (GGY) must be recorded within the respective  [regulatory return](/guidance/regulatory-returns-guidance)  and will be considered for fee category purposes. A Commission licence is relied upon if the customer involved in your bet is located in GB or any part of your remote gambling equipment is located here.

 Whenever a licensed operator makes or accepts a bet on behalf of another licensee it is the other licensee (the actual counterparty to the bet) which must record and consider the GGY for regulatory return and fee category purposes.

 Operators providing facilities by non-remote and remote means must ensure that the GGY is recorded against the appropriate licences. As a reminder, remote gambling means gambling in which persons participate by use of remote communication. If participation isn-t by use of remote communication then its non-remote gambling.

 We expect all licensees to regularly review their levels of GGY to ensure they are located within the correct fee category. You must submit a  [licence variation](/licensees-and-businesses/guide/make-changes-to-your-operating-licence)  if your fee category needs to change. Applications to vary an operating licence can take up to eight weeks to process.

 Loyalty schemes such as ‘VIP cash back- or ‘rebates- should not be counted when calculating GGY. Such payments do not form part of a gambling transaction and are considered to be part of the costs of conducting business such as payments to affiliates for the acquisition of players.

##  For example

---

 Last updated: 27 October 2022

 Show updates to this content  'regulatory return' link corrected following audit.


A customer with a 5% rebate on their stakes places £100 of bets into a pool. The total stakes into the pool are £1000 and the deduction level is 20%. GGY is £200 (20% of £1000) and  **not**  £195 (20% of £100 – 5% of £100).  The £5 the operator returns to the customer as a rebate is not deducted from GGY and (on the basis it is now cash) if it is wagered in another pool it would count towards amount staked in that pool.


On-course pool betting display requirement

 The purpose of this guidance is to provide additional clarity with regards to the requirements laid out in  [social responsibility code provision 4.2.10](/licensees-and-businesses/lccp/condition/4-2-10-pool-betting)  . Our primary goal is to maintain transparency for customers.

 As a minimum, we want pool betting customers to understand what they could win in the case of win and place bets and what is available to be won in the case of combination bets. Whilst this code provision relates to the display of information for those betting on-course, these principles of transparency should apply equally, where practicable, to other pool betting mediums such as licensed betting premises and online.

 We would expect that the calculation used to determine potential dividend returns relies upon the known stakes on each selection at the relevant point in time. We accept these potential dividends are for illustrative purposes and that their accuracy will increase as the pool grows in size and the race approaches its start time.

 When considering the scope of the display requirements for each pool operated our expectation focuses on ensuring the display of information for races taking place at the relevant racetrack. Thereafter, licensees offering pools on races taking place at other venues should make this information available in at least one place and this could, for example, be achieved through a looping screen(s) that prioritises information based upon upcoming race times and levels of customer interest.

 Combination bets include bets on a single race whereby multiple selections are required (eg correct finishing orders) and bets that require selections across multiple races.

 When referring to unit stakes on all types of combination bets offered we are referring to the total units staked on a pool net of deductions. This allows the customer to simply understand what is available to be won and avoids the need for them to access relevant deduction information to make their own calculations.

>  Licensees should be aware that they must already publish rules relevant to the deduction levels, expressed as a percentage, for each available pool. Whilst not a licence condition requirement at this time, a best practice approach would see deductions rates transparently displayed at each point of sale.
>
>

---

 Last updated: 26 February 2021

 Show updates to this content  No changes to show.


 Applies to:

 All remote casino, bingo and betting licences other than ancillary, host, remote betting intermediary (trading room only), remote general betting (limited) and remote general betting (standard) (remote platform) licences

>  [Read additional guidance on the technical requirements](/licensees-and-businesses/page/display-of-licensed-status-technical-requirements)  contained within this section.
>
>

1. Licensees providing facilities for remote gambling must display on every screen from which customers are able to access gambling facilities provided in reliance on this licence:
	1. a statement that they are licensed and regulated by the Gambling Commission;
	2. their account number; and
	3. a link (which will be supplied by the Commission) to their current licensed status as recorded on the Commission-s website.
2. Such statement, account number and link must be in the format, provided by the means, and contain the information from time to time specified by the Commission in its technical standards applicable to the kind of facilities for gambling provided in accordance with this licence or otherwise notified to licensees for the purposes of this condition.
3. Licensees may also display on screens accessible from Great Britain information about licences or other permissions they hold from regulators in, or by virtue of the laws of, jurisdictions outside Great Britain provided it is made plain on those screens that the licensee provides facilities for gambling to persons in Great Britain in reliance on their Gambling Commission licence(s).


 Since the Act came into force we have received many enquires from both the traditional bingo industry and new or potential entrants around new game formats proposed to be offered as bingo in bingo licensed premises. We have also had correspondance with The Bingo Association about how bingo is defined.  Although only the courts can provide a definitive interpretation of the law, we think it helpful to publish this advice setting out our views on the essential requirements for a gambling product recognised as bingo.

 Under  [section 291 of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/291)  , as well as providing bingo, holders of bingo premises licences may also offer facilities for prize gaming  [1](#1)  as long as the gambling complies with the conditions attached to all bingo operating licences by the Gambling Act 2005 (Operating Licence Conditions) Regulations 2007 (SI 2007 No. 2257) which impose limits on both participation fees and prizes.

 Although bingo is traditonally played for a prize pool comprising players' stakes less participation fees, it may also be played for a set of prizes. These prizes are not determined by the number of people playing or the amount paid or raised by the game, therefore they are in a format which meets the definition of 'prize gaming'. This type of bingo format is often referred to as 'prize bingo', especially when played for modest prizes.

 Bingo of this type also meets the essential following requirements and may be offered in bingo licensed premises without relying on the specific permission contained in  [section 291 of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/291)  . It also does not have to comply with the participation fee and prize limits laid down in the 2007 Regulations.

 [Previous page
 How bingo is defined](/licensees-and-businesses/guide/how-bingo-is-defined)  [Next page
 The fundamental principles of bingo](/licensees-and-businesses/guide/page/fundamental-principles-of-bingo)

---

 Last updated: 22 February 2021

 Show updates to this content  No changes to show.


 In June 2009 the Commission published a document entitled Key characteristics of bingo, which was particularly relevant to bingo played on bingo machines. That information, as updated and revised in the light of more recent discussions with such stakeholders, is reproduced at  [Annex B](/licensees-and-businesses/guide/page/annex-b-key-characteristics-of-bingo-revised-january-2014)  .

 We have set separate  [technical standards](/licensees-and-businesses/page/bingo-and-casino-technical-requirements)  and equipment requirements for remote and non-remote bingo respectively to which operators must comply as a condition of their licence.

 [Previous page
 The fundamental principles of bingo](/licensees-and-businesses/guide/page/fundamental-principles-of-bingo)  [Next page
 Annex A: Banker-s games and equal chance gaming - January 2014](/licensees-and-businesses/guide/page/annex-a-bankers-games-and-equal-chance-gaming)

---

 Last updated: 7 June 2021

 Show updates to this content  No changes to show.


Annex A: Banker-s games and equal chance gaming - January 2014

###  A.1

 Under  [section 7(2) of the Gambling Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/7)  , bingo must always be ‘equal chance gaming- in order to distinguish it from casino gaming (‘In this Act, ‘casino game- means a game of chance which is not equal chance gaming-).

###  A.2

 [Section 8(1) (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/8)  says that gaming is ‘equal chance gaming- if:

* it does not involve playing or staking against a bank and
* the chances are equally favourable to all participants.

###  A.3

 It is important to note that these are two separate, cumulative, requirements. If a game either involves a bank or is one in which the chances as between all those playing are unequal then it is not ‘equal chance gaming- and cannot be offered as bingo.

###  A.4

 This note seeks to address the meaning in this context of playing or staking against a bank.

###  A.5

 A good starting point is the definition given in ‘The Law of Gambling- edited by Smith and Monkcom which says that in essence a game involves a bank where one player plays against all the others, winning from them the stakes  [2](#2)  that they lose and paying out to them the stakes that they win.

###  A.6

 The most obvious types of banker-s game are those (such as roulette or blackjack) which contain an inbuilt advantage to whoever is the banker (a house or banker-s edge). The players- payments are made up entirely of stakes: the operator does not need to decide what deductions to make from stakes and never makes any such deductions.

###  A.7

 The position is however complicated by the fact that, even if the bank does not have an edge, the game remains a banker-s game (and therefore cannot be played as bingo) if the operator acts as the bank in the sense at paragraph 2.

###  A.8

 As a consequence, in deciding whether or not something offered as bingo is truly equal chance gaming, regard needs to be had to the following:
 **a)**  are stakes involved at all, or merely participation fees? For instance, if the person makes a payment to participate for a prize put up by the operator, that is not a stake and the game is not a banker-s game
 **b)**  if there are stakes, are there any circumstances in which any part of those stakes may be retained by the operator, or are they all paid out in prizes, either in that game or rolled over to later ones? If the latter, there is no bank against which the person is betting; instead the operator merely holds the prize fund on behalf of the players.

###  A.9

 A game which has both a participation fee and stakes which are fully returned to the winning player(s) also remains ‘equal chance- gaming.

###  A.10

 Thus, as long as bingo operators either return all stakes in prizes or decide themselves how much to put up as prizes and separately decide how much to charge to ensure that the payouts are likely to be covered (such that they do not make a commercial loss) the format will not be a banker-s game and will (provided chances are equally favourable to all players  [3](#3)  ) meet the definition of ‘equal chance gaming-.

 [Previous page
 Further guidance](/licensees-and-businesses/guide/page/further-guidance)  [Next page
 Annex B: Key characteristics of bingo - Revised, January 2014](/licensees-and-businesses/guide/page/annex-b-key-characteristics-of-bingo-revised-january-2014)

---

 Last updated: 26 May 2021

 Show updates to this content  No changes to show.


Annex B: Key characteristics of bingo - Revised, January 2014

###  B.1

 Following discussions with the Bingo Association and BACTA, the Gambling Commission published in June 2009 a list of characteristics, which it considered should be present in games, whether or not played by machine, in order for them to be classed as bingo. The Commission has recently reviewed and revised, and now republishes, this list.

###  B.2

 The listed characteristics are particularly relevant to bingo machines, also known as video bingo terminals (VBTs). Machines that play bingo are exempt from limits on numbers, and stakes and prizes which apply to gaming machines. If these characteristics are not present it is likely that the Commission will view the machines as gaming machines and regulate them accordingly.

###  B.3

 Manufacturers and operators should address these characteristics when developing bingo machines for bingo clubs, adult gaming centres (AGCs) and family entertainment centres (FECs) and should also note that the Commission has concerns about potential access to these machines by children and young people (those under the age of 18). At this stage we do not intend to introduce licence conditions restricting this product to over 18s in those premises that are not age restricted, as the industry has agreed to the following characteristics. However, the options to do so remains open to the Commission should issues arise.

###  B.4

 The Commission will continue to monitor the development of bingo machines with a view to a decision, in the longer term, whether it is necessary to incorporate the characteristics in our Technical Standards, Equipment Technical Requirements and/or  [Licence Conditions and Codes of Practice](/licensees-and-businesses/lccp/online)  . In the meantime, we note that both the Bingo Association and BACTA have communicated these characteristics to their members by way of a Code of Practice.

###  B.5

 In the following list, any reference to ‘game- or ‘games- means a game or games of bingo.

##  Key characteristics of bingo

##  Characteristics specific to bingo machines

##  Regulations specific to bingo machines in AGCs/FECs

##  References


* Players- payments must be divided between stakes and participation fees, although they may consist entirely of stake or entirely of participation fee.
* The way that division is made must be transparent to the player and in particular there must be a notice displayed showing participation fees in a way that makes it readily accessible to players. Any stakes must be returned to players, either in the particular game or in a subsequent one.
* Each game must be played to a single set of numbers, or symbols; drawing a second set starts a new game.
* Any game formats must clearly be presented as offering the player the opportunity to participate in a game of bingo. This includes numbers (or symbols) being marked off and the game having the appearance of a game of bingo (rather than a gaming machine).
* Any ‘added prize money- stated to be available in a game, once offered (and unless the offer is specifically limited in time), must remain available until won in that or subsequent games ie: by way of rollover; the operator cannot claim them back. Prizes clearly advertised as being offered only for a limited period can be claimed back if they are not won. All prizes offered in each game must be transparent to the player.
* Games may operate with a single player, provided there is a meaningful opportunity for other players to participate in the same game.
* The game must comply with the requirements of the Gambling Act 2005 and must be capable of audit, where appropriate, to demonstrate legal compliance. Such audit data will demonstrate for example how players- payments are split between stakes and participation fees and that all stakes are returned to the players, either in that game or subsequent games.


Characteristics specific to bingo machines

* The speed of game, including the time taken to join, should be similar to that of an interval game. Games must not have an auto play function.
* The machines must provide a facility for the player to extend the playing time by a minimum of 100%.
* The amount that can be staked in a set period should be no greater than on a Category C machine.


Regulations specific to bingo machines in AGCs/FECs

* the nature or size of the prize offered may not be determined by the number of persons playing; or the amount paid for or raised by the game
* bingo machines in FECs will not be made available in areas where children and young people (those under the age of 18) are permitted.


 1  [Gambling Act 2005 section 288 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/288)  – Meaning of ‘prize gaming- Gaming is prize gaming for the purposes of this Act if neither the nature nor the size of a prize played for is determined by reference to:
 (a) The number of people playing
 (b) The amount paid for or raised by the gaming.
 2  The 2005 Act-s definition of a stake is: ‘an amount paid or risked in connection with gambling and which either
 (a) is used in calculating the amount of winnings or value of the prize that the person making the stake receives if successful
 (b) is used in calculating the total amount of winnings or value of the prizes in respect of the gambling in which the person making the stake participates.-
 3  Case law establishes that the fact that a player in bingo may purchase more than one card does not make the chances unequal as between players; such a player will have paid for two or more chances to win and not a chance to win two or more times what another player can win.

 [Previous page
 Annex A: Banker-s games and equal chance gaming - January 2014](/licensees-and-businesses/guide/page/annex-a-bankers-games-and-equal-chance-gaming)

---

 Last updated: 26 May 2021

 Show updates to this content  No changes to show.


Residential gaming is one of two forms of what's known as 'private gaming' - which can only take place somewhere the public can't access.


 Anywhere the public does not have access to. For example, a hostel or halls of residence.

 You do not need a licence for this kind of gaming.


 You must:

* physically play the game together, at the same physical location
* make sure at least half of the people playing live at that location.


 You can't:

* charge any entry fees - this includes any kind of admission fee or fee for taking part
* make a profit from the game - even if you intend to donate the profits to charity or good causes
* deduct from or ‘levy- on money staked or won by players in the game. It doesn-t matter if the charge is voluntary or compulsory
* run the game as part of a trade or business
* play the bingo virtually, or online in any way.


 A group of four friends want to play a game of bingo at their student halls. They invite two more friends over to join them and everyone plays the game at the same physical location, using a bingo board game.

 Every player pays a £1 stake and this makes up the pot of money which can be won.

 [Previous page
 How to run bingo legally](/licensees-and-businesses/guide/how-to-run-a-game-of-bingo)  [Next page
 Domestic gaming](/licensees-and-businesses/guide/page/domestic-gaming)

---

 Last updated: 1 July 2021

 Show updates to this content  No changes to show.


Domestic gaming is one of two forms of what's known as 'private gaming' - which can only take place somewhere the public can't access.


 In a private dwelling, such as a house. This can also include other types of accommodation used as, or as part of, a home. For example, motorhomes, houseboats and garden sheds.

 Under 18s can take part.

 You do not need a licence for this kind of gaming.


 You must:

* make sure the game takes place in the house or accommodation where you usually live
* play the game on a domestic occasion. For example, a dinner party or other small gathering in your home.


 You can-t:

* hold the bingo game outside of a residential setting
* play the game in group accommodation, such as student halls of residence. See  [residential gaming](/licensees-and-businesses/guide/how-to-run-a-game-of-bingo#residential-gaming)  instead
* charge any entry fees - this includes any kind of admission fee or fee for taking part
* make a profit from the game - even if you intend to donate the profits to charity or good causes
* play the bingo virtually, or online in any way.


 Danielle invites her friends over to her house for her babyshower. One of the activities is a game of bingo. Everyone will physically play the bingo game at Danielle-s house and everyone has the same chance of winning.

 Every player pays a £1 stake and this makes up the pot of money which can be won.

 [Previous page
 Residential gaming](/licensees-and-businesses/guide/page/residential-gaming)  [Next page
 Online bingo](/licensees-and-businesses/guide/page/running-online-bingo)

---

 Last updated: 11 November 2022

 Show updates to this content  Following an audit the 'residential gaming' link has been updated.


 You need a licence to run any kind of online or 'remote' bingo. This includes any type of game where players would be taking part virtually. For example, you need a licence to run a bingo game played using social media or on a video call, using platforms such as Zoom.

 !  **Warning  If you run an online bingo game without a licence you are breaking the law.** ###  Online bingo includes bingo offered using any form of 'remote' communications

 This includes:

* internet
* telephone
* television
* radio
* any other type of electronic or other technology that enable communication.


 The legal basis for bingo means that even if you have good intentions (such as playing for charity) you could face a fine or criminal prosecution.

 You can read more in  [Section 6 of the Gambling Act 2005 (opens in new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/6)  .


 If you want to run  **online**  bingo you-ll need to  [apply for a remote bingo operating licence](/licensees-and-businesses/licences-and-fees/remote-bingo)  with us. You-ll also need to comply with the relevant legal requirements and our regulatory codes.

 If you don-t want to apply for a licence, we-d strongly recommend choosing another activity. You can find fundraising ideas on the  [NHS Charities Together website (opens in new tab)](https://www.nhscharitiestogether.co.uk/fundraising-pack/)  .

 [Previous page
 Domestic gaming](/licensees-and-businesses/guide/page/domestic-gaming)  [Next page
 Bingo using a club gaming permit](/licensees-and-businesses/guide/page/bingo-using-a-club-gaming-permit)

---

 Last updated: 10 June 2021

 Show updates to this content  No changes to show.


 In the following places:

* [members- clubs](/licensees-and-businesses/guide/members-clubs-and-commercial-clubs#what-is-a-members-club)  - such as working men-s clubs, branches of the Royal British Legion clubs and with political ties, or
* miners- welfare institutes.

 You do not need a licence for this kind of gaming. However, you'll need to apply for a  [club gaming permit](/licensees-and-businesses/guide/club-gaming-and-machine-permits#club-gaming-permit)  with your local authority.


 You must make sure:

* the game is played as an equal chance game (essentially all players must have the same chance of winning)
* the gaming is not the main purpose of the club – it can only be an additional activity
* every player is a member of the club, or, a guest of a member
* children and young people under 18 are not allowed in the area of the club where the gaming is taking place
* total stakes and prizes for the game do not exceed £2,000 in a 7 day period. Otherwise, this will be classed as ‘high turnover- bingo. If this happens, you-ll need to tell us. If it happens more than once, then you-ll need a licence
* you charge a maximum of  **£3**  in participation fees, per person and per day.


 You can-t:

* run ‘linked- games with players on other premises. For example, you cannot run a linked game between two branches of the Royal British Legion based in two locations
* deduct from or ‘levy- on money staked or won by players in the game. It doesn-t matter if the charge is voluntary or compulsory
* play the bingo virtually, or online in any way.


 A local branch of a political club want to run a bingo night. Usually, the club meet to discuss environmental issues. Everyone taking part in the bingo night will be a member of the club, or a registered guest.

 There will be no under 18s taking part, and no children or young people will be allowed in the function room where the bingo will take place. The total stakes and prizes will be less than £2,000. The club applies for a club gaming permit and their request for the permit is granted.


 A club gaming permit also allows you to provide a maximum of 3  [gaming machines](/licensees-and-businesses/guide/gaming-machine-categories)  from categories B3A (with agreement), B4, C or D.

 You can read more about  [club gaming permits](/licensees-and-businesses/guide/club-gaming-and-machine-permits#club-gaming-permit)  .

 [Previous page
 Online bingo](/licensees-and-businesses/guide/page/running-online-bingo)  [Next page
 Exempt gaming in clubs and miners' welfare institutes](/licensees-and-businesses/guide/page/exempt-gaming-in-clubs-and-institutions)

---

 Last updated: 6 July 2021

 Show updates to this content  No changes to show.


Exempt gaming in clubs and miners' welfare institutes

 You can run games like bingo and poker in the following places:

* [members- clubs](/licensees-and-businesses/guide/members-clubs-and-commercial-clubs#what-is-a-members-club)  - such as working men-s clubs, branches of the Royal British Legion and clubs with political ties
* [Commercial clubs](/licensees-and-businesses/guide/members-clubs-and-commercial-clubs#what-is-a-commercial-club)  - clubs created with the aim of making a profit, such as snooker clubs and gyms or sports facilities, where you'd pay to become a member but have no say in how the club is run.
* miners- welfare institutes.

 You do not need a licence for this kind of gaming.


 You must make sure:

* the game is played as an equal chance game (essentially all players must have the same chance of winning)
* the gaming is not the main purpose of the club – it can only be an additional activity.
* every player is a member of the club, or, a guest of a member
* children and under 18s do not take part
* total stakes and prizes for the game do not exceed £2,000 in a 7 day period. Otherwise, this will be classed as ‘high turnover- bingo. If this happens, you-ll need to tell us. If it happens more than once, then you-ll need a licence
* you charge a maximum of  **£1**  in participation fees, per person and per day.

 If you-re a commercial club with a  [club machine permit](/licensees-and-businesses/guide/club-gaming-and-machine-permits)  the participation fee increases to £3 per person per day.


 You can-t:

* deduct from or ‘levy- on money staked or won by players in the game. It doesn-t matter if the charge is voluntary or compulsory
* run ‘linked- games with players on other premises. For example, you cannot run a linked game between two branches of the Royal British Legion based in two locations
* play the bingo virtually, or online in any way.

 [Previous page
 Bingo using a club gaming permit](/licensees-and-businesses/guide/page/bingo-using-a-club-gaming-permit)  [Next page
 Exempt gaming in pubs](/licensees-and-businesses/guide/page/exempt-gaming-in-pubs)

---

 Last updated: 11 June 2021

 Show updates to this content  No changes to show.


 Generally, in any alcohol-licensed premises, such as pubs and bars.

 You do not need a licence for this kind of gaming.


 You must make sure:

* the game is played as an equal chance game (essentially all players must have the same chance of winning)
* children and under 18s do not take part
* total stakes and prizes for the game do not exceed £2,000 in a 7 day period. Otherwise, this will be classed as ‘high turnover- bingo. If this happens, you-ll need to tell us. If it happens more than once, then you-ll need a licence
* the stake limit is  **£5**  per person, per game
* all stakes are returned as prizes.


 You can-t:

* Make a profit from the game - even if you intend to donate the profits to charity or good causes
* charge any participation fees – or any kind of admission fee
* run ‘linked- games with players on other premises. For example, you cannot run a linked game between two chain pubs, based in two different locations
* deduct from or ‘levy- on money staked or won by players in the game. It doesn-t matter if the charge is voluntary or compulsory
* play the bingo virtually, or online in any way.


 The owner of a nightclub wants to run a bingo night. The club-s premises already has an alcohol licence and only adults are allowed in the club. The total stakes and prizes for the bingo will be less than £2,000. All stakes will be returned as prizes. The owner of the club will give free entry to the club for the bingo night and there won-t be any other charges for people to take part.

 The maximum stake is charged at  **£5**  per person per game. All the money raised from the bingo night will be given back as prizes. Guests will still be able to buy drinks and pay for them as usual.


If you're holding bingo as part of a wider event

 You can charge admission costs for the overall entertainment. However, you can't charge participation fees, or any kind of entry fees for the bingo.

###  Scenario

 A pub landlady wants to hold an entertainment evening. She plans to offer entertainment a live band, quiz and a game of bingo. The landlady can charge an entry fee – for instance £10 – for the event as a whole and make a profit from the fee. However, people who will be playing bingo must be able to enter the pub without paying the entry fee. Some venues have a separate area where people can join in with bingo for free, but they can-t access the other entertainment, in order to do this.

 For example, the landlady can use a function room for the bingo which people will access for free (or, to pay a maximum of £5 stake per person, per game). However, guests won-t be able to access the main pub to watch the band or take part in the quiz without paying the £10 entry fee.

 [Previous page
 Exempt gaming in clubs and miners' welfare institutes](/licensees-and-businesses/guide/page/exempt-gaming-in-clubs-and-institutions)  [Next page
 Bingo at a premises: prize gaming](/licensees-and-businesses/guide/page/bingo-at-a-premises-which-has-a-gambling-licence)

---

 Last updated: 19 May 2021

 Show updates to this content  No changes to show.


The rules about playing bingo as prize gaming depend on the type of premises it is played in.


 You must make sure you only offer the type of gaming you're permitted to, as follows:

* Licensed bingo premises - any type of prize gaming
* Adult Gaming Centre (AGC) - any type of prize gaming
* Family Entertainment Centre (FEC) - any type of prize gaming
* Unlicensed Family Entertainment Centre (UFEC) - can  **only**  offer equal chance prize gaming (under their gaming machine permit)
* Travelling fairs - can  **only**  offer equal chance prize gaming, which must be ancillary (additional) to other amusements at the fair.

###  Time restrictions

 For the following, the game of bingo must take place over  **one**  day only:

* prize gaming permit holders
* Adult Gaming Centre (AGC)
* Family Entertainment Centre (FEC)
* travelling fairs.

>  These restrictions do not apply to licensed bingo premises.
>
>

 In Adult Gaming Centres, licensed and unlicensed family entertainment centres and travelling fairs, you must also make sure that:

* all chances to play are allocated or acquired on the premises where the gambling is taking place and on one day
* the game must be played and completed on the day the chances are allocated
* the result of the game must be made public in the premises on the day the game is played.

 You must also follow  [additional rules](/licensees-and-businesses/guide/page/bingo-at-a-premises-which-has-a-gambling-licence#additional-rules)  - including keeping to the maximum prize limits. These depend on the type of premises, as follows.


 You can't:

* base the value of the prizes on the number of people playing, or the amount raised by the game
* play the bingo virtually, or online in any way.


 You must also adhere to the following rules, including prize limits and maximum participation fees, which vary depending on the type of premises.

##  Licensed bingo premises

###  The rules

 The maximum participation fee you can charge people is  **£1**  per chance to win 1 or more prizes in a game.

 The maximum aggregate participation fees per game are  **£500**  .

 The maximum single prize limit is  **£70**  cash or in prize value (if under 18s are allowed on the premises). Or, the maximum prize limit is  **£100**  (if under 18s are not allowed on the premises).

 The maximum aggregate prize fund (cash or in prize value) per game is  **£500**  .

 Under 18s cannot take part in prize gaming at a bingo hall.

##  Adult Gaming Centre (AGC)

 For example, AGCs offer games which include slots, casino-style games and fruit machines. AGCs must have a Gambling Commission licence.

###  The rules

 The maximum participation fee is  **£1**  per chance to win 1 or more prizes in a game.

 The maximum aggregate participation fees per game are  **£500**  .

 The maximum single prize limit is  **£70**  cash or in prize value.

 The maximum aggregate prize fund (cash or in prize value) per game is  **£500**  .

 Under 18s  **cannot**  take part in this kind of gaming at an AGC.

##  Family Entertainment Centre (FEC)

 They're allowed to provide an unlimited number of certain types of gaming machine in a premise which is open to all ages. FECs must have a Gambling Commission licence.

###  The rules

 The maximum participation fee is  **£1**  per chance to win 1 or more prizes in a game.

 The maximum aggregate participation fees per game are  **£500**  .

 The maximum single prize limit is  **£70**  cash or in prize value.

 The maximum aggregate prize fund (cash or in prize value) per game is  **£500**  .

##  Unlicensed Family Entertainment Centre (UFEC)

 Unlicensed FECs must have a permit from the local licensing authority.

###  The rules

 The maximum participation fee is  **£1**  per chance to win 1 or more prizes in a game.

 The maximum aggregate participation fees per game are  **£500**  .

 The maximum single prize limit is  **£70**  cash or in prize value.

 The maximum aggregate prize fund (cash or in prize value) per game is  **£500**  .

##  Travelling fairs

###  The rules

 At a travelling fair, the bingo must be an ancillary (additional) amusement at the fair. For example, a travelling fair could offer bingo as well as their main attractions of fairground rides.

 The maximum participation fee is  **£1**  per chance to win 1 or more prizes in a game.

 The maximum aggregate participation fees per game are  **£500**  .

 The maximum single prize limit is  **£70**  cash or in prize value.

 The maximum aggregate prize fund (cash or in prize value) per game is  **£500**  .

 Under 18s can take part in this kind of gaming at a travelling fair.

 Some  [category D gaming machines](/licensees-and-businesses/guide/page/d-gaming-machines#bingo-machines)  are designed or adapted to play bingo as a prize game.  [Previous page
 Exempt gaming in pubs](/licensees-and-businesses/guide/page/exempt-gaming-in-pubs)  [Next page
 Bingo for fundraising](/licensees-and-businesses/guide/page/bingo-for-fundraising)

---

 Last updated: 10 June 2021

 Show updates to this content  No changes to show.


Bingo halls and clubs that hold a bingo premises licence.


High-street outlets with gaming machines only available to over 18s.


Larger arcades which cater for a range of ages.


Unlicensed Family Entertainment Centre (UFEC)

Family-friendly amusement arcades and small arcades in holiday parks and resorts.


Made up of amusements, rides and games.


 [Non-remote bingo operating licence](/licensees-and-businesses/licences-and-fees/non-remote-bingo)

 [Remote bingo operating licence](/licensees-and-businesses/licences-and-fees/remote-bingo)

 [Remote bingo game host operating licence](/licensees-and-businesses/licences-and-fees/remote-bingo-game-host-operating-licence)

 [Previous page
 Betting licence activities](/licensees-and-businesses/guide/page/betting-licence-activities)  [Next page
 Casino licence activities](/licensees-and-businesses/guide/page/casino-licence-activities)

---

 Last updated: 15 February 2021

 Show updates to this content  No changes to show.


 Bingo can be offered on alcohol licensed premises, members' clubs, miners- welfare institutes and commercial clubs without an operating licence. However, the games must:

* be for adults only
* not be linked with games played on other premises.

 [GLA: Part 18 Bingo](/guidance/guidance-to-licensing-authorities/gla-part-18-bingo)

 There are limits on the amount which can be charged for participation:

|  |  With a club gaming permit  |  With a club machine permit  |  WITHOUT either a club gaming permit or club machine permit  |
| --- | --- | --- | --- |
|  Members' clubs  |  £3 maximum, per person, per day  |  £1 maximum, per person, per day  |  £1 maximum, per person, per day  |
|  Miners welfare institutes  |  £3 maximum, per person, per day  |  £1 maximum, per person, per day  |  £1 maximum, per person, per day  |
||  Commercial clubs  |  Not available  |  £3 maximum, per person, per day  |  £1 maximum, per person, per day  |

 Pubs must ensure that:

* no participation fee is charged
* they remain within the stake limit of charging a maximum of £5 per person, per game.

 Both alcohol licensed premises and clubs must ensure they do not exceed the maximum of £2,000 per week in stakes/prizes. Those wishing to exceed this limit need to  [apply for a bingo operating licence](/licensees-and-businesses/licences-and-fees/sector/bingo)  .


 When we say ‘prize gaming- we mean neither the nature nor the size of the prize is determined by:

* the number of people playing
* the amount paid for or raised by the game.

 You can run bingo as a prize game without the need for a bingo operating licence in adult gaming centres, family entertainment centres, unlicensed family entertainment centres and travelling fairs.

 To comply with the rules for prize gaming, the bingo games offered in these venues must:

* have a maximum stake of £1 and a prize worth no more than £70 per game
* offer no more than £500 of prizes per game
* have no more than £500 in stakes per game.


 Some files may not be accessible for users of assistive technology. If you require a copy of the file in an accessible format  [contact us](/forms/formatrequest)  with details of what you require. It would help us to know what technology you use and the required format.

 **PDF Files**  Some PDF files cannot be displayed in a browser, you will see a message saying 'Please wait...'. If you see this message, you will need to download the file and open it in  [Adobe Acrobat Reader (opens in a new tab)](https://get.adobe.com/reader/)  .

 [What constitutes bingo?

 application/pdf PDF 65.5 kB](//assets.ctfassets.net/j16ev64qyf6l/52bEZvvotMEdbCHYqnRJ0t/d464465c2de9ad878bf8ab281e78b619/What-constitutes-bingo-advice-note.pdf) [Previous page
 Pubs and clubs - case studies](/authorities/guide/page/pubs-and-clubs-case-studies)  [Next page
 Club gaming and machine permits](/authorities/guide/page/club-gaming-and-machine-permits)

---

 Last updated: 13 August 2021

 Show updates to this content  No changes to show.


 Applies to:

 Non-remote bingo operating licences and bingo ancillary remote licences

1. Licensees must comply with the Commission-s specification for bingo equipment.


 Applies to:

 Non-remote casino operating licences and casino ancillary remote licences

1. Licensees must comply with the Commission-s specifications for casino equipment.


 Applies to:

 All non-remote bingo licences

 **Ordinary code**  These do not have the status of operator licence conditions but set out good practice. Operators may adopt alternative approaches to those set out in ordinary code provisions if they have actively taken account of the ordinary code provision and can demonstrate that an alternative approach is reasonable in the operator's particular circumstances; or that to take an alternative approach would be acting in a similarly effective manner. Ordinary codes of practice are admissible in evidence in criminal or civil proceedings and must be taken into account in any case in which the court or tribunal think them relevant, and by the Commission in the exercise of its functions; any departure from ordinary code provisions by an operator may be taken into account by the Commission on a licence review, but cannot lead to imposition of a financial penalty.

1. Licensees who employ children under (under-16-year-olds) and young persons (those aged 16 or 17) should be aware that it is an offence:

- to employ them to provide facilities for playing bingo;
- for their contracts of employment to require them, or for them to be permitted, to perform a function in connection with a gaming machine; and
- to employ a child to perform any function on premises where, and at time when, facilities are being provided for playing bingo.

- As to 1b, it should be noted that in the Commission-s view the relevant provision of the Act applies to any function performed in connection with a gaming machine. This includes servicing or cleaning such a machine.
- Accordingly, licensees should have and put into effect policies and procedures designed to ensure that:

- children and young persons are never asked to perform tasks within 1a or 1b, above
- all staff, including those who are children and young persons themselves, are instructed about the laws relating to access to gambling by children and young persons.
- Licensees should consider adopting a policy that:

- children are not employed to work on bingo licensed premises at any time when the premises are open for business
- neither children nor young persons are in any event asked to work in areas where gaming machines are situated.


 Applies to:

 All non-remote casino licences

 **Social responsibility code**  Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator-s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.

1. In complying with any condition on a casino premises licence requiring the display of rules about gaming, licensees must ensure that the following are included:
	1. the rules of each type of casino game available to be played
	2. a player-s guide to the house edge
	3. a player-s guide to the rules of any equal chance games which are made available.


When gaming machines are available to use - 20% regulations

Gaming machine entitlements in adult gaming centres (AGCs) or bingo premises set out that only 20% of machines can be category B machines in order to ensure a balanced offering of gambling products and restrict harder gambling opportunities.


 Machine design has changed in recent years and space-saving gaming machines have become available.

 These are in the form of:

* tablets
* multi-player units
* narrow/in-fill machines.

 However, some of these machines appear to be designed primarily to maximise category B machine entitlements. For example, narrow/in-fill single player gaming machines designed to fit in between full-sized gaming machines have become two-player and more recently four-player machines.

 Both variants were within the same size cabinet as the original single player machine, which had a width of approximately 10 inches. Such two and four-player machines are not actually available for use in any practical way by more than one player at a time. For example, they cannot be played simultaneously by more than one person.

 Such narrow/in-fill machines, subject to appropriate spacing, can only be considered to be one gaming machine for the purpose of calculating the number of machines ‘available for use-.


 We have updated our  [available for use guidance](/licensees-and-businesses/guide/when-a-machine-is-available-for-use)  to make it clear that for the purpose of calculating the category B machine entitlement in gambling premises, gaming machines should only be counted if they can be played simultaneously by different players without physical hindrance.

 Licensees should consider their own product offering alongside our updated guidance. Should licensees fail to address our concerns in this respect, we may take enforcement action. Individual licence conditions, for example, could be applied on a case-by-case basis if we had concerns that a licensee was not addressing this problem.

 We will continue to monitor the situation and give further consideration to whether additional guidance or action is required to ensure that the intended product balance is maintained in gambling premises. You can read more about our  [on-going work on category B gaming machines and player protections](/news/article/gambling-commission-calls-for-evidence-on-category-b-gaming-machines-and)  .

---

 Last updated: 8 June 2021

 Show updates to this content  No changes to show.


 Skill with prizes (SWPs) are not classed as gaming machines under the  [Gambling Act 2005 (opens in new tab)](http://www.legislation.gov.uk/ukpga/2005/19/contents)  and therefore can be sited anywhere. For example, you might see them located in a cinema foyer or shopping centre.

 You  **do not**  need a licence for skill with prize machines. However, you do need one for a machine if it is classed as a gaming machine.

 SWPs do not count towards the machine allowance in an alcohol licensed premises, or a members' club. They also do not count towards machine numbers in:

* licensed adult gaming centres
* family entertainment centres
* bingo premises for the purpose of determining category B3 gaming machine allowances.

>  Skill with prize machines may be liable for Machine Games Duty and may need to be registered with HMRC. Read more about  [Machine Games Duty on GOV.UK (opens in new tab)](https://www.gov.uk/machine-game-duty/register)  .
>
>

##  Skill with prize machine or gaming machine

##  When a game is a game of chance

##  Is it really a skill-based game?

##  When you need a licence

##  Maximum stake or prize

##  Compensation mechanisms

---

 Last updated: 18 May 2021

 Show updates to this content  No changes to show.


Skill with prize machine or gaming machine

 The main difference is whether any of the games offered on the machine amount to ‘gaming- as defined in  [section 6 of the Gambling Act 2005 (opens in new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/6)  . In the Gambling Act 2005, ‘gaming- means playing a game of chance for a prize.

 If just one game from a group of skill games is a game of chance, then the machine as a whole is classed as a gaming machine.


 Consider all four of the following questions to help you decide.

###  Does the outcome of the game depend entirely on chance?

 If yes, then the game is clearly a game of chance and, if played by means of a machine, that machine is a gaming machine.

 An example of a game whose outcome is determined entirely by chance is roulette.

###  Does the game contain an element of chance as well as an element of skill?

 A game in which the result can be influenced by chance is a game of chance for the purposes of the Gambling Act 2005. Therefore the machine on which the game is played is a gaming machine. It does not matter for these purposes whether the element of chance is greater than the element of skill. Nor does it matter whether the element of chance can be eliminated by great skill.

 An example of a game which contains both an element of chance and skill is poker.

###  Is the element of chance involved in the game significant enough to make a difference?

 There comes a point where the element of chance is so small that it should be disregarded.

 An example of a game where the element of chance should be disregarded is chess, where the element of chance introduced by determining who is to play as white and black is so small as to be likely to be considered irrelevant.

###  Is the game presented as involving an element of chance?

 Where the game does not involve an element of chance it may still be considered to be presented as involving an element of chance. We'll take into account the following:

* How the game appears to the player. It must not look like a game of chance. For example, roulette, bingo or game of cards.
* The name of the game and whether it contains language associated with gambling games. For example ‘stake- and ‘jackpot-.
* The livery of the machine and whether it contains symbols or graphics associated with gambling games, such as bars, bells, lucky 7s or fruits.
* The appearance of the game itself and whether it contains symbols or graphics associated with gambling, including (but not limited to) the turn of a wheel, the spin of a coin, the roll of a dice, reel bands, or the random selection of numbers.
* Whether the game involves the player in actions associated with gambling including (but not limited to) placing chips or markers on numbers.
* Any contextual indications such as advertising signage or marketing material

 Any one of these factors by itself may not be enough to classify a machine as a gaming machine. For example, a picture of dice in a game by itself doesn-t necessarily make it a gaming machine.


 If you have answered the previous questions and you think the machine is an SWP then you should ask these further questions.

 Games with any of the following factors are likely to contain a significant enough element of chance that the machine would be a gaming machine, even if the game claims to test a player-s skill in order for them to win a prize.

 It doesn-t matter whether the factors are present at all times, or whether they are introduced by means of a compensation mechanism.

 The factors are:

* a suitably skilful player does not have sufficient time to exercise their skill
* an outcome based on a player-s reactions is not genuinely achievable
* a game based on memory does not give the player the opportunity for all the necessary information to be retained and recalled
* a game where the player controls operate in an inconsistent manner, for example where a pressure sensitive button does not give the same output for the same applied pressure in each go on that machine.

 Finally, if it is not possible for all of the advertised prizes to be won, then the game may be a fraud, in which case we would draw it to the attention of other agencies.


 You do not need a licence for skill with prize machines.

 However, if the answers to the previous questions indicate that the game in question is ‘gaming- then you need an appropriate  [gaming machine licence](/licensees-and-businesses/licences-and-fees/sector/gaming-machines-and-software#gaming-machines-and-software-licences-and-fees-licence-activities)  .

 You'll need a licence not only to make the machine  [available for use](/licensees-and-businesses/guide/when-a-machine-is-available-for-use)  , but also to:

* manufacture
* supply
* install
* adapt
* maintain, or
* repair the gaming machine.


 As you do not need a licence or permit, there is no legal limit for stake or prizes.

 However, it would be very difficult to manufacture a genuine SWP machine that is economically viable and offers prizes over £50 (the prize limit set by the industry trade body following discussion with us).

 We would be likely to raise questions about machines with prizes above this range.


 Some SWPs have a compensation mechanism. In broad terms ‘compensation- affects payout. It can alter the chances of winning depending on the circumstances. For example, the amount of money a machine has already taken or paid out.

 Compensation can also result in the outcome of a game, which may be presented as dependant on skill, being in fact predetermined.

 There are many different types of compensation mechanism. It is not possible to generalise as to their legal effect. Each case needs to be considered on its individual facts. However, the operation of compensation is clearly a relevant factor when considering the questions mentioned previously.

 Where a compensation mechanism introduces a random element into the game, this may result in the game being one of chance, but it does not necessarily follow in every case.

 Not every random or unpredictable element in a game necessarily leads to the conclusion that the game is a game of chance. There will be cases where the unpredictable or random element is present for the very purpose of testing the skill or knowledge of the player. For example, to challenge the player-s use of skill, whether that be manual dexterity or knowledge.

 It follows that compensators that vary the degree of skill required to win a prize, without introducing an appreciable element of chance, will not necessarily, in and of themselves, make a game a game of chance, provided that compensation does not prevent a suitably skilful player from being able to win any of the published prizes. The interpretation of the Gambling Act is ultimately a matter for the courts.


* [Skill with prizes (SWPs)](#)
* [Skill with prize machine or gaming machine](#differences-between-a-skill-with-prize-machine-and-a-gaming-machine)
* [When a game is a game of chance](#when-a-game-is-a-game-of-chance)
* [When you need a licence](#licences-required)
* [Maximum stake or prize](#maximum-stake-or-prize)
* [Compensation mechanisms](#compensation-mechanisms)

 [Print this guide](#)


 Approved Test Houses are required to report to us any incident or change that could have a significant impact on the delivery or structure of their business and/or ability to deliver and/or uphold the testing framework.

##  Key events (Test Houses)

---

 Last updated: 27 January 2022

 Show updates to this content  No changes to show.


 Approved Test Houses must notify us of the occurrence of any reportable changes or incidents. Details of the events to be reported are set out in the following table.

 They must do this as soon as reasonably practicable and in any event within five working days of becoming aware of the event.

 The Test House must notify us of such changes or incidents by email to  [testhousesubmission@gamblingcommission.gov.uk](mailto:testhousesubmission@gamblingcommission.gov.uk)  .

 Emails should be sent using the following format:

* Test House (Trading Name) – tell us the Test House-s trading name (e.g. Test House Alpha Ltd)
* date of event – tell us the date the event happened (e.g. 01/01/2022)
* key event (Test Houses) – tell us the name of the key event being reported (e.g. Key event (Test Houses) 1) Winding up of companies)
* summary of event details – provide a summary of the details of the event, including the reasons, if appropriate, and the date when an outcome of change is expected to take place
* contact details – tell us the name and contact details of a person we can contact to discuss the event
* supporting documents – attach any relevant supporting documentation.

 On receipt of an email relating to a reportable change or incident we may request additional information.

|  Reportable Change or Incident  |  Description  |  Guidance  |
| --- | --- | --- |
|  Key event (Test Houses) 1: Winding up of companies  |  A Test House must submit a key event report to us if it is presented with a petition for winding up for a company being a direct entity with controlling interest of an approved Test House, the making of a winding up order, or if the direct entity with controlling interest enters administration or receivership.  |  Provide the reasons behind the events and a copy of the petition, if relevant. Give details of any administrators acting on the company-s behalf. Tell us if the business is continuing to trade, what information that company has provided to its customers, and who is now running the business, or if the company is looking for a buyer, if relevant.  |
|  Key event (Test Houses) 2: Changes to shareholders  |  A Test House must submit a key event report to us if any person who (whether or not already a shareholder or member) becomes a shareholder or member holding 10% or more of the issued share capital of the company or its holding company.  |  Provide the name, date of birth and address of any new shareholders or members with 10% or more of the issued share capital.  |
|  Key event (Test Houses) 3: Changes to key positions  |  A Test House must submit a key event report to us if a person is appointed to, or a person ceases to occupy, a key position.  |  A key person in a Test House includes all directors, board members or anyone with influence who hold key positions with overall authority and responsibility (including, but not limited to) CEO, COO, Head of Finance, Head of Quality Control, Head of Compliance, Technical Director, or equivalent positions. Tell us who has been appointed, or who has left their position. Provide the name, address, and date of birth of the individuals concerned, along with the data of the change. If someone has left a position and has not been replaced, explain how this position be covered.  |
|  Key event (Test Houses) 4: Organisational changes  |  A Test House must submit a key event report to us if there is any material change(s) in the Test House structure or the operation of its business, specifically linked to gambling related testing.  |  A ‘material change- includes (but is not limited to) acquisitions, mergers and significant restructures or redundancies. Provide details of the change and the new arrangements.  |
|  Key event (Test Houses) 5: Address changes  |  A Test House must submit a key event report to us if it changes its Head Office or Registered address.  |  Provide details of the new address and date of the change.  |
|  Key event (Test Houses) 6: Regulatory investigations  |  A Test House must submit a key event report to us if it is subject to an investigation by a professional, statutory, regulatory, or government body into its activities which could reasonably be expected to raise doubts about the Test Houses continued suitability to test gambling products.  |  Tell us the name of the professional, statutory, regulatory, or government body conducting the investigation and details of the investigation and any adverse report, penalties, fines, or sanctions imposed. You need to inform us at the outset of the investigation, when there are initial findings, and at the conclusion of the investigation. Provide copies of reports received from the investigating body. You must tell us about investigations by UK and overseas bodies, but you do not need to inform us of investigations initiated by us.  |
|  Key event (Test Houses) 7: Criminal investigations  |  A Test House must submit a key event report to us if it (i.e. the Test House business) is subject to a criminal investigation which may reasonably cause us to question whether the Test House-s measures to keep crime out of gambling had failed.  |  Tell us the name of the investigating body and details of the investigation and any convictions, sentences, penalties, fines, or sanctions imposed. You need to inform us at the outset of the investigation, when there are initial findings, and at the conclusion of the investigation. Provide copies of reports received from the investigating body. You must tell us about investigations by UK and overseas bodies, but you do not need to inform us of investigations initiated by us.  |
|  Key event (Test Houses) 8: Loss, suspension or relinquishment of BS/ENISO 17025 accreditation  |  A Test House must submit a key event report to us if it loses its BS/ENISO 17025 accreditation, that accreditation is suspended, or it ceases to be accredited.  |  Tell us the date the accreditation was lost, suspended, or relinquished. Explain the reasons for the loss, suspension, or relinquishment of the accreditation. Identify if this change will this affect any licensees testing and, if so, have they been informed. Provide a copy of any applicable reports or correspondence (e.g. notification of loss accreditation from the accreditor).  |
|  Key event (Test Houses) 9: Customer data security breach  |  A Test House must submit a key event report to us if any security breach to its environment, has an adverse effect on the confidentiality of customer data.  |  Tell us the nature of the security breach, how many customers it affected and the impact or potential impact of the breach. If the breach is one which is reportable to the Information Commissioner-s Office, tell us the date you reported it to them. Further details on  [notifying security breaches](/licensees-and-businesses/guide/what-you-need-to-tell-us-when-you-hold-an-operating-licence#notification-of-security-breaches)  are on our website.  |

 Should a Test House wish to report something that is not a specified key event but which we may reasonably be expected to know, they should report this to us in the same way.


* [Test House information reporting](#)
* [Key events (Test Houses)](#key-events-test-houses)

 [Print this guide](#)


Updated Test House Framework - what this means for operators

 Following the test house framework consultation the Commission has worked with the United Kingdom Accreditation Service (UKAS) and test houses to implement changes aimed at raising standards in the industry.

 Although the new framework is focused on the way in which the Commission approves test houses, we recognise that this might impact on operators and how they gain game approval.


What are the main changes the Commission brought in?

* new accreditation requirements
* new approval process, meaning all existing test houses having to re-apply
* introducing immediate notice of and yearly reporting requirements
* introduction of revocation of test house approval.


The Commission is only changing the approval and accreditation process of test houses, not the testing regime of remote and non-remote games.


Can we see a copy of the new approval and accreditation documents?

The Commission will be publishing new application documents along with guidance for how test houses can apply. However due to copyright requirements the full accreditation document is only available to test houses upon application.


What will test houses now be accredited too?

The new Test House Framework requires approved test houses to be accredited to ISO/IEC 17025 which has not changed. In addition, the approved test houses will now have to be compliant with other requirements taken from ISO/IEC 17065 and ISO/IEC 27001.


What happens if my test house does not seek or gain approval?

>  You should all contact your test houses to gain assurances that they are continuing to be approved to test games within Britain.
>
>

 If they are not continuing to be approved by the Commission, you should find a new approved test house to ensure all of your games are continuing to be tested beyond 1 October.

 In the meantime, your games will be tested in the usual way but please make plans for any changes far enough in advance should your current provider be leaving the GB market.

---

 Last updated: 20 July 2021

 Show updates to this content  No changes to show.


Notification of information security breaches

 You must tell us about any security breach to your environment that could harm the confidentiality of customer data or prevent the licensee-s customers, staff, or legitimate users from accessing accounts for longer than 12 hours.

 We use the information you report to monitor ongoing compliance and evaluate risk across the industry. If themes emerge that may be valuable to share (such as specific attacks targeting a number of businesses) this may be fed back to help you deal with emerging threats.

##  LCCP Licence Condition 15.2.1 (paragraph 16)

##  Types of incidents

##  When to report information security breaches

##  Which details to provide

##  How to notify us of an information security breach

---

 Last updated: 1 March 2022

 Show updates to this content  No changes to show.


LCCP Licence Condition 15.2.1 (paragraph 16)

This guidance relates to  [LCCP Licence Condition 15.2.1. This licence condition applies to all operators and would include an information security breach for any operator who holds electronic records of customer information or gambling transactions.](https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/15-2-1-reporting-key-events)


 These are some common examples of incidents which may impact on the confidentiality of customer data or the availability of accounts:

* infection by viruses or malicious software
* ransomware infection
* theft or damage of computer equipment
* attacks by unauthorised outsiders resulting in network penetration
* unauthorised access (internal or external)
* unauthorised or accidental disclosure of customer data
* staff or third party misuse of customer data
* denial of services attacks
* customer impersonated fraud (identity theft).


When to report information security breaches

 Minor incidents should not necessarily be reported. You can decide whether the severity of an incident means it should be reported. You should record and keep your evidence as to how the decision to report or not report was made by the appropriate PML (or in the case of a small scale operator the appropriate ‘qualified person-).

 The Information Commissioner-s Office (ICO) provides guidance on when security breaches involving personal data should be reported to them and this should be considered when making a decision to report (both to the ICO and to us). The key considerations are:

* potential detriment that could be caused to the individuals affected
* volume of data that has been affected
* sensitivity of the data that has been affected
* financial loss to customers.

 As a general rule, if a large volume of customer data has been affected, this should be reported. If a low volume has been affected but there is the potential for serious detriment or the data is highly sensitive, this should also be reported. Consideration should also be given to notifying affected customers where warranted. Refer again to the ICO guidance in this area.

 The ICO is primarily interested in breaches of personal information, our interest has a wider remit such as unavailability of customer accounts for more than 24 hours or the loss, corruption or unauthorised modification of other critical gambling records such as player account balances, prizes or gambling transaction records.


 You should provide sufficient information to describe the incident that has occurred, the severity of the incident and the volume of data affected.

 Consider the following when submitting a report:

* the nature of the incident
* the location of the incident
* the services attacked or compromised
* when it first occurred
* when it was detected
* how it was detected and whether you are able to precisely identify the extent of the incident (how many customers affected, whether data was taken, what data and systems were affected)
* what mitigating action has been taken
* whether the root cause been identified
* whether any other parties such as ICO, police, external security consultants or customers been notified and the consideration given to not notifying some or all of the other parties
* what preventative action has been taken or will be taken to prevent future breaches.


How to notify us of an information security breach

 Information security breaches are Key Events and must be reported as soon as reasonably practicable and in any event within five working days of the licensee becoming aware of the event-s occurrence.

 Our guidance on  [Key Events: Customer data security breach](/guidance/lccp-Information-requirements/guidance-to-operators-on-display-of-licensed-status-key-events-gambling)  provides further information on submitting this key event.


* [Notification of information security breaches](#)
* [Types of incidents](#types-of-incidents)
* [When to report information security breaches](#when-to-report-severity-of-incident)
* [Which details to provide](#which-details-to-provide)
* [How to notify us of an information security breach](#how-to-notify-us-of-an-information-security-breach)

 [Print this guide](#)


>  This is an HTML version of this advice. You can also view or download the  [original Lottery products and particular appeal to children advice (PDF)](#6qz2kxBzRNqMCfgKYwJmFQ)  published in July 2020.
>
>


 Society lottery operators promote lotteries via a range of products, which include the sale of scratchcards (both in non-remote and remote formats). Over the years, society lottery operators have seen the advantages of reaching a wider audience by being able to utilise the growing number of media formats to market and advertise their lottery products. This includes the development of their charity websites, online shops and general use of social media. It also has included providing links or thumbnails of the scratchcard design on their own website and social media platforms to provide further information about the product.

 All operators are required to comply with the  [Licence conditions and codes of practice (LCCP)](/licensees-and-businesses/lccp/online)  and the UK Advertising Codes which require them to market responsibly, with particular regard to the protection of children and young people (under 18s) and others who are vulnerable to being harmed or exploited by gambling advertising. We work very closely with the Advertising Standards Authority (ASA) to enforce the rules.

 In October 2017, we published  [a joint letter with the ASA and the Remote Gambling Association](#1XEiD65ojh7dtMzNLKStnK)  to all remote operators which reminded them of the rules in relation to protecting children and young people, and required them to remove any advertising on websites likely to appeal particularly to those under 18 and which are generally available to view (‘freely accessible-). Furthermore, in August 2018, the ASA banned an advert that promoted a scratchcard on an operator-s website which contained imagery found to be of particular appeal to under 18s.

 Although there are already rules in place for various media formats, this advice note clarifies the Gambling Commission-s rules and our expectations when we apply  [LCCP social responsibility code 5.1.7 (Compliance with advertising codes – lotteries)](/licensees-and-businesses/lccp/condition/5-1-7-compliance-with-advertising-codes-lotteries)  . Operators should consider this advice when developing products such as society lottery scratchcards.

##  The rules

##  The CAP Code states:

##  The CAP code guidance on particular appeal to under 18s

##  Files


LCCP 5.1.7 requires all lottery licensees to ensure that the marketing of products and services is undertaken in a socially responsible manner and that they must comply with the UK Advertising Codes issued by the Committees of Advertising Practice (CAP and for broadcast advertising, BCAP). LCCP 5.1.7(2) states that for media not explicitly covered you should apply the principles included in these codes of practice as if they were explicitly covered.


 **17.12**  Marketing communications for lotteries must not exploit the susceptibilities, aspirations, credulity, inexperience or lack of knowledge of children, young persons or other vulnerable persons.
 **17.13**  Marketing communications for lotteries must not be likely to be of particular appeal to children or young persons, especially by reflecting or being associated with youth culture.
 **17.14**  Marketing communications for lotteries should not be directed at those aged under 16 years through the selection of media or context in which they appear.

 The minimum age limit for purchasing National Lottery products and participating in society lotteries is 16. The rules in section 17 (Lotteries) of the CAP Code are designed to nevertheless ensure that marketing communications for lotteries are socially responsible with particular regard to the need to protect those aged under 18.

 The UK Advertising Codes explicitly cover a  [a range of media (opens in a new tab)](https://www.asa.org.uk/advice-online/remit-general.html)  , but do not extend to in-store communications (other than point of sale material that includes a promotion) or to products, for example a physical lottery scratchcard.

 The definition of advertising in the  [Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/contents)  captures anything which encourages a person to take advantage of gambling facilities or the providing of information about gambling facilities with the intention that that will increase the use of those facilities. We consider that this broad definition applies to the content and design of scratchcards as well as other lottery products.

 Accordingly, the provisions under LCCP 5.1.7(2) require operators to have regard to the principles included in the UK Advertising Codes as if they were explicitly covered, when considering the design of scratchcards. These principles include that marketing communications that are freely viewable and accessible should not be of particular appeal to under 18s. For example, we consider that an operator would breach LCCP if its lottery scratchcards were displayed on a supermarket counter and featured content of particular appeal to under 18s.