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1101 | Lottery proceeds - Advice note April 2013 (Updated July 2020) | Footnotes | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lottery-proceeds-advice-note-april-2013-updated-july-2020 | 1 Lottery operators will wish to take note of Charity Commission advice on how charity law applies to fundraising: [Charities and Fundraising (opens in a new tab)](https://www.gov.uk/government/publications/charities-and-fundraising-cc20)
2 Social Responsibility code 4.3.1
3 [Section 252(4) of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/252)
4 [Section 260 of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/260)
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1102 | Contents | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lottery-proceeds-advice-note-april-2013-updated-july-2020 | * [Lottery proceeds - Advice note April 2013 (Updated July 2020)](#)
* [Who can promote lotteries?](#who-can-promote-lotteries)
* [‘Proceeds- and ‘profits- of a lottery](#proceeds-and-profits-of-a-lottery)
* [The expenses of a lottery - lottery proceeds](#the-expenses-of-a-lottery-lottery-proceeds)
* [Lottery submissions - lottery proceeds](#lottery-submissions-lottery-proceeds)
* [Non-compliance - lottery proceeds](#non-compliance-in-lottery-proceeds)
[Print this guide](#) |
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1103 | Lotteries: sector specific compliance | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/lotteries-sector-specific-compliance | Lotteries (or raffles) can only be run for good causes, they cannot be run for private or commercial gain.
Lotteries differ from other types of gambling activity in that the minimum participation age is 16 for the National Lottery, society lotteries, customer lotteries and local authority lotteries, as opposed to 18 for other types of gambling.
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1104 | Lotteries: sector specific compliance | Lotteries are defined by the Gambling Act 2005 as either ‘simple- or ‘complex- | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/lotteries-sector-specific-compliance | ### A simple lottery is where:
* people are required to pay to take part
* prizes are allocated to participants
* prizes are allocated wholly by chance.
### A complex lottery is where:
* people are required to pay to take part
* prizes are allocated to participants
* prizes are allocated by a series of processes the first of which relies wholly on chance.
> Large society lotteries and local authority lotteries require a licence from the Gambling Commission.
>
>
> Small society lotteries can operate under a registration with their local authority.
>
>
> [Other types of lottery](/public-and-players/fundraising-and-lotteries) do not require specific permission but there are rules that must be complied with.
>
>
---
Last updated: 14 April 2021
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1105 | Using SMS short codes for lottery promotion | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/using-sms-short-codes-for-lottery-promotion | There is growing interest in using mobile phone SMS ‘short codes- in the promotion of lotteries. This involves licensed operators working with mobile phone operators and payment service providers.
This is a new initiative in the sector and may potentially involve an increased risk to compliance.
We have engaged with the following organisations about this initiative:
* [Phone-paid Services Authority (PSA) (opens in new tab)](https://psauthority.org.uk/)
* [Chartered Institute of Fundraising (opens in new tab)](https://ciof.org.uk/) and,
* [Association for Interactive Media and Entertainment (AIME) (opens in new tab)](https://aimm.co/tag/association-for-interactive-media-entertainment/) .
> As a licensed operator you must ensure that any product you offer is lawful and compliant with [the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/contents) and the [Licence conditions and codes of practice (LCCP).](/licensees-and-businesses/lccp/online)
>
>
We do not approve lottery schemes or provide advice about how they should be organised. However, if you are considering using SMS short codes you should first ensure that the arrangements are lawful and compliant with LCCP and that any potential increased risk to consumers and the licensing objectives has been assessed and, if necessary, policies and procedures put in place to mitigate those risks.
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1106 | Using SMS short codes for lottery promotion | Legal issues | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/using-sms-short-codes-for-lottery-promotion | Some of the issues you should consider and discuss with your legal advisors and any potential service provider before proceeding include:
* How will the social responsibility requirements such as age verification, customer interaction and self-exclusion be met given that these transactions could be anonymous apart from a telephone number. You need to assess the risk of problem gambling and underage play and, if necessary, introduce more stringent checks before a person is allowed to purchase a lottery ticket.
* All entrants must ‘receive a ticket- which includes all of the required information at the time they pay to enter a lottery, a participant cannot be simply directed to a website or elsewhere to collect their ticket. If the ticket is sent to the participant electronically they must be able to save or print the ticket.
* Payment must be made to the promoter before a person can be entered into a lottery.
* Arrangements must be in place to ensure the secure holding of lottery proceeds including ‘ring fencing- by a licensed ELM of all proceeds for the promoting society.
* Anyone who is not a member, officer or employee of a licensed society who is doing anything that constitutes ‘promoting- a lottery must hold an External Lottery Manager (ELM) licence issued by the Commission.
* Anyone providing or adapting remote gambling software for use in a remote lottery must hold a gambling software suppliers licence issued by the Commission.
* The Gambling Act 2005 only relates to Great Britain (England, Scotland and Wales). A lottery operating licence issued by the Commission only gives a society authority to promote a lottery in Great Britain. Members of the public resident in other parts of the UK including Northern Ireland and the Isle of Man and the Channel Islands have separate gambling laws and you may wish to contact the authorities in those jurisdictions if it is intended to offer this service throughout the UK.
You should also be aware of other regulatory requirements. For example, the PSA have introduced special conditions, which you will need to follow as of the 1 October 2018, in order to offer lotteries using SMS short codes.
---
Last updated: 7 June 2021
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1107 | Societies running lotteries for other good causes | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/societies-running-lotteries-for-other-good-causes |
> Lotteries can only be run to raise funds for good causes, they cannot be run for private or commercial gain.
>
>
Society lotteries are lotteries promoted by non-commercial societies.
Such societies are organisations that are established and conducted to raise funds to support the specific aims and objectives of the society, which could include any charitable, sporting, cultural or other non-commercial purpose.
They cannot be promoted for private or commercial purposes.
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1108 | Societies running lotteries for other good causes | Aims and objectives | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/societies-running-lotteries-for-other-good-causes | Societies holding a lottery licence with the Commission or a registration with their local authority can also run lotteries to raise funds for other good causes provided that the aims and objectives allow them to do so.
If the society-s current aims and objectives do not allow for this then the society can amend them by widening the aims and objectives to include raising funds for the additional good causes. The society would then be required to notify us or the local authority (dependant on who they hold their licence/registration with) of the amendment to their aims and objectives.
Societies who decide to expand their aims and objectives in order promote lotteries for other good causes must ensure that their marketing, terms and conditions and other information provided to consumers makes clear the name of the society promoting the lottery and its beneficiaries.
The promoting society must not imply that a beneficiary is promoting the society lottery. This provides transparency to consumers and allows them to understand who is promoting the lottery and the good cause that the society supports.
For societies that are registered charities or Community Interest Companies (CICs) they may need to check first that any potentially amended aims and objectives are compliant with relevant charity law or CIC requirements.
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1109 | Societies running lotteries for other good causes | Incidental lottery | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/societies-running-lotteries-for-other-good-causes | Alternatively, societies who would like to provide support to another good cause but do not wish to change their aims and objectives could decide to organise an ‘incidental lottery- at an event such as a fundraising dinner or fete.
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1110 | Societies running lotteries for other good causes | Workplace lottery | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/societies-running-lotteries-for-other-good-causes | Or a society could organise a lottery within their workplace. This type of lottery is called a ‘work lottery-.
There is more information on these types of lotteries as follows:
* [fundraising with lotteries or raffles at events](/public-and-players/guide/page/how-to-run-a-fundraiser-with-lotteries-or-raffles-at-events)
* [fundraising with the people you work with](/public-and-players/guide/page/how-to-run-a-lottery-with-people-you-work-with)
* [fundraising for people you live with](/public-and-players/guide/page/how-to-run-a-lottery-with-people-you-live-with)
* [fundraising for people you are in a club with](/public-and-players/guide/page/how-to-run-a-lottery-with-people-youre-in-a-club-with) .
---
Last updated: 7 June 2021
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1111 | Remote | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | Guidance and technical standards for businesses providing gambling online, through apps or via TV or other devices.
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1112 | Remote | Licences and Fees | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | * [Types of operating licence](#generic-types-of-operating-licence)
* [Licence activities](#remote-licences-and-fees-licence-activities)
* [Fees](#generic-fees-you-need-to-pay)
* [Calculating your fees](#generic-calculating-your-fees)
* [Personal Management Licences](#generic-personal-management-licences)
* [Annex A](#generic-annex-a-declaration)
* [Premises licence](#remote-licences-and-fees-premises)
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1113 | Remote | Legislation and Policies | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | * [Licence Conditions and Codes of Practice (LCCP)](#generic-legislation-and-policies-lccp)
* [Policies and guidance](#generic-legislation-and-policies-policies-and-guidance)
* [Technical standards](#generic-technical-standards)
* [Equipment technical requirements](#bingo-and-casino-technical-standards-bingo-and-casino-equipment-technical)
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1114 | Remote | Getting a licence | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | * [Information you-ll need for your application](#generic-getting-a-licence-information-youll-need-for-your-application)
* [Apply online](#generic-operating-licence-application)
* [Assessing your application](#generic-assessing-your-application)
* [Your licence](#generic-your-licence)
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1115 | Remote | When you hold a licence | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | * [Compliance](#generic-compliance)
* [What you need to tell us](#generic-what-you-need-to-tell-us-when-you-hold-a-licence)
* [Public Register](#generic-public-register)
* [Display of licensed status](#generic-display-of-licensed-status)
* [Making changes to your licence](#generic-making-changes-to-your-licence)
* [Surrendering your licence](#generic-surrendering-your-licence)
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1116 | Remote | Overview | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | Remote gambling includes all forms of gambling where players take part by using forms of remote communication.
This includes:
* the internet
* telephone
* TV
* radio, or
* any other kind of technology for gambling remotely.
Examples of remote gambling include:
* betting and slots apps on mobile phones and tablets
* self-service betting terminals in betting shops
* betting on live or virtual games and events online, such as [in-play betting](/licensees-and-businesses/guide/in-play-or-in-running-betting) .
You can read more about the legal definition of remote gambling in [Part 1 section 4 of the Gambling Act 2005 (opens in new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/4) .
You need a licence from us if you provide facilities for remote gambling to consumers in Great Britain.
### If your business is based abroad
You **must** have a licence to serve British consumers. For example, if your business is based in Malta, but your betting website or app can be played by people in England, Scotland or Wales.
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1117 | Remote | Guidance | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | Guidance for the remote sector.
* [**Guidance** What is gambling software?
An advice note, from June 2014 on the definition of gambling software, relevant statutory provisions and licence requirements.](/licensees-and-businesses/guide/what-is-gambling-software)
* [Key equipment
We do not specify where your remote gambling equipment must be located.](/licensees-and-businesses/page/key-equipment)
* [**Guidance** Live return to player performance monitoring of games of chance
As of 1 September 2016 remote operators are required to monitor the performance of the games they offer.](/licensees-and-businesses/guide/live-return-to-player-performance-monitoring-of-games-of-chance)
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1118 | Remote | Licences and Fees | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | There are different types of licence that remote businesses may need to apply for, you may need more than of the following:
* [operating licence](/licensees-and-businesses/guide/operating-licences)
* [Personal Management Licence](/licensees-and-businesses/guide/personal-management-licence)
* [Annex A for small-scale operators](/licensees-and-businesses/guide/annex-a-declaration) .
If you have premises which are providing remote gambling, you will need a [premises licence](/licensees-and-businesses/page/premises-licence) issued by local licensing authorities.
### Types of operating licence
An operating licence allows you to provide gambling activities to customers in Great Britain.
* [**Guidance** Operating licences
An operating licence is required to provide most gambling facilities in Great Britain.](/licensees-and-businesses/guide/operating-licences)
### Licence activities
You can apply to us for a licence to provide remote gambling.
## Activities
### Fees
The fees you need to pay depend on what you are applying for, and what your anticipated gross gambling yield (GGY) is.
* [**Guidance** Fees you need to pay and when you should pay them
Information on the fees for each licence, when these will need to be paid, and the payment methods you can use.](/licensees-and-businesses/page/fees-you-need-to-pay-and-when)
* [**Guidance** Annual fees
Information and guidance about annual fees for operating licence holders.](/licensees-and-businesses/guide/annual-fees)
* [**Guidance** Paying fees
Find out how to pay fees to the Gambling Commission.](/licensees-and-businesses/page/paying-fees)
### Calculating your fees
Our online fees calculator can help you with understanding the amounts of your application, first annual and annual fees.
* [**Service** Operating licence fees calculator
Calculate application, first annual and annual fees for operating licences.](https://secure.gamblingcommission.gov.uk/publicfeecalc "Link opens in a new tab")
### Personal Management Licences
Personal Management Licences allow people to work in certain roles in a gambling business.
Some businesses do not require personal licences to be held. Instead, you need to submit an Annex A. These are required for businesses with three employees or less.
* [**Guidance** Personal Management Licence (PML) guide
Information on PMLs, including the specific roles that require one, the fees you will have to pay, and how you can apply.](/licensees-and-businesses/guide/personal-management-licence)
### Annex A
If your business qualifies as a [small-scale operator](/licensees-and-businesses/guide/small-scale-operator) , you can submit an Annex A instead of applying for a Personal Management Licence.
* [**Guidance** Annex A guide
Information about Annex As and when they are required.](/licensees-and-businesses/guide/annex-a-declaration)
### Premises licence
If you intend to provide remote gambling from a premises, you will need a premises licence. You will need to apply to the licensing authority the premises is located in.
> You will need to apply for an operating licence **before** you apply for any premises licences.
>
>
* [**Guidance** Premises licence
Information on premises licences, which businesses require one, and what you need to do before applying.](/licensees-and-businesses/page/premises-licence)
### Information from other websites
We are not responsible for content on external websites. These links will open in a new tab.
[Find your local council on GOV.UK](https://www.gov.uk/find-local-council "Link opens in a new tab") |
1119 | Remote | Activities | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | * [All](#all)
* [Remote](#Remote)
* [Non-remote](#Non-remote)
## All activities
## Remote licence activities
## Non-remote licence activities
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1120 | Remote | All activities | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | * [Remote betting host real events licence
This licence will allow you to provide facilities for betting on real events (but not virtual events) by means of remote communication (for example, a website).
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-betting-host-real-events-licence)
* [Remote betting host virtual events licence
This licence will allow you to provide facilities for betting on virtual events (but not real events) by means of remote communication (for example, a website).
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-betting-host-virtual-events-licence)
* [Remote betting intermediary operating licence
This licence allows you to bring two or more betting parties together online in circumstances where you do not have liability for their bets. A remote betting intermediary is also commonly known as a betting exchange.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-betting-intermediary-operating-licence)
* [Remote betting intermediary trading rooms only licence
This licence allows you to run a trading room from a premises licensed by your local licensing authority (betting premises or track premises licence).
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-betting-intermediary-trading-rooms-operating-licence)
* [Remote bingo game host operating licence
This activity allows you to provide remote bingo under specific circumstances.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-bingo-game-host-operating-licence)
* [Remote bingo operating licence
This activity allows you to provide bingo games to customers via a website, apps, mobile, interactive TV or radio.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-bingo)
* [Remote casino game host operating licence
This activity allows you to provide remote casino under specific circumstances.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-casino-game-host-operating-licence)
* [Remote casino operating licence
This licence allows you to offer casino games to customers via a website, mobile phone, TV or other online service. This includes poker, roulette, blackjack and other casino games, as well as online slot games.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-casino-operating-licence)
* [Remote external lottery manager operating licence
This licence allows you to manage a lottery on behalf of a society or local authority.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-external-lottery-manager-operating-licence)
* [Remote gambling software licence
This licence allows you to manufacture, supply, install or adapt gambling software by means of remote communication.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-gambling-software-licence)
* [Remote gaming machine technical - full licence
This licence allows you to manufacture, supply, install, adapt, maintain or repair a gaming machine or a part of a gaming machine.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-gaming-machine-technical-full-licence)
* [Remote gaming machine technical – software operating licence
This licence allows you to manufacture, supply, install or adapt software for a gaming machine; to manufacture, supply, install or adapt gambling software.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-gaming-machine-technical-software-operating-licence)
* [Remote gaming machine technical – supplier operating licence
This licence allows you to to supply, install, adapt, maintain or repair (but not manufacture) a gaming machine or part of a gaming machine.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-gaming-machine-technical-supplier-licence)
* [Remote general betting limited licence
This licence allows you to provide facilities for betting only over the telephone or by email (in circumstances where you are manually processing the bets).
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-general-betting-limited-licence)
* [Remote general betting standard real events licence
This licence allows you to provide facilities for remote (online) gambling to consumers in Britain. It allows the provision of facilities for betting on real events (but not virtual events) by means of remote communication (for example, a website).
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-general-betting-standard-real-events-licence)
* [Remote general betting standard virtual events licence
This licence allows you to provide facilities for remote (online) gambling to consumers in Britain.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-general-betting-standard-virtual-events-licence)
* [Remote pool betting licence
This licence allows you to run a pool betting business online (or through other means of remote communication).
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-pool-betting-licence)
* [Remote society lottery licence
Society lotteries can only be run for good causes and cannot be run for private or commercial gain. Local authorities can promote a lottery to raise funds to spend on anything where they have power to incur expenditure.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-society-lottery-licence)
* [Non-remote linked licences gambling software
If you already hold, or are applying for, a full operating licence you may also, in certain circumstances, apply for a linked licence.
Further details and fees](/licensees-and-businesses/licences-and-fees/non-remote-linked-licences-gambling-software)
* [Remote linked licences gaming machine technical
If you already hold, or are applying for, a full operating licence you may also, in certain circumstances, apply for a linked licence.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-linked-licences-gaming-machine-technical)
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1121 | Remote | Remote licence activities | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | * [Remote betting host real events licence
This licence will allow you to provide facilities for betting on real events (but not virtual events) by means of remote communication (for example, a website).
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-betting-host-real-events-licence)
* [Remote betting host virtual events licence
This licence will allow you to provide facilities for betting on virtual events (but not real events) by means of remote communication (for example, a website).
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-betting-host-virtual-events-licence)
* [Remote betting intermediary operating licence
This licence allows you to bring two or more betting parties together online in circumstances where you do not have liability for their bets. A remote betting intermediary is also commonly known as a betting exchange.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-betting-intermediary-operating-licence)
* [Remote betting intermediary trading rooms only licence
This licence allows you to run a trading room from a premises licensed by your local licensing authority (betting premises or track premises licence).
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-betting-intermediary-trading-rooms-operating-licence)
* [Remote bingo game host operating licence
This activity allows you to provide remote bingo under specific circumstances.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-bingo-game-host-operating-licence)
* [Remote bingo operating licence
This activity allows you to provide bingo games to customers via a website, apps, mobile, interactive TV or radio.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-bingo)
* [Remote casino game host operating licence
This activity allows you to provide remote casino under specific circumstances.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-casino-game-host-operating-licence)
* [Remote casino operating licence
This licence allows you to offer casino games to customers via a website, mobile phone, TV or other online service. This includes poker, roulette, blackjack and other casino games, as well as online slot games.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-casino-operating-licence)
* [Remote external lottery manager operating licence
This licence allows you to manage a lottery on behalf of a society or local authority.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-external-lottery-manager-operating-licence)
* [Remote gambling software licence
This licence allows you to manufacture, supply, install or adapt gambling software by means of remote communication.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-gambling-software-licence)
* [Remote gaming machine technical - full licence
This licence allows you to manufacture, supply, install, adapt, maintain or repair a gaming machine or a part of a gaming machine.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-gaming-machine-technical-full-licence)
* [Remote gaming machine technical – software operating licence
This licence allows you to manufacture, supply, install or adapt software for a gaming machine; to manufacture, supply, install or adapt gambling software.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-gaming-machine-technical-software-operating-licence)
* [Remote gaming machine technical – supplier operating licence
This licence allows you to to supply, install, adapt, maintain or repair (but not manufacture) a gaming machine or part of a gaming machine.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-gaming-machine-technical-supplier-licence)
* [Remote general betting limited licence
This licence allows you to provide facilities for betting only over the telephone or by email (in circumstances where you are manually processing the bets).
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-general-betting-limited-licence)
* [Remote general betting standard real events licence
This licence allows you to provide facilities for remote (online) gambling to consumers in Britain. It allows the provision of facilities for betting on real events (but not virtual events) by means of remote communication (for example, a website).
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-general-betting-standard-real-events-licence)
* [Remote general betting standard virtual events licence
This licence allows you to provide facilities for remote (online) gambling to consumers in Britain.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-general-betting-standard-virtual-events-licence)
* [Remote pool betting licence
This licence allows you to run a pool betting business online (or through other means of remote communication).
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-pool-betting-licence)
* [Remote society lottery licence
Society lotteries can only be run for good causes and cannot be run for private or commercial gain. Local authorities can promote a lottery to raise funds to spend on anything where they have power to incur expenditure.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-society-lottery-licence)
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1122 | Remote | Non-remote licence activities | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | * [Non-remote linked licences gambling software
If you already hold, or are applying for, a full operating licence you may also, in certain circumstances, apply for a linked licence.
Further details and fees](/licensees-and-businesses/licences-and-fees/non-remote-linked-licences-gambling-software)
* [Remote linked licences gaming machine technical
If you already hold, or are applying for, a full operating licence you may also, in certain circumstances, apply for a linked licence.
Further details and fees](/licensees-and-businesses/licences-and-fees/remote-linked-licences-gaming-machine-technical)
|
1123 | Remote | Legislation and Policies | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | Gambling in Great Britain and the Gambling Commission's duties and responsibilities are detailed in the Gambling Act 2005.
The following legislation and policies are applicable to all licensees.
* [Gambling Act 2005
Gambling Act 2005 (link opens in new window)](https://www.legislation.gov.uk/ukpga/2005/19/contents "Link opens in a new tab")
### Licence Conditions and Codes of Practice (LCCP)
The LCCP outlines the requirements that all operating and personal licence holders must follow.
* [**Guidance** Licence Conditions and Codes of Practice (LCCP)
The LCCP outlines the requirements that all licensees must follow when running a gambling business or working in the industry.](/licensees-and-businesses/guide/lccp)
### Policies and guidance
The following guidance and policies are also relevant for all licensees.
* [**Policy** Licensing, compliance and enforcement under the Gambling Act 2005
The Commission-s approach to risk underpins its licensing, compliance and enforcement functions.](/policy/licensing-compliance-and-enforcement-under-the-gambling-act-2005)
* [**Policy** Statement of principles for licensing and regulation
The Commission's statement of principles for licensing and regulation.](/policy/statement-of-principles-for-licensing-and-regulation)
* [**Policy** Statement of principles for determining financial penalties
The Commission's statement of principles for determining financial penalties.](/policy/statement-of-principles-for-determining-financial-penalties)
* [**Guidance** Other policies, advice and guidance notes
We are gradually removing PDF's from our website. Find published advice notes and guidance in PDF's we've not yet converted.](/licensees-and-businesses/page/all-policies-advice-and-guidance-notes)
* [**Guidance** Anti-money laundering legislation
Anti-money laundering legislation and regulatory codes of practice operators must comply with.](/licensees-and-businesses/page/anti-money-laundering-legislation)
### Technical standards
All licence holders must comply with our technical standards and requirements. However, these standards should not be used as a measure of reliability, quality or security.
These standards and requirements permit equivalence between different types of technology and do not specify proprietary products or technologies.
Testing regimes for these standards will permit equivalent international standards (ISO).
* [**Guidance** Remote gambling and software technical standards (RTS) guidance
Gambling software and remote operating licence holders (including ancillary remote betting) are required to comply with our remote technical standards (RTS).](/licensees-and-businesses/guide/remote-gambling-and-software-technical-standards)
* [**Standards** Remote gambling and software technical standards (RTS)
Remote gambling and software technical standards under section 89 and section 97 of the Gambling Act 2005.](/standards/remote-gambling-and-software-technical-standards)
* [**Strategy** Testing strategy for compliance with remote gambling and software technical standards
Requirements for the timing and procedures for the testing of remote gambling products.](/strategy/testing-strategy-for-compliance-with-remote-gambling-and-software-technical)
* [**Guidance** Test houses
All gambling products must have been tested by an approved test house before they are released to the market.](/licensees-and-businesses/page/test-houses)
* [**Guidance** Gaming machine and remote games information requirements
This guidance explains our data and information requirements for games test, games annual audit and security audit reports.](/licensees-and-businesses/guide/gaming-machine-and-remote-games-information-requirements)
* [**Guidance** Technical standards: security requirements
Our testing strategy requires a third party annual security audit against particular sections of ISO/IEC 27001:2013.](/licensees-and-businesses/page/technical-standards-security-requirements)
* [**Guidance** Security audit advice
For holders of all remote gambling operator licences including specified remote lottery licences.](/licensees-and-businesses/guide/security-audit-advice)
### Equipment technical requirements
These technical requirements will regulate bingo and casino equipment in two different situations:
* equipment that is used on premises in Great Britain to provide casino games, and
* bingo games to the public and equipment used to provide such games in gambling premises by means of a remote communication system, where the provider is regulated by the Act.
These Requirements cover a variety of equipment including a 'live' roulette wheel and bingo tickets. They do not cover gaming machines.
* [**Standards** Bingo and casino technical requirements
Bingo and casino technical requirements under section 85 and section 89 of the Gambling Act 2005.](/standards/bingo-and-casino-technical-requirements)
|
1124 | Remote | Getting a licence | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | You can apply online for a licence from us to provide remote games.
A remote application can take up to x months to process depending on the complexity of your business.
> You will need to apply for an operating licence, before you apply for a premises licence from the local licensing authority.
>
>
### Information you-ll need for your application
Details of the information we'll ask you for when you apply for a licence.
* [**Guidance** What you need to send us when you apply for an operating licence
Find out which documents you will need when applying for an operating licence for your gambling business.](/licensees-and-businesses/guide/what-you-need-to-send-us-when-you-apply-for-an-operating-licence)
### Apply online
You can use our online service to apply for an operating licence.
If you have not used the service before, you'll need an email address only you can access to be able to create an account.
> Make sure you include all the information we ask for when you submit your application. If your application is rejected because something is missing, we will not refund your application fee.
>
>
* [**Service** Apply for a licence to operate a gambling business
Use this service if you want to apply for a licence to run a gambling business.](https://secure.gamblingcommission.gov.uk/ApplicationHub/Account/Login "Link opens in a new tab")
### Assessing your application
### If your application is rejected
We will send you a letter explaining which documents are missing and you'll need to reapply online.
You must provide the missing documents, as well as the documents you included originally, and you will need to pay the application fee again.
* [**Guidance** How we assess operating licence applications
Find out what we consider when assessing an operating licence application.](/licensees-and-businesses/guide/page/how-we-assess-operating-licence-applications)
### Your licence
If we grant you a licence to run a gambling business, you will be able to download a copy of your licence from eServices.
You must make your licence available for inspection by request from Gambling Commission staff, licensing authority staff or other official bodies such as the police or fire service.
* [**Service** eServices for operating licence holders
eServices allows operating licence holders to make changes to their licence, submit regulatory returns and other notifications to the Gambling Commission.](https://secure.gamblingcommission.gov.uk/EServices/Account/Login?ReturnUrl=%2feservices "Link opens in a new tab")
|
1125 | Remote | When you hold a licence | https://www.gamblingcommission.gov.uk/licensees-and-businesses/licences-and-fees/sector/remote | An important part of the Gambling Commission-s work is to ensure that licence holders are compliant. Compliance requires licence holders to understand and act in accordance with:
* the [Gambling Act 2005](https://www.legislation.gov.uk/ukpga/2005/19/contents)
* regulations (statutory instruments) made under the Gambling Act 2005
* the [Licence conditions and codes of practice (LCCP)](/licensees-and-businesses/lccp)
* any [technical standards](#generic-technical-standards) that apply to operating licences.
Compliance activity is based on risk and the risk that each licensed activity poses to the Gambling Commission-s licensing objectives.
The three licensing objectives are:
* keeping crime out of gambling
* ensuring gambling is conducted fairly and openly
* protecting children and vulnerable people from being harmed or exploited by gambling.
### Compliance
Guidance and information for running a compliant gambling business. Including information on how we carry out assessments, your responsibilities under the LCCP and other gambling-related legislation.
* [**Hub** Compliance
How we do compliance assessments and important compliance information.](/licensees-and-businesses/compliance)
### What you need to tell us
You are required to tell us about certain things that happen in your business, these are dependent on the licences and activities you hold.
* [**Guidance** What you need to tell us when you hold an operating licence
This guidance summarises all of the types of data and information that you are required to tell us when you hold an operating licence.](/licensees-and-businesses/guide/what-you-need-to-tell-us-when-you-hold-an-operating-licence)
* [**Guidance** Key events for operators
These guides will inform you of the key events you must tell us about when you hold an operating licence.](/licensees-and-businesses/guide/key-events-for-operators)
* [**Guidance** Guidance to operators for age verification test purchasing (non-remote)
This guidance explains what data we need from you about age verification test purchasing when you hold a non-remote operating licence.](/guidance/guidance-to-operators-for-age-verification-test-purchasing-non-remote)
* [**Guidance** Regulatory returns guidance
Guidance for information collected in the Regulatory Returns service by licensing sector.](/guidance/regulatory-returns-guidance)
* [**Guidance** Assurance statements
This guidance explains our data and information requirements if you are required to send us an assurance statement.](/licensees-and-businesses/guide/assurance-statements)
* [**Guidance** Gaming machine and remote games information requirements
This guidance explains our data and information requirements for games test, games annual audit and security audit reports.](/licensees-and-businesses/guide/gaming-machine-and-remote-games-information-requirements)
### Public Register
We provide details of all businesses and individuals we licence on our [Public Register](/public-register) service.
When you are issued a licence, we will display the details of your licence on the register.
This includes:
* your head office address
* details of the activities you are licensed for and from when
* domain and trading names you've told us about, and
* details of any regulatory action that has been carried out.
* [**Service** Public Register of licensees, premises and regulatory actions
The register lets you search and download information about licensed businesses, individuals and premises. You can also find information about regulatory action we have taken against licensees.](/public-register "Link opens in a new tab")
### Display of licensed status
If you hold a remote licence, the gambling websites and apps you provide must show details about your licence and link to your public register licence information.
> This is a condition of your licence under [LCCP Condition 8 - Display of licensed status](/licensees-and-businesses/lccp/1/8) .
>
>
### Making changes to your licence
You can make most changes to your licence online, using eServices.
You can:
* add or remove licence activities
* change the activity fee category up or down
* add or remove management or key people in the business
* add or remove trading names
* add or remove domain names for websites where you provide gambling.
> Some of these [changes require you to pay a fee](/licensees-and-businesses/guide/make-changes-to-your-operating-licence) .
>
>
* [**Service** eServices for operating licence holders
eServices allows operating licence holders to make changes to their licence, submit regulatory returns and other notifications to the Gambling Commission.](https://secure.gamblingcommission.gov.uk/EServices/Account/Login?ReturnUrl=%2feservices "Link opens in a new tab")
### Surrendering your licence
If you no longer need your licence, you can surrender it.
* [**Guidance** Surrender your operating licence
Find out how to surrender your operating licence partially or in full.](/licensees-and-businesses/page/surrender-your-operating-licence)
|
1126 | What is gambling software? | Introduction and background | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/what-is-gambling-software | The Gambling Commission (the Commission) published [Licence conditions and codes of practice (LCCP)](/licensees-and-businesses/lccp/online) (consolidated version) May 2014 which made a number of improvements to the previous version of the LCCP. One such provision [1](#1) requires licensed remote gambling operators to source their gambling software from Commission licensed gambling software businesses. During the consultation period and during a subsequent workshop held with the industry in January 2014 the industry sought further guidance on the application of this provision to explain what constitutes gambling software and the activities which require a gambling software licence to be held.
The Commission-s intention is to ensure a smooth transition of those operators currently legally targeting the British market from overseas to the point of consumption licensing which will be implemented under the Gambling (Licensing and Advertising) Act 2014. On this basis, the Commission has announced that the requirement for licensed remote gambling operators to source their gambling software from Commission licensed gambling software businesses came into force on 31 March 2015 [2](#2) .
This note is intended to help businesses consider whether they need a gambling software licence and furthermore, if they do, whether they also require any other form of Commission licence by virtue of their role in the provision of facilities for gambling. It may also be used to assist remote operators to assess whether their suppliers require a gambling software operating licence. It builds on and replaces previous information published by the Commission in the form of frequently asked questions. This document does not provide a definitive legal view, nor can this note cover each and every possible scenario that may arise. If in doubt businesses should seek their own legal advice.
## Definition of gambling software
## Relevant statutory provisions
## When is a licence required?
## Supplying gambling software
## Installing gambling software
## Manufacturing and adapting gambling software
## Do gambling software businesses require additional remote operating licences?
## Technical standards for gambling software
## Footnotes
---
Last updated: 13 July 2021
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1127 | What is gambling software? | Definition of gambling software | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/what-is-gambling-software | Gambling software is defined in [Section 41(2) of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/41) as “computer software for use in connection with remote gambling”, but does not include anything for use solely in connection with a gaming machine.
The Commission does not consider that software which is used by non-gambling businesses as well as gambling businesses, such as general infrastructure or business applications, to be gambling software. For example we do not intend to license companies that supply or install general Microsoft, Oracle or Apple applications.
This exclusion does not extend to cover the products produced using non-gambling business applications, such as Microsoft Visual Studio. For example, the resultant software produced from these tools would be considered gambling software if it meets the definition explained herein.
Subject to the exception as previously explained, the Commission considers any software which is designed for use in connection with remote gambling (including online gambling), that is intended to be used or is used by a gambling operator in the provision of facilities for gambling, to be gambling software. This includes any gambling specific application, such as software used in:
* virtual event web pages
* virtual event control
* bet capture/matching
* settlement
* random number generation
* gambling records [3](#3) , showing detailed results of games.
In our view, the purpose of gambling software licensing is to ensure that those manufacturing software which can impact on the fairness of remote gambling do so in a regulated environment. At its core this generally means the software that accepts and records gambling transactions, determines the result, calculates and allocates any wins to the customer-s account. It would not include software developed more generally for associated activities such as performance analytics, affiliate and CRM management.
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1128 | What is gambling software? | Relevant statutory provisions | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/what-is-gambling-software | There are two relevant provisions when considering who needs a gambling software operating licence, one set out in the Gambling Act 2005 the other in LCCP (consolidated) May 2014.
[Section 41(1) of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/41) states that ‘a person commits an offence if in the course of a business he manufactures, supplies, installs or adapts gambling software unless he acts in accordance with an operating licence-. This provision has been in place since the Act came into force in September 2007.
[Licence condition 2.2.1](/licensees-and-businesses/lccp/condition/2-2-1-gambling-software) ‘gambling software- which comes into force on 31 March 2015 states that:
“All remote casino, bingo and betting licences other than ancillary licences and remote betting intermediary (trading room only) licences
All gambling software used by the licensee must have been manufactured by the holder of a gambling software operating licence. All such gambling software must also be supplied to the Licensee by a holder of a gambling software operating licence. Such software must only be installed or adapted by the holder of such a licence.”
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1129 | What is gambling software? | When is a licence required? | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/what-is-gambling-software | Whether a licence is needed comes down to what constitutes the activities of manufacture, supply, installation and adaptation of gambling software.
Performance of any one of these functions will require a company to hold a gambling software licence. There will be businesses that conduct all or a number of those activities and in complex and extended supply chains businesses that may undertake one or more of thoseactivities.
|
1130 | What is gambling software? | Supplying gambling software | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/what-is-gambling-software | We do not expect to require a business to hold a gambling software licence if the extent of its involvement in the supply chain is that it purchases or otherwise acquiresgambling software from a person and sells or otherwise supplies it to a third party without any involvement itself in its manufacture, adaptation or installation.
The exception is that the final supplier to a Commission licensed operator will require a gambling software licence as set out in [Licence condition 2.2.1](/licensees-and-businesses/lccp/condition/2-2-1-gambling-software) , even if they actually perform no development/manufacturing, adaptation or installation activity. The Commission considers a licence to be required by such an entity simply by virtue of it entering into a supply contract with a Commission licensed operator.
However, there are circumstances where the final ‘supplier- is a company (IP holding company) whose only function is to hold the intellectual property rights subsisting in software developed by another company in its wider group (ie it has no tangible assets and does not adapt or install software). Such a group-s software development company (developer) which manufactures the software product may supply the product to the IP holding company through an intra-group arrangement, the IP holding company then selling or licensing the software to a Commission licensed operator.
In such circumstances, where the developer and the IP holding company are under common ownership, management and control, we may consider it appropriate to issue the developer with an ‘umbrella- licence covering supply through the agency of the IP holding company subject to the arrangement meeting our information note on ‘umbrella- licensing.
> In circumstances where an umbrella licence is not appropriate both the developer and IP holding company will require their own gambling software licence.
>
>
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1131 | What is gambling software? | Installing gambling software | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/what-is-gambling-software | The Commission considers that any person that installs gambling software on the system of a Commission licensed operator must do so in reliance on a gambling software licence issued by the Commission. If you already hold, or intend to apply for, a remote gambling operating licence with the Commission (eg remote casino licence) but also want to install software updates or otherwise manufacture, supply or adapt gambling software that is used in your own gambling business, you will require a gambling software licence but may in certain circumstances apply for a supplementary or ‘linked- gambling software licence.
|
1132 | What is gambling software? | Manufacturing and adapting gambling software | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/what-is-gambling-software | The activities of manufacturing and adapting are similar and relatively straight forward in that both activities involve developing gambling software to produce a finalised (or almost finalised) product. However this activity is also one of the more complex areas as multiple parties may be involved in the overall development project, each developing a piece of gambling softwarethat, in aggregate, create the ultimate gambling product. There may be various contractual arrangements in place to facilitate manufacture of such software and that govern the various relationships between the parties.
In such complex cases the Commission, when considering which parties require a gambling software licence, is interested in where the ultimate control of the development of the product sits. At a high-level the Commission understands that not all circumstances in which a third party is contracted to assist with software development are the same. Ultimately, we will be looking to determine whether the contract between the parties in essence involves purchase of a product or merely payment for time and expertise.
In circumstances where a business is purchasing a product and the overall control, design and development of the product sits with the third party (the development company) then the development company needs a gambling software licence.
This is in contrast to circumstances where a business (company Y) is purchasing time and/or skills and company Y retains control over the design and content of the product and the contracted third party is working to specific parameters, then company Y requires the gambling software licence and the contracted third party does not.
## The Commission when determining where control sits (and therefore who needs a licence) will want to understand:
Where the third party is only providing part of a game, such as artwork, under the control and design specifications of Company Y, then this indicates Company Y is in control and is the entity to hold a gambling software licence whereas the third party does not.
We would expect information about the respective indicators will be contained within a commercial contract. Operators are recommended to review their existing contracts to ensure this is the case and, where this is not the case, should consider how they would satisfy the Commission in the absence of such contract terms.
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1133 | What is gambling software? | The Commission when determining where control sits (and therefore who needs a licence) will want to understand: | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/what-is-gambling-software | * which company is responsible for the design and functionality of the software?
* which company is responsible for approving design changes?
* which company is responsible for the functionality and acceptance testing?
* which company is responsible for the quality assurance/regulatory compliance testing of the product?
* which company retains the IP for the product [4](#4)
* what the contract says in terms of responsibilities and liabilities.
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1134 | What is gambling software? | Do gambling software businesses require additional remote operating licences? | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/what-is-gambling-software | A gambling software licence only authorises the manufacture, supply, installation and adaptation of gambling software. It does not permit the provision of facilities for gambling and therefore any business that provides facilities for gambling (even if they hold a gambling software licence) will need a relevant remote operating licence: a casino, bingo, general betting, pool betting, betting intermediary or lottery licence. For example a business that holdsa gambling software licence but also hosts a poker network or a games platform will also require a remote casino operating licence as it is responsible for the fairness of the gambling.
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1135 | What is gambling software? | Technical standards for gambling software | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/what-is-gambling-software | All gambling software (eg that which runs a slots game or sports betting service) must meet the Commission-s remote gambling and software technical standards if it is made available to customers, for example via an online casino or sports betting service in reliance on a Gambling Commission operating licence. Any such gambling software must be tested in accordance with the testing strategy [5](#5) prior to the game being made available to customers.
However, if the gambling software (eg for a slots game) is only ever supplied to operators licensed only in other jurisdictions it does not need to comply with the Commission-s remote gambling and software technical standards.
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1136 | What is gambling software? | Footnotes | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/what-is-gambling-software | 1 [Licence condition 2.2.1](/licensees-and-businesses/lccp/condition/2-2-1-gambling-software) .
2 [Licence condition 2.2.1](/licensees-and-businesses/lccp/condition/2-2-1-gambling-software) .
3 This includes gambling software used in the facilities for gambling, eg software using player records as a basis for awarding bonuses in a gambling session.
4 IP that relates to the functionality of the game and does not include branding (eg superhero characters) that may be subject to their own IP.
5 Please refer to Annex A of the Testing strategy for compliance with remote gambling and software technical standards (version containing updates for transitional licensees June 2014).
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1137 | Contents | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/what-is-gambling-software | * [What is gambling software?](#)
* [Definition of gambling software](#definition-of-gambling-software)
* [Relevant statutory provisions](#relevant-statutory-provisions)
* [When is a licence required?](#when-is-a-licence-required)
* [Do gambling software businesses require additional remote operating licences?](#do-gambling-software-businesses-require-additional-remote-operating-licences)
* [Technical standards for gambling software](#technical-standards-for-gambling-software)
[Print this guide](#) |
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1138 | Key equipment | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/key-equipment | We will take into account a number of factors when considering applications in order to ensure that we have appropriate controls over the gambling offered and can ensure we can fulfil our compliance and enforcement activities.
The factors that will be considered will include ensuring:
* equipment is located in jurisdictions where operating a remote gambling business is permitted
* we have access to data on demand in order to conduct our regulatory activities. For example, local DPA laws must allow data to be transferred to us. If it cannot you could not locate equipment in that jurisdiction
* we can be satisfied that all data and records are accurate and complete.
In addition, we will require access to key staff at potentially short notice. It will be your responsibility to provide us with satisfactory assurance over the manner in which you structure and manage your business.
---
Last updated: 28 January 2021
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1139 | Live return to player performance monitoring of games of chance | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/live-return-to-player-performance-monitoring-of-games-of-chance | Remote operators are required to monitor the performance of the games they offer.
See [remote technical standards: section 5](/standards/remote-gambling-and-software-technical-standards/5-annex) .
Even though games must be tested prior to release (and after updates which may affect fairness) it is possible for a design, implementation or operational issue to evade identification during testing or deployment. This may affect the game-s RTP and result in either an overpaying or underpaying product.
If you provide applicable products you must have processes in place to measure the ongoing performance of games. These would usually be periodic reports or automated backend processes running over the stored transactional data.
You should raise alerts where a game appears to be falling outside the acceptable performance range. You should keep appropriate records as evidence of these processes as well as any more detailed investigations that have been performed as a result of an alert or an escalated customer complaint that warrants such an investigation.
Where a game indicates an error in its performance that is confirmed upon further investigation a key event must be submitted. Businesses in scope for the annual games testing audit (those who produce and update games and obtain the external testing by approved test houses) part of this audit will involve a review of RTP monitoring processes for adequacy.
While the focus of this guidance is on RNG driven products with a statistically defined RTP, such as slots games, there will be some performance monitoring applicable for other products as indicated in some of the examples. This will generally include products such as bingo, peer-to-peer poker, blackjack and virtual sports where skill or player choices can influence the return. For these products the focus of monitoring would instead be on the frequency and distribution of possible event outcomes to ensure they are acceptably random.
The overall aim of this monitoring is to ensure games are operating fairly as designed and advertised.
## How to calculate return to player (RTP)
## What volume of play should be achieved before measuring the actual RTP?
## Other considerations for live return to player performance monitoring of games of chance
## Measuring each stake level
## Measuring per channel
## Segregating base game activity from bonus features or progressive jackpots
## Virtual sports products
## What about live dealer casino games?
## Measuring progressive jackpots
## Key terms relating to live return to player performance monitoring of games of chance
---
Last updated: 1 November 2021
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1140 | Live return to player performance monitoring of games of chance | How to calculate return to player (RTP) | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/live-return-to-player-performance-monitoring-of-games-of-chance | By dividing the win and turnover figures generated from a game you can determine the actual RTP.
For example, if after one month of play a game, designed with a 91.68% RTP, has accrued £1,200,000 of turnover and £1,085,000 in wins the RTP can be calculated as follows:
1,085,000 / 1,200,000 = .9042
Therefore this game has achieved an actual RTP of 90.42%, which is below the designed RTP.
Importantly however the volatility of the game must also be considered as it will inform the allowable tolerance above or below the theoretical RTP. The tolerance will be wider when only a limited amount of play has been measured, but as the volume of play increases the tolerance will decrease.
After a significant amount of plays the actual RTP should be very close or equal to the theoretical RTP. To continue with the above example, if the game had a volatility (standard deviation) of 5.6 then the acceptable upper and lower tolerance will be as below:
| Number of games played | Range +/- | % from the mean [†](#ref-†) |
| --- | --- | --- |
| 50,000 | +/- | 4.90862 |
| 100,000 | +/- | 3.47092 |
| 200,000 | +/- | 2.45431 |
| 300,000 | +/- | 2.00393 |
| 400,000 | +/- | 1.73546 |
| 500,000 | +/- | 1.55224 |
| 600,000 | +/- | 1.41700 |
| 700,000 | +/- | 1.31188 |
| 800,000 | +/- | 1.22715 |
| 900,000 | +/- | 1.15697 |
| 1,000,000 | +/- | 1.09760 |
† This deviation from the mean is calculated with a 95% [confidence interval (opens in new tab)](http://www.wikihow.com/Calculate-Confidence-Interval) . This would mean a non defective game might still fall outside range approximately 1 in 20 tests. A higher confidence interval can be selected to reduce the chance of false alarms however caution should be exercised so as not to create tolerances that are too wide. The confidence interval should not exceed 99%, this would mean a non-defective game might fall outside range approximately only 1 in 100 tests. One measurement failure does not confirm the game/RNG is faulty, however sequential failures or a number of failures over a given frequency of measurements might.
So if 400,000 games had been played to accrue turnover and win figures of the example then the allowable tolerance will be 1.75 above or below 91.68. The game could return between 89.93% and 93.43% and still be considered to be performing as expected.
The game-s designers will have calculated the exact theoretical RTP as well as the game-s volatility (these figures will also be reviewed as part of the required external testing). These are the figures against which the actual performance should be measured.
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1141 | Live return to player performance monitoring of games of chance | What volume of play should be achieved before measuring the actual RTP? | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/live-return-to-player-performance-monitoring-of-games-of-chance | Measuring a game with only a small amount of play will be pointless as the tolerance will be too large for meaningful results. On the other hand waiting for millions of game plays to occur might mean a game with errors is not detected for an unreasonably long time. The volatility of a game will detail the acceptable tolerance range and must be taken into account regardless of the amount of play accrued. In this way measurements can be performed at any time and the volatility derived tolerance will determine whether the game is performing as expected or not.
As one instance of a remote game will be released to potentially thousands of players the game will quickly accrue thousands of game plays, particularly if it-s a popular game offered by multiple remote casinos. In cases where the game is offered via a B2B supplier they will likely hold the aggregated win and turnover figures for all of the B2Cs offering the game to their customers.
It will be up to the licensee (often based on the game designer-s instructions) to determine the measurement approach and frequency. One approach could be to perform daily measurements based on the previous 30 days of play, which will ensure fresh data sets are measured as time progresses. Measuring months and months of activity could hide errors that have been introduced by new updates. A wider date range (eg measuring a rolling 90 days of activity) could be measured in parallel so that a greater volume of play is considered (meaning the data will have a much finer tolerance).
Another approach instead of basing the measurement on a number of days could be to measure once X number of plays has been achieved. This would account for volume of play issue between popular and unpopular games.
The following example chart shows how the actual RTP will be expected to align with the theoretical RTP based on the volume of play
Chart?
The theoretical RTP is the centre line and the allowable tolerance above and below is represented by the green and red lines respectively and is determined by the game-s volatility. As more gameplay is achieved the actual RTP should be very close to the theoretical RTP.
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1142 | Live return to player performance monitoring of games of chance | Other considerations for live return to player performance monitoring of games of chance | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/live-return-to-player-performance-monitoring-of-games-of-chance | As remote gambling will record transactions in databases, and often at a very granular level, it easily facilitates more sophisticated measurements. The granularity of recorded gaming transactions and performance measurements should be commensurate with the game-s design and complexity, it should enable accurate performance monitoring. Below are more detailed examples, these could be performed as part of the normal monitoring processes, on an ad-hoc basis, or when investigating an apparent discrepancy.
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1143 | Live return to player performance monitoring of games of chance | Measuring each stake level | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/live-return-to-player-performance-monitoring-of-games-of-chance | A game that allows players to alter the stake per spin will result in turnover and win figures with mixed stake and wins from all bet levels. This will mean that activity played at max bet levels might drown out activity played at minimum bet levels. After a high number of games the influence of this will reduce, however measuring a game independently for each main bet level can give more accurate results. It can also detect if there is a problem that only exists with certain stake levels (eg a designed multiplier might not be working properly). Consideration should be given to monitoring games at a stake level where possible, particularly when investigating possible game faults.
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1144 | Live return to player performance monitoring of games of chance | Measuring per channel | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/live-return-to-player-performance-monitoring-of-games-of-chance | Remote games are often released separately on different platforms or channels (eg mobile, flash, download). Depending on the game-s design and architecture it could mean a game faults might only exist in one channel, this will be harder to detect if activity from all channels is aggregated into one measurement. We have seen instances where although the mobile version of a game was based on a previous flash version errors made in the adaption process have resulted in errors that only existed in the mobile version. Where there is the potential for fairness to be affected as a result of differences between channels then measurements should be made at both an aggregated level and per channel level.
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1145 | Live return to player performance monitoring of games of chance | Segregating base game activity from bonus features or progressive jackpots | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/live-return-to-player-performance-monitoring-of-games-of-chance | Where games are designed with complex bonus features the ability to monitor the game at both a base game and feature game level should be included. This will be particularly important where the feature has a large effect on the overall game-s RTP and is certainly important where a game implements a skill component in the feature (as the skill RTP component will vary greatly depending on players- actions). For example, some games will offer a 50/50 (double or quits) gamble feature; monitoring the overall game RTP including gambles will not necessarily confirm that the gamble is operating as a true and fair 50/50. Similarly for games connected to progressive jackpots, the base game should be measured independently of the progressive component.
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1146 | Live return to player performance monitoring of games of chance | Virtual sports products | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/live-return-to-player-performance-monitoring-of-games-of-chance | In a similar way to skill games virtual sports returns will mostly depend on the player choices and so there won-t be a single theoretical RTP. In its place operators could monitor the hit rate and distribution of each possible event outcome against the designed probability. For example if there are seven virtual horses in a racing event ensure each horse is winning the expected number of races according to their designed probability, as reflected by the offered odds (with over round). A similar approach might apply to roulette and blackjack.
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1147 | Live return to player performance monitoring of games of chance | What about live dealer casino games? | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/live-return-to-player-performance-monitoring-of-games-of-chance | The primary focus in RTP monitoring is on RNG driven software product. Live dealers use physical equipment (such as roulette wheels and decks of cards) to determine the results and there are a range of other integrity measures that surround such provision. For example, there will be controls over the supply (from casino standard manufacturers), installation and continuing operation of these devices. Fair shuffling of cards, ongoing integrity measurements of roulette wheels and dealing processes all have an influence over the fairness and will be part of everyday provision.
There is still merit in measuring certain outputs after a period of play, such as the distribution of results on a roulette wheel over an extended period to see if they are acceptably random. This information will be held in databases and can easily be measured.
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1148 | Live return to player performance monitoring of games of chance | Measuring progressive jackpots | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/live-return-to-player-performance-monitoring-of-games-of-chance | Games connected to progressive jackpot systems will need to be measured at a base game level (ie the game without the jackpot component). Jackpots are reaching very high values and their performance should be separately monitored. Given jackpots tend to be infrequent and large they will have high volatility ratings, therefore measuring their RTP might not be feasible. In its place other checks can be performed such as whether the frequency and distribution of jackpots and average jackpot levels are as expected. Designers of the jackpot system will be best placed to define the monitoring approach.
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1149 | Live return to player performance monitoring of games of chance | Key terms relating to live return to player performance monitoring of games of chance | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/live-return-to-player-performance-monitoring-of-games-of-chance | ### Theoretical RTP
This is the designed return to player percentage of the game, it will also be the advertised RTP of the game as displayed in the player facing rules, as per RTS 3C.
### Actual RTP
Calculated using the generated win and turnover figures of the live (operational) game. It shows the RTP the game has actually achieved for the past period as covered by the selected win and turnover amounts.
### Volatility
Most commonly the standard deviation of the game is used to represent the game-s volatility. A highly volatile game will have a larger tolerance and might be comprised of prizes falling into the ‘very large but rare- category. A low volatility game will be much more predictable and mostly comprised of prizes falling into the ‘small and often- category. Standard deviation is a mathematically calculated figure (square root of the game-s variance, where the variance depends on the game-s cycle and prize frequency).
### Turnover
The total of all stakes made on the game, this will include reinvested winnings awarded during play.
### Win
The total of all prizes awarded during game play. The GGY of a game will be the turnover minus win.
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1150 | Contents | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/live-return-to-player-performance-monitoring-of-games-of-chance | * [Live return to player performance monitoring of games of chance](#)
* [How to calculate return to player (RTP)](#how-to-calculate-return-to-player-rtp)
* [What volume of play should be achieved before measuring the actual RTP?](#what-volume-of-play-should-be-achieved-before-measuring-the-actual-rtp)
* [Other considerations for live return to player performance monitoring of games of chance](#other-considerations-for-live-return-to-player-performance-monitoring-of-games-of-chance)
* [What about live dealer casino games?](#what-about-live-dealer-casino-games)
* [Measuring progressive jackpots](#measuring-progressive-jackpots)
* [Key terms relating to live return to player performance monitoring of games of chance](#key-terms-relating-to-live-return-to-player-performance-monitoring-of-games)
[Print this guide](#) |
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1151 | Gaming machines in gambling premises | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/gaming-machines-in-gambling-premises |
> You must ensure category B gaming machines are only made available in a manner which is reasonably consistent with the [licensing objectives](/about-us/what-we-do) .
>
>
[LCCP: Social responsibility code 9.1](/licensees-and-businesses/lccp/2/9)
This applies to:
* non-remote betting
* non-remote bingo
* non-remote casinos.
The LCCP requirements are aimed at ensuring the policy objectives below are embedded consistently across the non-remote betting, bingo and casino sectors to ensure higher stake and prize gaming machines are made available in a socially responsible manner:
* with very few low-risk exceptions, gambling should be confined to dedicated gambling premises (casino, betting or bingo premises)
* distinctions between different types of licensed gambling premises are maintained
* gambling activities are supervised appropriately
* within bingo, betting and casino premises gaming machines must only be made available in combination with the non-remote gambling facilities named on the operating licence.
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1152 | Gaming machines in gambling premises | Enforcing these requirements | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/gaming-machines-in-gambling-premises | The approach to enforcing these requirements will continue to provide you with the flexibility required to determine how best to deliver the above outcomes within your business. It is not for us to prescribe how you operate your gambling premises or to encourage a tick box approach to compliance.
The ability to provide (and derive the commercial benefits) from [category B gaming machines](/licensees-and-businesses/guide/page/b1-gaming-machines) in your business, comes with a responsibility to ensure this is done in a manner consistent with the [licensing objectives](/about-us/what-we-do) . Compliance with existing and new regulatory requirements provides us, licensing authorities and the public with the necessary assurance.
Where we have concerns that an operating model has not taken sufficient account of regulatory requirements we believe the most proportionate and effective means of dealing with that, is through agreement or imposition of specific licence conditions relating to that particular business. This ensures any issues with specific operating models are addressed without impacting on the wider sector.
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Last updated: 8 June 2021
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1153 | Cashless payment technologies in gambling premises | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/cashless-payment-technologies-in-gambling-premises | Debit cards and contactless payments have risen in popularity. Advances in technology that enable payments via phone, watches and wristbands has coincided with a significant decline in the use of cash by consumers.
Gambling businesses are keen to make sure that they can offer their customers the same level of choice in payment options as other sectors of the leisure industry. Several operators have sought advice and guidance from us on their specific proposals for cashless facilities.
Whilst the developments in payment technology were not foreseen when the [Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/contents ) and supporting regulations were drafted, the legislation does, in most respects, permit operators to innovate and make cashless forms of payment available. However, the legislation also provides some important consumer protection measures. These aim to reduce the risks of customers spending more on gambling than they might be able to afford, or exceeding their budgets for a gambling session. There are specific restrictions in relation to payments to use gaming machines detailed in the following information.
We are supportive of innovation, as long as the way in which it is done is consistent with the licensing objectives. We expect operators to ensure they are mitigating and minimising the risks of gambling-related harm when they make new payment facilities available in their premises. Operators should also be leading the way on identifying how innovation in products and services can support innovation in protecting and empowering consumers. The responsibility rests with operators to be able to demonstrate that their payment solutions have been designed and made available with player protection measures in place. We may consider taking regulatory action in individual cases if, for example, an operator was to increase the risk of harm to its customers without providing appropriate mitigations. We may also consider options such as changes to our [Licence Conditions and Codes of Practice (LCCP)](/licensees-and-businesses/lccp/online) or advising government, in order to strengthen controls where necessary.
## Minimising gambling-related harm
## Considerations for operators
## Licence Conditions and Codes of Practice: cashless payment
## Checklist of considerations
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Last updated: 8 June 2021
Show updates to this content No changes to show.
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1154 | Cashless payment technologies in gambling premises | Minimising gambling-related harm | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/cashless-payment-technologies-in-gambling-premises | We encourage operators to consider how they can gather data both before and after the implementation of any measure so that they can demonstrate the impact of control measures.
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1155 | Cashless payment technologies in gambling premises | Considerations for operators | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/cashless-payment-technologies-in-gambling-premises | Research has shown that individuals can frequently gamble more money than they intended during gambling sessions. This leads to them making impulsive decisions that override their initial intentions to allocate a set amount of money to gamble with. Easy access to additional funds in gambling premises can therefore be a risk factor for problem gambling. [Key issues in product-based harm minimisation (opens in a new tab)](https://www.greo.ca/Modules/EvidenceCentre/Details/key-issues-in-product-based-harm-minimisation-examining-theory-evidence-and-pol) by Parke A, Parke J and Blaszczynski, A, was published in December 2016, and is a summary of research evidence.
Research also shows that non-cash payment methods in gambling can lead to consumers over-spending, as such methods require less thinking about the actual cost and affordability implications of a transaction compared to cash payments.
It is for operators to consider how player protection and empowerment can be most effectively delivered in practice.
They are best placed to assess which measures are:
* most effective in mitigating the risk of customers spending more on gambling than they might be able to afford
* which are most effective in enabling customers to retain control over their own gambling spend. Operators may need to take account of specific risks such as the layout of their premises or vulnerabilities for particular customers.
As part of their assessments on how they can best mitigate harm, operators must consider how they can facilitate the following. While there is no evidence to suggest what the ideal duration of a break should be, wherever possible the customer should at least be required to cease gambling at, and physically leave, the machine, terminal or table at which they are situated. This provides some time away from the gambling facilities before they are able to access and use new funds. This is consistent with the mandatory conditions attached to all premises licences that any ATM is located in a place that requires customers to cease gambling and leave the gambling product in order to use it.
In any circumstance where customers might be able to access new gambling funds with only a limited or no physical break from the gambling product (for example, where customers might be able to use a debit card to replenish an app-based digital gambling ‘wallet-), the operator must ensure that customers are otherwise provided a break from or an interruption in gambling before those funds can be used.
### Customers should be required to take a break from gambling before they access and use new funds to continue gambling
The purpose of the break or interruption in play is to reduce the risk of harm to players that could arise from them losing track of the time and money they have spent gambling. By interrupting their state of dissociation, a break in play can give customers an opportunity to evaluate their own gambling behaviours, and could therefore facilitate better control (see [Operator-based approaches to harm minimisation in gambling (opens in a new tab)](https://www.begambleaware.org/media/1177/obhm-report-final-version.pdf ) , by Parke A, Parke J, Blaszczynski, A and Rigbye J, published by Gamble Aware in 2014). A break or interruption in play could therefore involve, for example, slowing the transactional process and providing delays before new funds are made available to the player for use; perhaps combined with informative messaging, so as to support the player-s control and awareness of their gambling spend.
Operators should use these new opportunities to support innovation in the protection and empowerment of consumers. For example, cashless payment technology may assist operators in tracking their customers- play, allowing them to collect better data on their customers- gambling behaviour and therefore helping to inform an assessment of those who may be at risk of gambling-related harm.
The new technologies may also assist in the provision of tailored responsible gambling information to customers, including transactional information on the sums of money they have spent or withdrawn; or the development of player-led controls to enable better self-management of the customer-s gambling (eg allowing customers to set their own spend or withdrawal limits).
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1156 | Cashless payment technologies in gambling premises | Licence Conditions and Codes of Practice: cashless payment | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/cashless-payment-technologies-in-gambling-premises | There are certain conditions and codes of practice that must be adhered to when providing cashless payment facilities. These include, for example, the need to implement effective policies and procedures for minimising certain risks to the licensing objectives; and provisions that limit the circumstances in which credit can be provided, or prevent credit cards being accepted (and where the Gambling Act does not otherwise prohibit or restrict any such facility).
## Operators should refer to the LCCP for full details of the following relevant requirements:
[The Gaming Machines (Circumstances of Use) Regulations 2007 (opens in a new tab)](https://www.legislation.gov.uk/uksi/2007/2319/contents/made) provide prohibitions and restrictions on the use of debit and credit cards for payments to play machines, which are straightforward safeguards intended to prevent consumers from gambling more than they can afford via a card.
## Specific matters in relation to gaming machine payments
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1157 | Cashless payment technologies in gambling premises | Operators should refer to the LCCP for full details of the following relevant requirements: | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/cashless-payment-technologies-in-gambling-premises | * [Licence condition 5.1 – cash and cash equivalents, payment methods and services](/licensees-and-businesses/lccp/condition/5-1-1-cash-and-cash-equivalents)
* [Licence condition 6.1 – provision of credit by licensees and the use of credit cards](/licensees-and-businesses/lccp/condition/6-1-1-provision-of-credit)
* [Social responsibility code provision 3.7 – provision of credit](/licensees-and-businesses/lccp/condition/3-7-1-provision-of-credit)
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1158 | Cashless payment technologies in gambling premises | Specific matters in relation to gaming machine payments | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/cashless-payment-technologies-in-gambling-premises | Our view is that card payments that originate from contactless mobile payment systems such as Apple Pay, Android Pay or Samsung Pay should be regarded as the same as payments to use a gaming machine by means of a card itself. This is because the device used for such types of payment (eg a smartphone or watch) is essentially just a medium by which a contactless card payment is made (ie the debit card sat behind the payment system is charged directly and the customer-s bank account is debited; the same as for any payment where the debit card itself is used).
Both contactless card and mobile payment system transactions can be completed quickly, and so the risks to the consumer are largely identical.
The regulations also prescribe limits as to the amounts an individual can deposit onto a gaming machine in any single action, and separately the (non-refundable) amount a player can commit to play the machine. These measures were designed to ensure consumers make regular decisions as to how much money they wish to commit to play a machine, and they must be observed regardless of the means of payment. That is, whether the customer has inserted cash into the machine, or whether they have transferred funds from a debit card via indirect means, a TITO (ticket-in, ticket-out) method or an operator-provided app-based digital wallet, a customer must only be able to deposit and commit funds to the gaming machine-s meters in accordance with these limits.
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1159 | Cashless payment technologies in gambling premises | Checklist of considerations | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/cashless-payment-technologies-in-gambling-premises | We welcome sight of novel product or concept developments before they are deployed in the market. We do not approve individual products, and the responsibility rests with operators to ensure that their developments are compliant and will help to deliver the licensing objectives of the Gambling Act. It is recommended that businesses obtain their own legal advice in this regard.
To assist developers we have provided a broad checklist of items that we expect them to have considered before contacting us. The list is not exhaustive and must not be considered in isolation from the previous advice. It provides a basic list of key issues.
## In respect of the cashless technology product or system you are developing, you should be able to fully explain:
## There are also a variety of harm mitigation and consumer empowerment measures that you should consider. You should ask yourself:
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1160 | Cashless payment technologies in gambling premises | In respect of the cashless technology product or system you are developing, you should be able to fully explain: | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/cashless-payment-technologies-in-gambling-premises | * How you will make sure that consumers are required to have a break from gambling before they are able to access and use new funds.
* How you have satisfied yourself that you will be compliant with the Gaming Machine (Circumstances of Use) Regulations in respect of the use of debit or credit cards, payment limits and committed payment limits.
* What anti-money laundering controls you have considered in designing your solution. For example, would a player be able to fund a gambling product via cash and then withdraw funds via an app or digital wallet?
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1161 | Cashless payment technologies in gambling premises | There are also a variety of harm mitigation and consumer empowerment measures that you should consider. You should ask yourself: | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/cashless-payment-technologies-in-gambling-premises | * What information can your product provide to the consumer about their own gambling? For example, will consumers be able to access information on their transactional gambling history over certain periods of time?
* Are you able to provide tools that enable the user to manage their gambling? For example, can the consumer use the product to set limits on the amount of money they are able to deposit or spend over a certain period of time?
* What alerts would be triggered when a limit is reached? How will the limit-setting be made effective in terms of reducing the risk of gambling-related harm?
* Does the product allow for users to voluntarily stop themselves from using the product for gambling purposes for a period of time? Or provide a cooling off period period whereby the product cannot be used for gambling for a certain period of time?
* If the product or system is to be made available for use with different gambling products (including different categories of gaming machine), how will you ensure that your solution is adaptable and able to respond to the different nature of each gambling product and the associated risks or legal requirements?
* Does your solution enable you or a gambling operator to monitor customer behaviour. For example, the gambling spend or intensity of an individual customer) over a period of time?
* How can you prevent, or assist in the prevention of, underage gambling?
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1162 | Contents | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/cashless-payment-technologies-in-gambling-premises | * [Cashless payment technologies in gambling premises](#)
* [Minimising gambling-related harm](#minimising-gambling-related-harm)
* [Licence Conditions and Codes of Practice: cashless payment](#licence-conditions-and-codes-of-practice-in-cashless-payment-technologies)
* [Checklist of considerations](#checklist-of-considerations)
[Print this guide](#) |
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1163 | List of organisations for operator contributions | Information for operators | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/list-of-organisations-for-operator-contributions | From 1 January 2020 operators must direct their annual financial contribution for gambling research, prevention and treatment as required by [Licence Conditions and Codes of Practice (LCCP) SR code 3.1.1](/licensees-and-businesses/lccp/condition/3-1-1-combating-problem-gambling) to one or more of the organisations on the following list.
The purpose of this list is to demonstrate to operators how to be compliant with the LCCP requirement to make annual financial contributions to research, prevention and treatment.
## Operators must:
> We will collate information about LCCP RET contributions and publish this information at least annually.
>
>
Businesses can continue to donate funds to any organisation outside of the approved list, but such contributions will not be counted as LCCP RET contributions.
> Organisations will continue to be able to submit information to us and be added to the list on an ongoing basis. You must inform us whenever any of your information changes.
>
>
List of organisations for operator contributions | Name of organisation | Category | Type of organisation |
| --- | --- | --- |
| Addiction Recovery Agency Ltd (Ara) | Prevention Treatment | Charity |
| Beacon Counselling Trust | Prevention Treatment | Charity |
| Betblocker | Prevention | Charity |
| Betknowmore UK | Research Prevention Treatment | Charity |
| Bet On Me | Treatment | Private Company |
| Better Change | Prevention | Community Interest Company |
| Bournemouth University | Research | University Research |
| Breakeven | Prevention Treatment | Charity |
| Centre of Excellence in Responsible Gaming (CERG) | Research | Charity |
| Deal me out | Prevention | Community Interest Company |
| Epic Restart Foundation | Prevention | Charity |
| EPIC Risk Management | Prevention | Private Company |
| ESG Corporate Community Interest Company (trading as ESG Gaming) | Research Prevention | Community Interest Company |
| GambleAware | Research Prevention Treatment | Charity |
| Gambling Harm UK | Prevention | Charity |
| Gambling Treatment and Research Clinic, University of Sydney | Research | Public Research University |
| GamCare | Prevention Treatment | Charity |
| Gordon Moody Association | Treatment | Charity |
| International Center for Responsible Gaming (ICRG) | Research Prevention | Charity |
| JC Foundation Trust | Prevention | Community Interest Company |
| Leon House Health & Wellbeing Ltd | Treatment | Private Company |
| Nowt Left to Lose | Prevention | Community Interest Company |
| Racing to School | Prevention | Charity |
| Red Card Gambling Support Project CIC | Prevention | Community Interest Company |
| Reframe Coaching | Prevention | Charity |
| Responsible Gambling Council (Canada) | Research | Charity |
| Sport in Mind | Prevention Treatment | Charity |
| The Forward Trust | Treatment | Charity |
| The University of Liverpool | Research | University research |
| Young Gamers & Gamblers Education Trust (YGAM) | Research Prevention | Charity |
## The process for organisations who wish to be on the list for annual LCCP RET contributions
## Information requirements for approved organisations for RET contributions
## LCCP RET contributions data – April 2021 to March 2022
## LCCP RET contributions data – January 2020 to March 2021
## Files
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1164 | List of organisations for operator contributions | Operators must: | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/list-of-organisations-for-operator-contributions | * make an annual financial contribution to each of research, prevention and treatment. Your annual financial contribution must be to organisations for the purposes of delivering research, prevention and treatment. Payments for paid for services should not be counted as LCCP RET contributions
* ensure that these donations go to one or more organisation on the following list
* ensure that they have no connection to the recipient organisation
* report information accurately in their annual or quarterly regulatory return to the Gambling Commission about the destination(s) of their payment and the amounts that have been contributed. This includes ensuring that there is no duplication of data across multiple licences.
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1165 | List of organisations for operator contributions | The process for organisations who wish to be on the list for annual LCCP RET contributions | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/list-of-organisations-for-operator-contributions | Gambling businesses are required to make an annual financial contribution to organisations which deliver or support research into the prevention and treatment of gambling-related harms, harm prevention approaches and treatment for those harmed by gambling (RET contributions). We do not specify an amount which may be contributed as this could be seen as imposing a levy, which is a power reserved for Parliament.
> Being on the LCCP RET list is not a guarantee of receiving any financial RET contributions.
>
>
We maintain a list to demonstrate to operators how to be compliant with the LCCP requirement to make financial contributions. It ensures that if businesses make contributions to organisations which work in other areas unconnected to reducing gambling harms in Britain, these amounts will not be considered compliant or published in the figures on LCCP RET contributions. Businesses can continue to donate funds to any organisation outside of the LCCP RET list, the only change is that such contributions will not be counted as LCCP RET contributions.
Organisations seeking to be on the list of organisations to which gambling businesses may direct their RET contributions should provide information to the Commission to help us assess their suitability. This will include working to reduce gambling harms in Britain, and the need for independent oversight or regulation for all organisations. It will also include:
* in the case of research: the commissioning of research that is of general benefit, not solely or mainly for the purposes of informing the organisation-s other work
* in the case of treatment: a connection to the existing National Gambling Treatment Service and/or existing NHS England, Scotland or Wales mental health or addiction services.
There is no cost for working with the Commission to be on the list, but we recommend that organisations read [the guidance on expectations and the procedure for removal](/licensees-and-businesses/guide/lccp-ret-list-procedure-and-guidance-for-removal-of-organisations) before submitting the [LCCP RET Information form](#71RYGqUXTWmc0ZL4lXZaeq) .
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1166 | List of organisations for operator contributions | Information requirements for approved organisations for RET contributions | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/list-of-organisations-for-operator-contributions | Approved organisations for RET contributions are required to send us quarterly returns listing the financial contributions they have received from operating licence holders. Returns consist of a templated MS Excel Open XML format spreadsheet, a blank copy of which is sent to approved organisations after their approval. Completed spreadsheets are to be submitted to [retdata@gamblingcommission.gov.uk](mailto:retdata@gamblingcommission.gov.uk) within 28 days of the end of each UK financial quarter.
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1167 | List of organisations for operator contributions | LCCP RET contributions data – April 2021 to March 2022 | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/list-of-organisations-for-operator-contributions | The data table below shows the data that has been reported to us from organisations on the LCCP RET list on contributions received during the period April 2021 to March 2022. The table covers 12 months of data.
LCCP RET contributions data – April 2021 to March 2022 | Recipient | April to June 2021 | July to September 2021 | October to December 2021 | January to March 2022 |
| --- | --- | --- | --- | --- |
| Action against Gambling Harms | 0.00 | 0.00 | 2,500.00 | 1,500.00 |
| Betblocker | 5,000.00 | 0.00 | 10,000.00 | 6,394.00 |
| Betknowmore UK | 36,500.00 | 91,600.00 | 25,000.00 | 35,750.00 |
| Deal me out | 0.00 | 1,600.00 | 26,600.00 | 64,650.00 |
| EPIC Risk Management | 166,950.00 | 58,200.00 | 200,934.00 | 58,200.00 |
| ESG Corporate Community Interest Company (trading as ESG Gaming) | 0.00 | 0.00 | 0.00 | 34,884.00 |
| GambleAware | 2,245,445.00 | 5,821,140.00 | 2,416,342.00 | 24,219,897.00 |
| GamCare | 479,056.00 | 451,521.00 | 895,708.00 | 0.00 |
| Gordon Moody Association | 51,445.00 | 93,732.00 | 255,281.00 | 300,196.00 |
| Leon House Health and Wellbeing Ltd | 100,000.00 | 121,000.00 | 24,400.00 | 0.00 |
| Red Card Gambling Support Project CIC | 0.00 | 0.00 | 10,000.00 | 0.00 |
| Responsible Gambling Council (Canada) | 0.00 | 0.00 | 0.00 | 5,947.00 |
| Sport in Mind | 0.00 | 0.00 | 250.00 | 0.00 |
| Young Gamer and Gamblers Education Trust (YGAM) | 43,902.00 | 427,781.00 | 420,438.00 | 525,015.00 |
| Total | 3,128,298.00 | 7,066,574.00 | 4,287,453.00 | 25,252,433.00 |
|
1168 | List of organisations for operator contributions | LCCP RET contributions data – January 2020 to March 2021 | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/list-of-organisations-for-operator-contributions | The data table shows the data that has been reported to us from organisations on the LCCP RET list on contributions received during the period January 2020 to March 2021. The table covers 15 months of data spanning two financial years.
LCCP RET contributions data – January 2020 to March 2021 | Recipient | January to March 2020 | April to June 2020 | July to September 2020 | October to December 2020 | January to March 2021 |
| --- | --- | --- | --- | --- | --- |
| Action against Gambling Harms | 0.00 | 0.00 | 500,000.00 | 0.00 | 0.00 |
| Addiction Recovery Agency Ltd (Ara) | 0.00 | 0.00 | 311,200.00 | 0.00 | 0.00 |
| Betblocker | 5,500.00 | 32,250.00 | 50,000.00 | 10,000.00 | 20,957.88 |
| Betknowmore UK | 0.00 | 0.00 | 54,320.00 | 46,832.19 | 130,669.31 |
| EPIC Risk Management | 0.00 | 51,250.00 | 57,500.00 | 156,750.00 | 108,750.00 |
| GambleAware | 4,074,507.55 | 1,940,985.25 | 692,508.98 | 2,552,392.59 | 14,544,811.10 |
| GamCare | 0.00 | 0.00 | 0.00 | 0.00 | 544,204.53 |
| Gordon Moody Association | 124,845.22 | 129,543.35 | 72,067.84 | 283,383.53 | 183,959.33 |
| Leon House Health and Wellbeing Ltd | 0.00 | 0.00 | 31,500.00 | 100,000.00 | 0.00 |
| Red Card Gambling Support Project CIC | 0.00 | 0.00 | 0.00 | 11,000.00 | 0.00 |
| Sport in Mind | 0.00 | 0.00 | 0.00 | 250.00 | 1,130.00 |
| Young Gamers & Gamblers Education Trust (YGAM) | 220,000.26 | 801,789.40 | 579,120.96 | 546,308.00 | 1,095,319.02 |
| Total | 4,424,853.03 | 2,955,818.00 | 2,348,217.78 | 3,706,916.31 | 16,629,801.17 |
|
1169 | List of organisations for operator contributions | Files | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/list-of-organisations-for-operator-contributions | 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/) .
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---
Last updated: 11 April 2023
Show updates to this content Removed 'Action against Gambling Harms' from the list.
Added 'Nowt Left to Lose' and 'Centre of Excellence in Responsible Gaming (CERG)' to the list.
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1170 | Contents | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/list-of-organisations-for-operator-contributions | * [List of organisations for operator contributions](#)
* [The process for organisations who wish to be on the list for annual LCCP RET contributions](#the-process-for-organisations-who-wish-to-be-on-the-list-for-annual-lccp-ret)
* [LCCP RET contributions data – April 2021 to March 2022](#lccp-ret-contributions-data-april-2021-to-march-2022)
* [LCCP RET contributions data – January 2020 to March 2021](#lccp-ret-contributions-data-january-2020-to-march-2021)
[Print this guide](#) |
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1171 | Self-exclusion in social responsibility | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/self-exclusion-in-social-responsibility | If you interact with customers you must provide the option of self-exclusion for those who would like to take steps to stop gambling.
[LCCP: Section 3.5 social responsibility code and ordinary code](/licensees-and-businesses/lccp/condition/3-5-2-non-remote-ordinary-code)
|
|
1172 | Self-exclusion in social responsibility | How to help your customers when they want to self-exclude | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/self-exclusion-in-social-responsibility | Entering into a self-exclusion is a significant step, and you should do what you can to ensure that the individual understands what it means. For example, that it is a commitment not to attempt to gamble for a minimum period of six months. Generally speaking, it is considered that this length of self-exclusion is necessary to enable an individual to deal with their problem gambling behaviour.
However, a customer who has decided to take the step of self-excluding should be able to do so immediately and should not be required to wait.
The customer should be offered the opportunity to speak to someone appropriate about self-exclusion, in some circumstances this may not be possible immediately. However, arrangements should be made as soon as possible, and if a customer is certain that they wish to self-exclude and does not wish to wait until they have spoken to a suitably trained and experienced member of staff, then they should be able to do so at once.
---
Last updated: 18 June 2021
Show updates to this content No changes to show.
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1173 | Regulatory settlements applied for socially responsible purposes | Background | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/regulatory-settlements-applied-for-socially-responsible-purposes | When the Commission takes regulatory action against a gambling operator, an outcome of that action can include a payment in lieu of the financial penalty the Commission might otherwise impose for breach of a licence condition. This is set in accordance with the [Statement of Principles for Determining Financial Penalties](/policy/statement-of-principles-for-determining-financial-penalties) .
We publish the details of those enforcement cases and regulatory settlements on our news page. For more information, see our approach to [regulating the gambling industry](/about-us/what-we-do) .
A regulatory settlement can include payment to an organisation for socially responsible purposes.
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1174 | Regulatory settlements applied for socially responsible purposes | Information about destinations of regulatory settlements to be applied for socially responsible purposes | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/regulatory-settlements-applied-for-socially-responsible-purposes | The Commission reviews proposals for destinations of regulatory settlements.
Projects that have been approved since March 2019 are listed on our [destinations of regulatory settlements to be applied for socially responsible purposes](/licensees-and-businesses/page/destinations-of-regulatory-settlements-to-be-applied-for-socially) page.
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1175 | Regulatory settlements applied for socially responsible purposes | Strict rules for operators | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/regulatory-settlements-applied-for-socially-responsible-purposes | Under the terms of a settlement, there is to be no publicity or benefit for the operator in connection with the regulatory settlement.
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1176 | Regulatory settlements applied for socially responsible purposes | Information for proposals for destinations of regulatory settlements | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/regulatory-settlements-applied-for-socially-responsible-purposes |
> Submissions for regulatory settlement funding are currently closed.
>
>
We recommend you review [our guidance for submitting a proposal for regulatory settlement funding](/guidance/guidance-for-submitting-a-proposal-for-regulatory-settlement-funding) before making a submission, and be aware of our deadlines.
If you want to know more about the group that will make the decisions about these proposals, review the [Social Responsibility Funds Group Terms of Reference](/licensees-and-businesses/guide/social-responsibility-funds-group-terms-of-reference) .
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1177 | Regulatory settlements applied for socially responsible purposes | Files | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/regulatory-settlements-applied-for-socially-responsible-purposes | 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/) .
[Stage 1 Proposal Form - Regulatory Settlements
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---
Last updated: 15 December 2022
Show updates to this content Callout added to indicate that proposals are now closed.
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1178 | 3.5.6 - Multi-operator non-remote SR code | https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/3-5-6-multi-operator-non-remote-sr-code | Applies to:
All non-remote casino, bingo and betting licences (except in respect of the provision of facilities for betting in reliance on a track premises licence) and holders of gaming machine general operating licences for adult gaming centres
**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 offer customers with whom they enter into a self-exclusion agreement in respect of facilities for any kind of gambling offered by them at licensed gambling premises the ability to self-exclude from facilities for the same kind of gambling offered in their locality by any other holder of an operating licence to whom this provision applies, by participating in one or more available multi-operator self-exclusion schemes.
|
|
1179 | 3.4.1 - Premises-based customer interaction | https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/3-4-1-customer-interaction | Applies to:
All non-remote licences (except non-remote lottery, gaming machine technical, gambling software and host licences); only the following remote licences – ancillary remote bingo, ancillary remote casino, ancillary remote betting, remote general betting limited, and remote betting intermediary (trading rooms only).
**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 interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling. This must include:
- identifying customers who may be at risk of or experiencing harms associated with gambling.
- interacting with customers who may be at risk of or experiencing harms associated with gambling.
- understanding the impact of the interaction on the customer, and the effectiveness of the Licensee-s actions and approach.
- Licensees must take into account the Commission-s guidance on customer interaction.
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|
1180 | Customer interaction: formal guidance for premises-based operators | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators |
> This guidance applies to premises-based operators and is currently in effect.
>
>
> This is an HTML version of this guidance. You can also view or download the [original customer interaction guidance for premises-based operators (PDF)](#4ae78UgfVJADGplhwuPC56) published in July 2019.
>
>
Premises-based licensees are required to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, as set out in [Social Responsibility Code Provision 3.4.1](/licensees-and-businesses/lccp/condition/3-4-1-customer-interaction) of the Licence Conditions and Codes of Practice (LCCP).
A requirement to LCCP with effect from 31 October 2019 (as amended 12 September 2022) requires premises-based licensees to take into account the Commission-s guidance on customer interaction. This guidance is structured along the three key outcomes operators are expected to meet.
These are, to:
* **identify**
* interact
* evaluate .
This guidance sets out why customer interaction is a requirement, makes our expectations clear, and suggests ways you could meet them. This includes learnings from research and some ways that gambling operators have found worked for them and their customers.
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1181 | Customer interaction: formal guidance for premises-based operators | How to use this guidance | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | The purpose of this guidance is to share knowledge based on research, current practice and lessons learned in order to support licensees in determining how they can meet the outcomes. It sets out why customer interaction is important and makes our expectations clear. Not all of the content of the guidance will be relevant to all operators, but licensees must take it into account and be able to demonstrate how they have done so.
Following the guidance is no guarantee that all customers experiencing or at risk of harm will be identified. The guidance is not the only source of information which operators should use to help them develop their own processes, and licensees should also keep up to date with published research and other sources.
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1182 | Customer interaction: formal guidance for premises-based operators | How we will use this guidance | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | For compliance and enforcement purposes, we will expect licensees to demonstrate how their policies, procedures and practices meet the required outcomes. This can be through implementing relevant parts of the guidance or demonstrating how and why implementing alternative solutions equally meet the outcomes.
Our understanding of gambling harms and how they manifest is constantly evolving, so for the purposes of raising standards, protecting consumer interests, and preventing harm to consumers, we will update and re-issue guidance where new evidence or risks emerge which may have a meaningful impact on how the outcomes can be met.
## Identifying the right customers
## Understanding the impact of gambling harms
## Using the right indicators for your business
## Affordability and a customer-s personal circumstances
## Vulnerability
## Spotting harmful gambling
## The role of staff
## Identify: questions to consider
## Interacting with the customer
## Offering help and support
## The role of staff
## Keeping records
## Interact: questions to consider
## Evaluate
## Understanding the impact of individual interactions
## Evaluating the effectiveness of the approach
## The role of staff
## Evaluate: questions to consider
## Files
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1183 | Customer interaction: formal guidance for premises-based operators | Identifying the right customers | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | You need to know:
* the types of markers and behaviours that could indicate harm relevant to online gambling, and
* how to spot when those indicators should trigger an interaction.
You need to put together what you know about the customer, with the relevant indicators of harm, to decide whether you need to interact. More knowledge about what to look for, with effective processes for monitoring customer behaviour, can mean quicker and better-informed decisions.
Some indicators of harm, such as high staking behaviour, can look similar to VIP and high-value customer activity. Even if you think the customer can afford it, they may still be experiencing gambling harms. Your enhanced contact with your VIPs means you have many opportunities to get to know them well and make better informed decisions.
### Identify
We expect you to: * Use a range of indicators relevant to your business that you can observe and monitor. Do not rely on financial indicators alone. Where trigger points or thresholds are used, they should be realistic, and remember that not every customer who is experiencing or at risk of harm will trigger every indicator.
* Monitor customer activity and behaviour so that you are able to interact early and quickly. Invest in appropriate systems and staff to manage your customer interaction process effectively.
* Make sure your process keeps pace with any increase in demand – through general growth or seasonal, promotional or other variations which might mean you are busier than usual.
* Train your staff to know their roles and responsibilities, and ensure they are supported and given the tools and skills they need to be able to act promptly when they spot or are alerted to indicators of harm, including those among your VIP and monitored customers.
* Ensure that your customers are not put at any greater risk of harm as a result of your premises being busier or quieter than usual. You need to protect your customers regardless of these factors.
* Think about the protection of new customers – you know less about them, so you may not know what their regular gambling pattern looks like. This means that alternative measures must be applied.
* Take safer gambling seriously for all customers including VIPs and not let commercial considerations override customer protection.
* Make meaningful records of all interactions with customers. Make these records available to staff and use them to aid decision-making. This should also take place in circumstances where an interaction has been ruled out. For example, because the customer is displaying signs of agitation.
* Even if you think your sector is 'lower risk', all forms of gambling present risks and you should understand the prevalence of gambling harms for the type of gambling products you offer and implement appropriate processes.
* Actively promote tools such as voluntary machine alerts, and ensure all your customers have access to information about safer gambling and the support available.
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1184 | Customer interaction: formal guidance for premises-based operators | Understanding the impact of gambling harms | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | In 2018 the Gambling Commission published research (Wardle et al 2018) on understanding the full range of gambling harms and the impact this can have on society. This research defined gambling harms as the ‘adverse impacts from gambling on the health and wellbeing of individuals, families, communities and society-. This can include loss of employment, debt and crime – gambling harms can also have detrimental impacts on physical and mental health and relationships, and at its worst, gambling can contribute to loss of life through suicide.
Gambling harms cannot be solely measured in terms of finance and resources. This is why we expect you to use a range of indicators in order to identify customers who may be experiencing harms.
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1185 | Customer interaction: formal guidance for premises-based operators | Using the right indicators for your business | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | Change compared with previous gambling activity is a general trigger for customer interaction. Building up your knowledge of your regular customers is key to helping you spot changes in their behaviour.
You should use a range of indicators. This is not an exhaustive list, but your indicators should include the following.
### Time indicators
Amount of time spent gambling, visit frequency or length of stay on the premises, leaving and then returning to the premises.
### Spend
Amount and frequency of deposits, large losses, using multiple or more expensive payment methods, declined payments, appearing to spend more than they originally intended.
### Behaviour or appearance
Such as signs of distress, agitation, or changes which could be an indication that gambling is having a negative impact on a customer-s wellbeing.
### Use of gambling management tools
Previous self-exclusions or previous customer interactions, or playing through machine alerts.
### Customer-led contact
Information or hints from the customer, frequent complaints about not winning, or talking about the negative impacts of their gambling.
### Play indicators
chasing losses, erratic betting patterns and gambling on higher risk products, or unusual markets or outcomes on which the customer is unlikely to have been able to make an informed choice. People who bet in-play may place a higher number of bets in a shorter time period than people who bet in other ways, as [in-play betting](/licensees-and-businesses/guide/in-play-or-in-running-betting) offers more opportunities to bet.
### A ‘big win- or a windfall
Research (Parke and Parke 2017) shows high staking following a win could hide or even lead to harmful behaviour. Suddenly having more money than usual can lead to increasing staking, which can lead to harms not associated with wealth or resources.
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1186 | Customer interaction: formal guidance for premises-based operators | Affordability and a customer-s personal circumstances | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | Historically, gambling operators have not systematically considered customer affordability when developing their customer interaction policies. Many have used deposit or loss thresholds as a main or sole prompt for a customer interaction, but these have often been set at levels that were inappropriately high, in comparison to the average amount of money that the majority of people have available to spend on leisure activities.
This has led to a number of examples of customers spending more than they could afford, and this not being identified sufficiently early, as seen in much of the Commission-s compliance and enforcement casework since 2017.
Operators should aim to identify those experiencing or at risk of harm and intervene to try to reduce harm at the earliest opportunity. Reliance on deposit or loss thresholds that are set too high will result in failing to detect some customers who may be experiencing significant harms associated with their gambling. It is therefore imperative that threshold levels are set appropriately.
Open source data exists which can help operators assess affordability for their British customer base and improve their risk assessment for customer interactions. Thresholds should be realistic, based on average available income for your customers. This should include the Office of National Statistics (ONS) publications on levels of household income. See the [ONS information on personal and household finances (opens in new tab)](https://www.ons.gov.uk/peoplepopulationandcommunity/personalandhouseholdfinances) .
In considering these thresholds, you should be aware of the difference between ‘disposable income- and ‘discretionary income- which refers to the amount left after living costs are taken into account, but it does still include many other unavoidable costs. Most people would consider it harmful if they were spending a significant amount of their discretionary income on gambling.
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1187 | Customer interaction: formal guidance for premises-based operators | Vulnerability | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | Life events or changes to an individual customer-s circumstances may mean that a person becomes more or less vulnerable to experiencing gambling harms. Those circumstances could include bereavement, loss of income or other factors, as follows. It will not always be obvious or clear to an operator when such events have occurred, but knowing your customers, and ensuring staff ask questions when there are potential signs of vulnerability, will help to determine whether those individual circumstances present an increased risk.
As part of ‘know your customer- and developing customer interaction policies and procedures, operators should consider the factors that might make an individual more vulnerable to experiencing gambling related harms.
Factors include:
* **personal and demographic** - if the individual is experiencing poor physical or mental health, physical or cognitive impairment, suffering side effects from a brain injury or medication or has an addiction
* **situational** - if the individual is experiencing financial difficulties, is homeless, is suffering from domestic or financial abuse, has caring responsibilities, experiences a life change or sudden change in circumstances
* **behavioural** - if an individual has a higher than standard level of trust or high appetite for risk
* **market-related** - if an individual is engaged in an activity which is highly complex; that they have a lack of knowledge and/or experience of the market
* **access** - if an individual has difficulty accessing information because of poor literacy or numeracy skills, knowledge, dyslexia.
We have seen examples through our casework of customers who should have received some interaction but did not, including customers who were particularly vulnerable, and more susceptible to experiencing gambling harms.
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1188 | Customer interaction: formal guidance for premises-based operators | Spotting harmful gambling | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | How you monitor activity depends on your business. For some very small operators, manual monitoring may work. Larger operators will need comprehensive systems, which could include a mix of automated and manual processes and should draw on all available sources of data to give a comprehensive picture of the customer-s gambling.
Options for spotting harmful gambling include:
* Reports on activity where relevant, for example from observation or loyalty carded play, particularly if the play is linked to online play
* Sharing of information by staff about concerns
* Customer interaction forms, day diary with flags
* Utilising back office systems and alerts where they exist.
The right information can mean better and quicker decisions. The customer interaction records you keep should give staff a more complete picture of the customer-s previous activity, which will help to inform decisions.
Your customers should not be at more risk because your premises are either busier or quieter than usual. You should ensure you have appropriate levels of well-trained staff on duty to meet the licensing objectives.
Because VIP customers can also experience harm, it is good practice to carry out a safer gambling check when upgrading customers to VIP status and keep this under review. You should also use these opportunities to carry out checks for Anti-Money Laundering (AML). This could also help you to support customers who have had major wins.
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1189 | Customer interaction: formal guidance for premises-based operators | The role of staff | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | It is important that all staff receive training so that they are aware of the signs that could indicate that a customer may be experiencing harms associated with gambling.
This is not an exhaustive list, but you should ensure that:
* Staff are trained to identify the signs of harm and refer back to documents that include the types of behaviour that may trigger customer interaction at an appropriate moment. Staff should know how to escalate a situation if they are unsure or require support.
* Staff understand how indicators of harm could be displayed differently in VIP or ‘high-value- customers and know how to spot the signs.
* As a minimum, staff receive training at induction as well as refresher training.
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1190 | Customer interaction: formal guidance for premises-based operators | Identify: questions to consider | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | These include:
* Are you curious about your customers?
* Are your indicators relevant to your gambling facilities and customers?
* How do you decide the right level of your thresholds?
* Do all appropriate staff have access to customer interaction records?
* How do you assess the risks posed by new and unfamiliar customers?
* Is staff training on customer interaction meaningful and engaging?
* Do you take into account all relevant information and act quickly?
* Does the structure and layout of your premises help or hinder identifying customers you need to interact with?
* Do you have any blind spots which mean that you are unable to monitor all customer activity?
* Is spend monitored across different products for individual customers?
* Do you offer the same level of protection for all your customers, no matter how long they have been a customer, or whether they are VIPs?
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1191 | Customer interaction: formal guidance for premises-based operators | Interacting with the customer | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | When you are concerned that a customer may be experiencing harm, acting early and quickly could help stop or prevent the harm worsening. It is important in a premises environment that you interact with the customer in a timely manner whilst the opportunity presents itself.
For some customers, making them aware of why you are concerned may be enough to prompt them to think and make a change. Some customers will need more support or advice.
Your interactions should have an outcome. Knowing what impact your interaction has had will help you support the customer and help to keep improving your approach. To achieve this, it is vital to keep good records and make them available to staff to inform decisions.
### Interact
We expect you to: * Be curious, and if you spot behaviour or vulnerabilities that could indicate harm, to act on it.
* Ensure your staff have access to the information and support they need, such as customer interaction records, so that they are able to make decisions about how to interact and can do so discreetly.
* Interact in a way that is appropriate to the severity of the potential harm. You should trial and evaluate different approaches to achieve this. **Importantly, this may include refusing service or ending the business relationship.**
* Think about what information you should give the customer to help them understand why you are interacting with them, such as describing the type of behaviour they display or practical help or support where appropriate.
In gambling premises, many of your interactions are likely to be face-to-face, so it is important for staff to be prepared in advance of carrying out a customer interaction.
You should consider:
* What do you need to know from the customer and what do you already know about them?
* What information do you want to give them?
* How many times have you already interacted with the customer?
* What outcome do you want to achieve?
* Is the customer behaving in a way which might inhibit an interaction at this point?
### A customer interaction has three parts
These are:
1. Observation – behaviour or activity you have spotted or something the customer tells you.
2. Action – contact to prompt the customer to think about their gambling, for you to find out more, and an opportunity for you to offer information or support.
3. Outcome – what you or the customer did next. In some cases, you may need to monitor the customer-s gambling to spot any change which may prompt further action.
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1192 | Customer interaction: formal guidance for premises-based operators | Offering help and support | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | Encourage customers to think about their gambling. Their responses will help you work out the right kind of help and support to offer.
You will need to direct some customers to information about safer gambling and/or suggest appropriate gambling management tools. You might need to signpost them to sources of help and specialist support from organisations which deal with advice and treatment for problem gambling.
You must also make information about safer gambling readily available to customers, as well as information about problem gambling.
You will need to interact with some customers a number of times. Your records of previous interactions with customers will help you decide how to provide the right help and support.
Feedback from consumers shows that they often respond better to being informed about their behaviour and why, rather than being “told” what to do. But for some customers, and particularly if the behaviour continues to cause concern, you may need to take a more proactive approach. In some cases, you may need to take action for the customer, which could mean refusing service.
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1193 | Customer interaction: formal guidance for premises-based operators | The role of staff | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | You should ensure that your staff:
* understand the types of interaction that could take place and how to interact appropriately. For example, they may only need a brief intervention.
* know the type of help or support to offer, such as information, signposting customers to specialist support or the gambling management tools which are available. These may be the minimum required under the LCCP or tools you offer which go beyond minimum requirements.
* know the circumstances and process for refusing service to customers, such as requesting a customer to leave or barring a customer.
* understand their respective responsibilities and who is designated to carry out customer interactions, if only certain staff members are authorised to interact.
* are advised how to deal with situations where customers demonstrate signs of agitation, distress, intimidation, aggression or other behaviours that may inhibit customer interaction, and what to do if the interaction does not take place at that time.
Whilst training on the legislative framework is important, staff also need to be trained on the skills and techniques they need to help them carry out customer interactions.
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1194 | Customer interaction: formal guidance for premises-based operators | Keeping records | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | Good record keeping allows you to demonstrate when and why you have interacted with customers and helps with ongoing monitoring of customers.
You should:
* Keep records of all customer interactions and, where an interaction has been ruled out, the reasons for this. Where an interaction has taken place at a later date, this should also be recorded.
* Make use of all relevant sources of information to guide and deliver effective customer interactions, including your records of previous interactions.
Good records should include:
* the behaviour or activity before the interaction.
* the change in behaviour or prompt for the interaction.
* how you interacted and what was said or done, for example advice or suggestions to help the customer manage their gambling, or to take a break from their gambling, and
* what happened next.
You should also record situations where an interaction was prompted but did not take place, and how you followed that up.
In some cases, you will need to monitor the customer-s gambling to spot behaviours which could indicate further harm.
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1195 | Customer interaction: formal guidance for premises-based operators | Interact: questions to consider | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | * Where concerns arise, are you able to intervene early and engage with a customer at the right time?
* How do you ensure your staff are prepared and able to carry out interactions?
* Are your staff able to carry out customer interactions discreetly?
* Are your staff aware of and trained to carry out different levels of interaction?
* Have you allocated the right level and kind of resources to be able to interact with customers effectively when you have concerns?
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1196 | Customer interaction: formal guidance for premises-based operators | Evaluate | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | By evaluate, we mean to understand impact and effectiveness in two ways:
* did an individual customer interaction have a positive outcome for the customer, and
* does your overall approach to customer interaction work?
To help with the latter, the Advisory Board for Safer Gambling published an evaluation protocol in 2016 for the industry to use when designing evaluations.
> Find out more about the [National Strategy to Reduce Gambling Harms](/about-us/reducing-gambling-harms) , including the [evaluation protocol](/strategy/national-strategy-to-reduce-gambling-harms/evaluation-gambling-commission-actions) and further research on gambling-related harms.
>
>
### Evaluate
We expect you to: * Understand the impact of individual interactions on a consumer-s behaviour and whether, or what, further action is needed.
* Evaluate the effectiveness of your approach by trialling and measuring impact.
* Embed lessons learned and best practice across the business and collaborate to share across the industry.
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1197 | Customer interaction: formal guidance for premises-based operators | Understanding the impact of individual interactions | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | In this context, by impact we mean a change in the customer-s gambling activity which could be attributed to the interaction. An important part of this is whether the customer has understood the information or advice you gave.
Not every customer who receives an interaction will require active follow up, but many will. In these cases, follow up activity should be proportionate to the severity or extent of the harm being displayed. This approach will help you target your resources where they are most needed.
Understanding the impact of the interaction on the customer includes being able to look at and compare:
* the behaviour before the interaction.
* the change in behaviour or prompt for the interaction.
* how you interacted – what was said or done, and
* what happened next.
Some ways to work out impact include:
* Did the customer start using gambling management tools independently or following your advice?
* If you use email, did the customer click through to safer gambling information from your tracked links?
* Was there a positive change in behaviour? Did the customer-s gambling seem to change after the interaction?
* You could also follow up and ask the customer whether they found the interaction helpful or not.
* Is there a need for further or follow up action?
You may already quality assure individual customer interactions by spot- checking records. As well as checking that customers are getting the right support, this can also identify staff development needs and highlight good practice that you can share across your business and across the industry.
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1198 | Customer interaction: formal guidance for premises-based operators | Evaluating the effectiveness of the approach | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | Records of interactions can provide useful evidence of what types of indicators, methods of interacting and options for providing support work well for customers. They will help to inform an evaluation of the effectiveness of your overall approach to customer interaction. Good evaluation helps you to understand which aspects of your approach are the most effective at identifying the right customers, and the types of tools or support that work well to help customers manage their gambling in a way that works for them.
The following measures could help to work out whether your approach is working well:
* Customer retention.
* Reduction in complaints.
* The appropriate number of customer interactions in relation to the size of your customer base or footfall, and the type of gambling you offer, as follows.
You should know and understand the prevalence of at-risk gambling among your customer base. A starting point is the [combined health surveys](/news/article/gambling-commission-publishes-latest-combined-health-survey) of England, Scotland and Wales (Gambling Commission 2018). This data is broken down to gambling activity type, and by region.
However, rates will vary significantly between geographical areas and localities, and research shows that problem gambling rates in urban areas are likely to be higher than the national average. Further information on this topic can be found in the Research Report Problem Gambling in Leeds (Kenyon et al 2016). When looking at the potential percentage of your customers who may be experiencing harm, remember to consider the percentage of gamblers participating in that activity and not the percentage of the adult population.
Currently the only industry-wide quantitative measure of identifying and interacting with customers who may be experiencing harms associated with gambling is data on the numbers of customers who received an interaction, submitted to the Commission as part of regulatory returns. We have clarified the definitions in regulatory returns to offer guidance on what should be included in a customer interaction (incident) log and make clearer what should be recorded.
Your log should include as a minimum:
* the identity or other identifier of the customer involved
* the behaviour or activity that prompted the interaction
* the advice or support given, and
* the outcome of the interaction.
Keeping your policies and procedures under review and up to date by taking into account research and industry best practice will help you to identify customers you should be interacting with, which will help you target your resources where they are most needed, in ways which may lead to better outcomes.
You should also review your internal controls following the publication of a regulatory settlement, to address any similar weaknesses which could exist in your own processes.
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1199 | Customer interaction: formal guidance for premises-based operators | The role of staff | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | Your staff have an important role to play to understand whether your approach works.
As a minimum, you should:
* Ensure that records of all customer interactions are made by staff and used to aid decision making. Such records should be used for evaluation purposes, for example, dip sampling for quality assurance purposes. Or, to assess whether a customer changed their behaviour as the result of an interaction.
* Train staff to recognise when follow-up activity to an interaction is required.
* Ensure that staff use customer interaction records as a decision-making tool.
* Ensure that staff are properly supported in carrying out effective interventions.
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1200 | Customer interaction: formal guidance for premises-based operators | Evaluate: questions to consider | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-premises-based-operators | * Do you know how many of your customers may be experiencing some level of harm associated with gambling?
* How do you know you are delivering positive outcomes for your customers?
* How could you improve on your policies and procedures?
* How could you share your good practice with the industry?
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