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1601 | Annex B: Key characteristics of bingo - Revised, January 2014 | Key characteristics of bingo | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/annex-b-key-characteristics-of-bingo-revised-january-2014 | * Players- payments must be divided between stakes and participation fees, although they may consist entirely of stake or entirely of participation fee.
* The way that division is made must be transparent to the player and in particular there must be a notice displayed showing participation fees in a way that makes it readily accessible to players. Any stakes must be returned to players, either in the particular game or in a subsequent one.
* Each game must be played to a single set of numbers, or symbols; drawing a second set starts a new game.
* Any game formats must clearly be presented as offering the player the opportunity to participate in a game of bingo. This includes numbers (or symbols) being marked off and the game having the appearance of a game of bingo (rather than a gaming machine).
* Any ‘added prize money- stated to be available in a game, once offered (and unless the offer is specifically limited in time), must remain available until won in that or subsequent games ie: by way of rollover; the operator cannot claim them back. Prizes clearly advertised as being offered only for a limited period can be claimed back if they are not won. All prizes offered in each game must be transparent to the player.
* Games may operate with a single player, provided there is a meaningful opportunity for other players to participate in the same game.
* The game must comply with the requirements of the Gambling Act 2005 and must be capable of audit, where appropriate, to demonstrate legal compliance. Such audit data will demonstrate for example how players- payments are split between stakes and participation fees and that all stakes are returned to the players, either in that game or subsequent games.
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1602 | Annex B: Key characteristics of bingo - Revised, January 2014 | Characteristics specific to bingo machines | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/annex-b-key-characteristics-of-bingo-revised-january-2014 | * The speed of game, including the time taken to join, should be similar to that of an interval game. Games must not have an auto play function.
* The machines must provide a facility for the player to extend the playing time by a minimum of 100%.
* The amount that can be staked in a set period should be no greater than on a Category C machine.
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1603 | Annex B: Key characteristics of bingo - Revised, January 2014 | Regulations specific to bingo machines in AGCs/FECs | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/annex-b-key-characteristics-of-bingo-revised-january-2014 | * the nature or size of the prize offered may not be determined by the number of persons playing; or the amount paid for or raised by the game
* bingo machines in FECs will not be made available in areas where children and young people (those under the age of 18) are permitted.
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1604 | Annex B: Key characteristics of bingo - Revised, January 2014 | References | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/annex-b-key-characteristics-of-bingo-revised-january-2014 | 1 [Gambling Act 2005 section 288 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/288) – Meaning of ‘prize gaming- Gaming is prize gaming for the purposes of this Act if neither the nature nor the size of a prize played for is determined by reference to:
(a) The number of people playing
(b) The amount paid for or raised by the gaming.
2 The 2005 Act-s definition of a stake is: ‘an amount paid or risked in connection with gambling and which either
(a) is used in calculating the amount of winnings or value of the prize that the person making the stake receives if successful
(b) is used in calculating the total amount of winnings or value of the prizes in respect of the gambling in which the person making the stake participates.-
3 Case law establishes that the fact that a player in bingo may purchase more than one card does not make the chances unequal as between players; such a player will have paid for two or more chances to win and not a chance to win two or more times what another player can win.
[Previous page
Annex A: Banker-s games and equal chance gaming - January 2014](/licensees-and-businesses/guide/page/annex-a-bankers-games-and-equal-chance-gaming)
---
Last updated: 26 May 2021
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1605 | Residential gaming | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/residential-gaming | Residential gaming is one of two forms of what's known as 'private gaming' - which can only take place somewhere the public can't access.
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1606 | Residential gaming | Where it can take place | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/residential-gaming | Anywhere the public does not have access to. For example, a hostel or halls of residence.
You do not need a licence for this kind of gaming.
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1607 | Residential gaming | What you must do | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/residential-gaming | You must:
* physically play the game together, at the same physical location
* make sure at least half of the people playing live at that location.
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1608 | Residential gaming | What you can't do | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/residential-gaming | You can't:
* charge any entry fees - this includes any kind of admission fee or fee for taking part
* make a profit from the game - even if you intend to donate the profits to charity or good causes
* deduct from or ‘levy- on money staked or won by players in the game. It doesn-t matter if the charge is voluntary or compulsory
* run the game as part of a trade or business
* play the bingo virtually, or online in any way.
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1609 | Residential gaming | Example | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/residential-gaming | A group of four friends want to play a game of bingo at their student halls. They invite two more friends over to join them and everyone plays the game at the same physical location, using a bingo board game.
Every player pays a £1 stake and this makes up the pot of money which can be won.
[Previous page
How to run bingo legally](/licensees-and-businesses/guide/how-to-run-a-game-of-bingo) [Next page
Domestic gaming](/licensees-and-businesses/guide/page/domestic-gaming)
---
Last updated: 1 July 2021
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1610 | Domestic gaming | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/domestic-gaming | Domestic gaming is one of two forms of what's known as 'private gaming' - which can only take place somewhere the public can't access.
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1611 | Domestic gaming | Where it can take place | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/domestic-gaming | In a private dwelling, such as a house. This can also include other types of accommodation used as, or as part of, a home. For example, motorhomes, houseboats and garden sheds.
Under 18s can take part.
You do not need a licence for this kind of gaming.
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1612 | Domestic gaming | What you must do | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/domestic-gaming | You must:
* make sure the game takes place in the house or accommodation where you usually live
* play the game on a domestic occasion. For example, a dinner party or other small gathering in your home.
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1613 | Domestic gaming | What you can-t do | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/domestic-gaming | You can-t:
* hold the bingo game outside of a residential setting
* play the game in group accommodation, such as student halls of residence. See [residential gaming](/licensees-and-businesses/guide/how-to-run-a-game-of-bingo#residential-gaming) instead
* charge any entry fees - this includes any kind of admission fee or fee for taking part
* make a profit from the game - even if you intend to donate the profits to charity or good causes
* play the bingo virtually, or online in any way.
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1614 | Domestic gaming | Example | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/domestic-gaming | Danielle invites her friends over to her house for her babyshower. One of the activities is a game of bingo. Everyone will physically play the bingo game at Danielle-s house and everyone has the same chance of winning.
Every player pays a £1 stake and this makes up the pot of money which can be won.
[Previous page
Residential gaming](/licensees-and-businesses/guide/page/residential-gaming) [Next page
Online bingo](/licensees-and-businesses/guide/page/running-online-bingo)
---
Last updated: 11 November 2022
Show updates to this content Following an audit the 'residential gaming' link has been updated.
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1615 | Online bingo | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/running-online-bingo | You need a licence to run any kind of online or 'remote' bingo. This includes any type of game where players would be taking part virtually. For example, you need a licence to run a bingo game played using social media or on a video call, using platforms such as Zoom.
! **Warning If you run an online bingo game without a licence you are breaking the law.** ### Online bingo includes bingo offered using any form of 'remote' communications
This includes:
* internet
* telephone
* television
* radio
* any other type of electronic or other technology that enable communication.
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1616 | Online bingo | Why you need a licence | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/running-online-bingo | The legal basis for bingo means that even if you have good intentions (such as playing for charity) you could face a fine or criminal prosecution.
You can read more in [Section 6 of the Gambling Act 2005 (opens in new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/6) .
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1617 | Online bingo | What you must do | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/running-online-bingo | If you want to run **online** bingo you-ll need to [apply for a remote bingo operating licence](/licensees-and-businesses/licences-and-fees/remote-bingo) with us. You-ll also need to comply with the relevant legal requirements and our regulatory codes.
If you don-t want to apply for a licence, we-d strongly recommend choosing another activity. You can find fundraising ideas on the [NHS Charities Together website (opens in new tab)](https://www.nhscharitiestogether.co.uk/fundraising-pack/) .
[Previous page
Domestic gaming](/licensees-and-businesses/guide/page/domestic-gaming) [Next page
Bingo using a club gaming permit](/licensees-and-businesses/guide/page/bingo-using-a-club-gaming-permit)
---
Last updated: 10 June 2021
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1618 | Bingo using a club gaming permit | Where it can take place | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-using-a-club-gaming-permit | In the following places:
* [members- clubs](/licensees-and-businesses/guide/members-clubs-and-commercial-clubs#what-is-a-members-club) - such as working men-s clubs, branches of the Royal British Legion clubs and with political ties, or
* miners- welfare institutes.
You do not need a licence for this kind of gaming. However, you'll need to apply for a [club gaming permit](/licensees-and-businesses/guide/club-gaming-and-machine-permits#club-gaming-permit) with your local authority.
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1619 | Bingo using a club gaming permit | What you must do | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-using-a-club-gaming-permit | You must make sure:
* the game is played as an equal chance game (essentially all players must have the same chance of winning)
* the gaming is not the main purpose of the club – it can only be an additional activity
* every player is a member of the club, or, a guest of a member
* children and young people under 18 are not allowed in the area of the club where the gaming is taking place
* total stakes and prizes for the game do not exceed £2,000 in a 7 day period. Otherwise, this will be classed as ‘high turnover- bingo. If this happens, you-ll need to tell us. If it happens more than once, then you-ll need a licence
* you charge a maximum of **£3** in participation fees, per person and per day.
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1620 | Bingo using a club gaming permit | What you can-t do | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-using-a-club-gaming-permit | You can-t:
* run ‘linked- games with players on other premises. For example, you cannot run a linked game between two branches of the Royal British Legion based in two locations
* deduct from or ‘levy- on money staked or won by players in the game. It doesn-t matter if the charge is voluntary or compulsory
* play the bingo virtually, or online in any way.
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1621 | Bingo using a club gaming permit | Example | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-using-a-club-gaming-permit | A local branch of a political club want to run a bingo night. Usually, the club meet to discuss environmental issues. Everyone taking part in the bingo night will be a member of the club, or a registered guest.
There will be no under 18s taking part, and no children or young people will be allowed in the function room where the bingo will take place. The total stakes and prizes will be less than £2,000. The club applies for a club gaming permit and their request for the permit is granted.
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1622 | Bingo using a club gaming permit | Gaming machines | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-using-a-club-gaming-permit | A club gaming permit also allows you to provide a maximum of 3 [gaming machines](/licensees-and-businesses/guide/gaming-machine-categories) from categories B3A (with agreement), B4, C or D.
You can read more about [club gaming permits](/licensees-and-businesses/guide/club-gaming-and-machine-permits#club-gaming-permit) .
[Previous page
Online bingo](/licensees-and-businesses/guide/page/running-online-bingo) [Next page
Exempt gaming in clubs and miners' welfare institutes](/licensees-and-businesses/guide/page/exempt-gaming-in-clubs-and-institutions)
---
Last updated: 6 July 2021
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1623 | Exempt gaming in clubs and miners' welfare institutes | Where it can take place | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/exempt-gaming-in-clubs-and-institutions | You can run games like bingo and poker in the following places:
* [members- clubs](/licensees-and-businesses/guide/members-clubs-and-commercial-clubs#what-is-a-members-club) - such as working men-s clubs, branches of the Royal British Legion and clubs with political ties
* [Commercial clubs](/licensees-and-businesses/guide/members-clubs-and-commercial-clubs#what-is-a-commercial-club) - clubs created with the aim of making a profit, such as snooker clubs and gyms or sports facilities, where you'd pay to become a member but have no say in how the club is run.
* miners- welfare institutes.
You do not need a licence for this kind of gaming.
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1624 | Exempt gaming in clubs and miners' welfare institutes | What you must do | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/exempt-gaming-in-clubs-and-institutions | You must make sure:
* the game is played as an equal chance game (essentially all players must have the same chance of winning)
* the gaming is not the main purpose of the club – it can only be an additional activity.
* every player is a member of the club, or, a guest of a member
* children and under 18s do not take part
* total stakes and prizes for the game do not exceed £2,000 in a 7 day period. Otherwise, this will be classed as ‘high turnover- bingo. If this happens, you-ll need to tell us. If it happens more than once, then you-ll need a licence
* you charge a maximum of **£1** in participation fees, per person and per day.
If you-re a commercial club with a [club machine permit](/licensees-and-businesses/guide/club-gaming-and-machine-permits) the participation fee increases to £3 per person per day. |
1625 | Exempt gaming in clubs and miners' welfare institutes | What you can-t do | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/exempt-gaming-in-clubs-and-institutions | You can-t:
* deduct from or ‘levy- on money staked or won by players in the game. It doesn-t matter if the charge is voluntary or compulsory
* run ‘linked- games with players on other premises. For example, you cannot run a linked game between two branches of the Royal British Legion based in two locations
* play the bingo virtually, or online in any way.
[Previous page
Bingo using a club gaming permit](/licensees-and-businesses/guide/page/bingo-using-a-club-gaming-permit) [Next page
Exempt gaming in pubs](/licensees-and-businesses/guide/page/exempt-gaming-in-pubs)
---
Last updated: 11 June 2021
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1626 | Exempt gaming in pubs | Where it can take place | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/exempt-gaming-in-pubs | Generally, in any alcohol-licensed premises, such as pubs and bars.
You do not need a licence for this kind of gaming.
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1627 | Exempt gaming in pubs | What you must do | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/exempt-gaming-in-pubs | You must make sure:
* the game is played as an equal chance game (essentially all players must have the same chance of winning)
* children and under 18s do not take part
* total stakes and prizes for the game do not exceed £2,000 in a 7 day period. Otherwise, this will be classed as ‘high turnover- bingo. If this happens, you-ll need to tell us. If it happens more than once, then you-ll need a licence
* the stake limit is **£5** per person, per game
* all stakes are returned as prizes.
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1628 | Exempt gaming in pubs | What you can-t do | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/exempt-gaming-in-pubs | You can-t:
* Make a profit from the game - even if you intend to donate the profits to charity or good causes
* charge any participation fees – or any kind of admission fee
* run ‘linked- games with players on other premises. For example, you cannot run a linked game between two chain pubs, based in two different locations
* deduct from or ‘levy- on money staked or won by players in the game. It doesn-t matter if the charge is voluntary or compulsory
* play the bingo virtually, or online in any way.
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1629 | Exempt gaming in pubs | Example | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/exempt-gaming-in-pubs | The owner of a nightclub wants to run a bingo night. The club-s premises already has an alcohol licence and only adults are allowed in the club. The total stakes and prizes for the bingo will be less than £2,000. All stakes will be returned as prizes. The owner of the club will give free entry to the club for the bingo night and there won-t be any other charges for people to take part.
The maximum stake is charged at **£5** per person per game. All the money raised from the bingo night will be given back as prizes. Guests will still be able to buy drinks and pay for them as usual.
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1630 | Exempt gaming in pubs | If you're holding bingo as part of a wider event | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/exempt-gaming-in-pubs | You can charge admission costs for the overall entertainment. However, you can't charge participation fees, or any kind of entry fees for the bingo.
### Scenario
A pub landlady wants to hold an entertainment evening. She plans to offer entertainment a live band, quiz and a game of bingo. The landlady can charge an entry fee – for instance £10 – for the event as a whole and make a profit from the fee. However, people who will be playing bingo must be able to enter the pub without paying the entry fee. Some venues have a separate area where people can join in with bingo for free, but they can-t access the other entertainment, in order to do this.
For example, the landlady can use a function room for the bingo which people will access for free (or, to pay a maximum of £5 stake per person, per game). However, guests won-t be able to access the main pub to watch the band or take part in the quiz without paying the £10 entry fee.
[Previous page
Exempt gaming in clubs and miners' welfare institutes](/licensees-and-businesses/guide/page/exempt-gaming-in-clubs-and-institutions) [Next page
Bingo at a premises: prize gaming](/licensees-and-businesses/guide/page/bingo-at-a-premises-which-has-a-gambling-licence)
---
Last updated: 19 May 2021
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1631 | Bingo at a premises: prize gaming | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-at-a-premises-which-has-a-gambling-licence | The rules about playing bingo as prize gaming depend on the type of premises it is played in.
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1632 | Bingo at a premises: prize gaming | What you must do | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-at-a-premises-which-has-a-gambling-licence | You must make sure you only offer the type of gaming you're permitted to, as follows:
* Licensed bingo premises - any type of prize gaming
* Adult Gaming Centre (AGC) - any type of prize gaming
* Family Entertainment Centre (FEC) - any type of prize gaming
* Unlicensed Family Entertainment Centre (UFEC) - can **only** offer equal chance prize gaming (under their gaming machine permit)
* Travelling fairs - can **only** offer equal chance prize gaming, which must be ancillary (additional) to other amusements at the fair.
### Time restrictions
For the following, the game of bingo must take place over **one** day only:
* prize gaming permit holders
* Adult Gaming Centre (AGC)
* Family Entertainment Centre (FEC)
* travelling fairs.
> These restrictions do not apply to licensed bingo premises.
>
>
In Adult Gaming Centres, licensed and unlicensed family entertainment centres and travelling fairs, you must also make sure that:
* all chances to play are allocated or acquired on the premises where the gambling is taking place and on one day
* the game must be played and completed on the day the chances are allocated
* the result of the game must be made public in the premises on the day the game is played.
You must also follow [additional rules](/licensees-and-businesses/guide/page/bingo-at-a-premises-which-has-a-gambling-licence#additional-rules) - including keeping to the maximum prize limits. These depend on the type of premises, as follows.
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1633 | Bingo at a premises: prize gaming | What you can't do | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-at-a-premises-which-has-a-gambling-licence | You can't:
* base the value of the prizes on the number of people playing, or the amount raised by the game
* play the bingo virtually, or online in any way.
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1634 | Bingo at a premises: prize gaming | Additional rules | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-at-a-premises-which-has-a-gambling-licence | You must also adhere to the following rules, including prize limits and maximum participation fees, which vary depending on the type of premises.
## Licensed bingo premises
### The rules
The maximum participation fee you can charge people is **£1** per chance to win 1 or more prizes in a game.
The maximum aggregate participation fees per game are **£500** .
The maximum single prize limit is **£70** cash or in prize value (if under 18s are allowed on the premises). Or, the maximum prize limit is **£100** (if under 18s are not allowed on the premises).
The maximum aggregate prize fund (cash or in prize value) per game is **£500** .
Under 18s cannot take part in prize gaming at a bingo hall.
## Adult Gaming Centre (AGC)
For example, AGCs offer games which include slots, casino-style games and fruit machines. AGCs must have a Gambling Commission licence.
### The rules
The maximum participation fee is **£1** per chance to win 1 or more prizes in a game.
The maximum aggregate participation fees per game are **£500** .
The maximum single prize limit is **£70** cash or in prize value.
The maximum aggregate prize fund (cash or in prize value) per game is **£500** .
Under 18s **cannot** take part in this kind of gaming at an AGC.
## Family Entertainment Centre (FEC)
They're allowed to provide an unlimited number of certain types of gaming machine in a premise which is open to all ages. FECs must have a Gambling Commission licence.
### The rules
The maximum participation fee is **£1** per chance to win 1 or more prizes in a game.
The maximum aggregate participation fees per game are **£500** .
The maximum single prize limit is **£70** cash or in prize value.
The maximum aggregate prize fund (cash or in prize value) per game is **£500** .
## Unlicensed Family Entertainment Centre (UFEC)
Unlicensed FECs must have a permit from the local licensing authority.
### The rules
The maximum participation fee is **£1** per chance to win 1 or more prizes in a game.
The maximum aggregate participation fees per game are **£500** .
The maximum single prize limit is **£70** cash or in prize value.
The maximum aggregate prize fund (cash or in prize value) per game is **£500** .
## Travelling fairs
### The rules
At a travelling fair, the bingo must be an ancillary (additional) amusement at the fair. For example, a travelling fair could offer bingo as well as their main attractions of fairground rides.
The maximum participation fee is **£1** per chance to win 1 or more prizes in a game.
The maximum aggregate participation fees per game are **£500** .
The maximum single prize limit is **£70** cash or in prize value.
The maximum aggregate prize fund (cash or in prize value) per game is **£500** .
Under 18s can take part in this kind of gaming at a travelling fair.
Some [category D gaming machines](/licensees-and-businesses/guide/page/d-gaming-machines#bingo-machines) are designed or adapted to play bingo as a prize game. [Previous page
Exempt gaming in pubs](/licensees-and-businesses/guide/page/exempt-gaming-in-pubs) [Next page
Bingo for fundraising](/licensees-and-businesses/guide/page/bingo-for-fundraising)
---
Last updated: 10 June 2021
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1635 | Bingo at a premises: prize gaming | Licensed bingo premises | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-at-a-premises-which-has-a-gambling-licence | Bingo halls and clubs that hold a bingo premises licence. |
1636 | Bingo at a premises: prize gaming | Adult Gaming Centre (AGC) | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-at-a-premises-which-has-a-gambling-licence | High-street outlets with gaming machines only available to over 18s. |
1637 | Bingo at a premises: prize gaming | Family Entertainment Centre (FEC) | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-at-a-premises-which-has-a-gambling-licence | Larger arcades which cater for a range of ages. |
1638 | Bingo at a premises: prize gaming | Unlicensed Family Entertainment Centre (UFEC) | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-at-a-premises-which-has-a-gambling-licence | Family-friendly amusement arcades and small arcades in holiday parks and resorts. |
1639 | Bingo at a premises: prize gaming | Travelling fairs | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-at-a-premises-which-has-a-gambling-licence | Made up of amusements, rides and games. |
1640 | Bingo | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-licence-activities | [Non-remote bingo operating licence](/licensees-and-businesses/licences-and-fees/non-remote-bingo)
[Remote bingo operating licence](/licensees-and-businesses/licences-and-fees/remote-bingo)
[Remote bingo game host operating licence](/licensees-and-businesses/licences-and-fees/remote-bingo-game-host-operating-licence)
[Previous page
Betting licence activities](/licensees-and-businesses/guide/page/betting-licence-activities) [Next page
Casino licence activities](/licensees-and-businesses/guide/page/casino-licence-activities)
---
Last updated: 15 February 2021
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1641 | Bingo in pubs and clubs | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-in-pubs-and-clubs | Bingo can be offered on alcohol licensed premises, members' clubs, miners- welfare institutes and commercial clubs without an operating licence. However, the games must:
* be for adults only
* not be linked with games played on other premises.
[GLA: Part 18 Bingo](/guidance/guidance-to-licensing-authorities/gla-part-18-bingo)
There are limits on the amount which can be charged for participation:
| | With a club gaming permit | With a club machine permit | WITHOUT either a club gaming permit or club machine permit |
| --- | --- | --- | --- |
| Members' clubs | £3 maximum, per person, per day | £1 maximum, per person, per day | £1 maximum, per person, per day |
| Miners welfare institutes | £3 maximum, per person, per day | £1 maximum, per person, per day | £1 maximum, per person, per day |
|| Commercial clubs | Not available | £3 maximum, per person, per day | £1 maximum, per person, per day |
Pubs must ensure that:
* no participation fee is charged
* they remain within the stake limit of charging a maximum of £5 per person, per game.
Both alcohol licensed premises and clubs must ensure they do not exceed the maximum of £2,000 per week in stakes/prizes. Those wishing to exceed this limit need to [apply for a bingo operating licence](/licensees-and-businesses/licences-and-fees/sector/bingo) .
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1642 | Bingo in pubs and clubs | Bingo as prize gaming | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-in-pubs-and-clubs | When we say ‘prize gaming- we mean neither the nature nor the size of the prize is determined by:
* the number of people playing
* the amount paid for or raised by the game.
You can run bingo as a prize game without the need for a bingo operating licence in adult gaming centres, family entertainment centres, unlicensed family entertainment centres and travelling fairs.
To comply with the rules for prize gaming, the bingo games offered in these venues must:
* have a maximum stake of £1 and a prize worth no more than £70 per game
* offer no more than £500 of prizes per game
* have no more than £500 in stakes per game.
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1643 | Bingo in pubs and clubs | Files | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/bingo-in-pubs-and-clubs | Some files may not be accessible for users of assistive technology. If you require a copy of the file in an accessible format [contact us](/forms/formatrequest) with details of what you require. It would help us to know what technology you use and the required format.
**PDF Files** Some PDF files cannot be displayed in a browser, you will see a message saying 'Please wait...'. If you see this message, you will need to download the file and open it in [Adobe Acrobat Reader (opens in a new tab)](https://get.adobe.com/reader/) .
[What constitutes bingo?
application/pdf PDF 65.5 kB](//assets.ctfassets.net/j16ev64qyf6l/52bEZvvotMEdbCHYqnRJ0t/d464465c2de9ad878bf8ab281e78b619/What-constitutes-bingo-advice-note.pdf) [Previous page
Pubs and clubs - case studies](/authorities/guide/page/pubs-and-clubs-case-studies) [Next page
Club gaming and machine permits](/authorities/guide/page/club-gaming-and-machine-permits)
---
Last updated: 13 August 2021
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1644 | 2.3.2 - Bingo equipment specifications | https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/2-3-2-bingo-equipment-specifications | Applies to:
Non-remote bingo operating licences and bingo ancillary remote licences
1. Licensees must comply with the Commission-s specification for bingo equipment.
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1645 | 2.3.3 - Casino equipment specifications | https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/2-3-3-casino-equipment-specifications | Applies to:
Non-remote casino operating licences and casino ancillary remote licences
1. Licensees must comply with the Commission-s specifications for casino equipment.
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1646 | 3.6.2 - Bingo | https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/3-6-2-bingo | Applies to:
All non-remote bingo licences
**Ordinary code** These do not have the status of operator licence conditions but set out good practice. Operators may adopt alternative approaches to those set out in ordinary code provisions if they have actively taken account of the ordinary code provision and can demonstrate that an alternative approach is reasonable in the operator's particular circumstances; or that to take an alternative approach would be acting in a similarly effective manner. Ordinary codes of practice are admissible in evidence in criminal or civil proceedings and must be taken into account in any case in which the court or tribunal think them relevant, and by the Commission in the exercise of its functions; any departure from ordinary code provisions by an operator may be taken into account by the Commission on a licence review, but cannot lead to imposition of a financial penalty.
1. Licensees who employ children under (under-16-year-olds) and young persons (those aged 16 or 17) should be aware that it is an offence:
- to employ them to provide facilities for playing bingo;
- for their contracts of employment to require them, or for them to be permitted, to perform a function in connection with a gaming machine; and
- to employ a child to perform any function on premises where, and at time when, facilities are being provided for playing bingo.
- As to 1b, it should be noted that in the Commission-s view the relevant provision of the Act applies to any function performed in connection with a gaming machine. This includes servicing or cleaning such a machine.
- Accordingly, licensees should have and put into effect policies and procedures designed to ensure that:
- children and young persons are never asked to perform tasks within 1a or 1b, above
- all staff, including those who are children and young persons themselves, are instructed about the laws relating to access to gambling by children and young persons.
- Licensees should consider adopting a policy that:
- children are not employed to work on bingo licensed premises at any time when the premises are open for business
- neither children nor young persons are in any event asked to work in areas where gaming machines are situated.
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1647 | 4.2.1 - Display of rules – casino | https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/4-2-1-casino | Applies to:
All non-remote casino licences
**Social responsibility code** Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator-s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.
1. In complying with any condition on a casino premises licence requiring the display of rules about gaming, licensees must ensure that the following are included:
1. the rules of each type of casino game available to be played
2. a player-s guide to the house edge
3. a player-s guide to the rules of any equal chance games which are made available.
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1648 | When gaming machines are available to use - 20% regulations | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/when-gaming-machines-are-available-to-use-20-regulations | Gaming machine entitlements in adult gaming centres (AGCs) or bingo premises set out that only 20% of machines can be category B machines in order to ensure a balanced offering of gambling products and restrict harder gambling opportunities.
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1649 | When gaming machines are available to use - 20% regulations | Gaming machine design changes | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/when-gaming-machines-are-available-to-use-20-regulations | Machine design has changed in recent years and space-saving gaming machines have become available.
These are in the form of:
* tablets
* multi-player units
* narrow/in-fill machines.
However, some of these machines appear to be designed primarily to maximise category B machine entitlements. For example, narrow/in-fill single player gaming machines designed to fit in between full-sized gaming machines have become two-player and more recently four-player machines.
Both variants were within the same size cabinet as the original single player machine, which had a width of approximately 10 inches. Such two and four-player machines are not actually available for use in any practical way by more than one player at a time. For example, they cannot be played simultaneously by more than one person.
Such narrow/in-fill machines, subject to appropriate spacing, can only be considered to be one gaming machine for the purpose of calculating the number of machines ‘available for use-.
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1650 | When gaming machines are available to use - 20% regulations | Our guidance | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/when-gaming-machines-are-available-to-use-20-regulations | We have updated our [available for use guidance](/licensees-and-businesses/guide/when-a-machine-is-available-for-use) to make it clear that for the purpose of calculating the category B machine entitlement in gambling premises, gaming machines should only be counted if they can be played simultaneously by different players without physical hindrance.
Licensees should consider their own product offering alongside our updated guidance. Should licensees fail to address our concerns in this respect, we may take enforcement action. Individual licence conditions, for example, could be applied on a case-by-case basis if we had concerns that a licensee was not addressing this problem.
We will continue to monitor the situation and give further consideration to whether additional guidance or action is required to ensure that the intended product balance is maintained in gambling premises. You can read more about our [on-going work on category B gaming machines and player protections](/news/article/gambling-commission-calls-for-evidence-on-category-b-gaming-machines-and) .
---
Last updated: 8 June 2021
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1651 | Skill with prizes (SWPs) | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/skill-with-prizes-swps | Skill with prizes (SWPs) are not classed as gaming machines under the [Gambling Act 2005 (opens in new tab)](http://www.legislation.gov.uk/ukpga/2005/19/contents) and therefore can be sited anywhere. For example, you might see them located in a cinema foyer or shopping centre.
You **do not** need a licence for skill with prize machines. However, you do need one for a machine if it is classed as a gaming machine.
SWPs do not count towards the machine allowance in an alcohol licensed premises, or a members' club. They also do not count towards machine numbers in:
* licensed adult gaming centres
* family entertainment centres
* bingo premises for the purpose of determining category B3 gaming machine allowances.
> Skill with prize machines may be liable for Machine Games Duty and may need to be registered with HMRC. Read more about [Machine Games Duty on GOV.UK (opens in new tab)](https://www.gov.uk/machine-game-duty/register) .
>
>
## Skill with prize machine or gaming machine
## When a game is a game of chance
## Is it really a skill-based game?
## When you need a licence
## Maximum stake or prize
## Compensation mechanisms
---
Last updated: 18 May 2021
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1652 | Skill with prizes (SWPs) | Skill with prize machine or gaming machine | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/skill-with-prizes-swps | The main difference is whether any of the games offered on the machine amount to ‘gaming- as defined in [section 6 of the Gambling Act 2005 (opens in new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/6) . In the Gambling Act 2005, ‘gaming- means playing a game of chance for a prize.
If just one game from a group of skill games is a game of chance, then the machine as a whole is classed as a gaming machine.
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1653 | Skill with prizes (SWPs) | When a game is a game of chance | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/skill-with-prizes-swps | Consider all four of the following questions to help you decide.
### Does the outcome of the game depend entirely on chance?
If yes, then the game is clearly a game of chance and, if played by means of a machine, that machine is a gaming machine.
An example of a game whose outcome is determined entirely by chance is roulette.
### Does the game contain an element of chance as well as an element of skill?
A game in which the result can be influenced by chance is a game of chance for the purposes of the Gambling Act 2005. Therefore the machine on which the game is played is a gaming machine. It does not matter for these purposes whether the element of chance is greater than the element of skill. Nor does it matter whether the element of chance can be eliminated by great skill.
An example of a game which contains both an element of chance and skill is poker.
### Is the element of chance involved in the game significant enough to make a difference?
There comes a point where the element of chance is so small that it should be disregarded.
An example of a game where the element of chance should be disregarded is chess, where the element of chance introduced by determining who is to play as white and black is so small as to be likely to be considered irrelevant.
### Is the game presented as involving an element of chance?
Where the game does not involve an element of chance it may still be considered to be presented as involving an element of chance. We'll take into account the following:
* How the game appears to the player. It must not look like a game of chance. For example, roulette, bingo or game of cards.
* The name of the game and whether it contains language associated with gambling games. For example ‘stake- and ‘jackpot-.
* The livery of the machine and whether it contains symbols or graphics associated with gambling games, such as bars, bells, lucky 7s or fruits.
* The appearance of the game itself and whether it contains symbols or graphics associated with gambling, including (but not limited to) the turn of a wheel, the spin of a coin, the roll of a dice, reel bands, or the random selection of numbers.
* Whether the game involves the player in actions associated with gambling including (but not limited to) placing chips or markers on numbers.
* Any contextual indications such as advertising signage or marketing material
Any one of these factors by itself may not be enough to classify a machine as a gaming machine. For example, a picture of dice in a game by itself doesn-t necessarily make it a gaming machine.
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1654 | Skill with prizes (SWPs) | Is it really a skill-based game? | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/skill-with-prizes-swps | If you have answered the previous questions and you think the machine is an SWP then you should ask these further questions.
Games with any of the following factors are likely to contain a significant enough element of chance that the machine would be a gaming machine, even if the game claims to test a player-s skill in order for them to win a prize.
It doesn-t matter whether the factors are present at all times, or whether they are introduced by means of a compensation mechanism.
The factors are:
* a suitably skilful player does not have sufficient time to exercise their skill
* an outcome based on a player-s reactions is not genuinely achievable
* a game based on memory does not give the player the opportunity for all the necessary information to be retained and recalled
* a game where the player controls operate in an inconsistent manner, for example where a pressure sensitive button does not give the same output for the same applied pressure in each go on that machine.
Finally, if it is not possible for all of the advertised prizes to be won, then the game may be a fraud, in which case we would draw it to the attention of other agencies.
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1655 | Skill with prizes (SWPs) | When you need a licence | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/skill-with-prizes-swps | You do not need a licence for skill with prize machines.
However, if the answers to the previous questions indicate that the game in question is ‘gaming- then you need an appropriate [gaming machine licence](/licensees-and-businesses/licences-and-fees/sector/gaming-machines-and-software#gaming-machines-and-software-licences-and-fees-licence-activities) .
You'll need a licence not only to make the machine [available for use](/licensees-and-businesses/guide/when-a-machine-is-available-for-use) , but also to:
* manufacture
* supply
* install
* adapt
* maintain, or
* repair the gaming machine.
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1656 | Skill with prizes (SWPs) | Maximum stake or prize | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/skill-with-prizes-swps | As you do not need a licence or permit, there is no legal limit for stake or prizes.
However, it would be very difficult to manufacture a genuine SWP machine that is economically viable and offers prizes over £50 (the prize limit set by the industry trade body following discussion with us).
We would be likely to raise questions about machines with prizes above this range.
|
1657 | Skill with prizes (SWPs) | Compensation mechanisms | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/skill-with-prizes-swps | Some SWPs have a compensation mechanism. In broad terms ‘compensation- affects payout. It can alter the chances of winning depending on the circumstances. For example, the amount of money a machine has already taken or paid out.
Compensation can also result in the outcome of a game, which may be presented as dependant on skill, being in fact predetermined.
There are many different types of compensation mechanism. It is not possible to generalise as to their legal effect. Each case needs to be considered on its individual facts. However, the operation of compensation is clearly a relevant factor when considering the questions mentioned previously.
Where a compensation mechanism introduces a random element into the game, this may result in the game being one of chance, but it does not necessarily follow in every case.
Not every random or unpredictable element in a game necessarily leads to the conclusion that the game is a game of chance. There will be cases where the unpredictable or random element is present for the very purpose of testing the skill or knowledge of the player. For example, to challenge the player-s use of skill, whether that be manual dexterity or knowledge.
It follows that compensators that vary the degree of skill required to win a prize, without introducing an appreciable element of chance, will not necessarily, in and of themselves, make a game a game of chance, provided that compensation does not prevent a suitably skilful player from being able to win any of the published prizes. The interpretation of the Gambling Act is ultimately a matter for the courts.
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1658 | Contents | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/skill-with-prizes-swps | * [Skill with prizes (SWPs)](#)
* [Skill with prize machine or gaming machine](#differences-between-a-skill-with-prize-machine-and-a-gaming-machine)
* [When a game is a game of chance](#when-a-game-is-a-game-of-chance)
* [When you need a licence](#licences-required)
* [Maximum stake or prize](#maximum-stake-or-prize)
* [Compensation mechanisms](#compensation-mechanisms)
[Print this guide](#) |
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1659 | Test House information reporting | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/test-house-information-reporting | Approved Test Houses are required to report to us any incident or change that could have a significant impact on the delivery or structure of their business and/or ability to deliver and/or uphold the testing framework.
## Key events (Test Houses)
---
Last updated: 27 January 2022
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1660 | Test House information reporting | Key events (Test Houses) | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/test-house-information-reporting | Approved Test Houses must notify us of the occurrence of any reportable changes or incidents. Details of the events to be reported are set out in the following table.
They must do this as soon as reasonably practicable and in any event within five working days of becoming aware of the event.
The Test House must notify us of such changes or incidents by email to [testhousesubmission@gamblingcommission.gov.uk](mailto:testhousesubmission@gamblingcommission.gov.uk) .
Emails should be sent using the following format:
* Test House (Trading Name) – tell us the Test House-s trading name (e.g. Test House Alpha Ltd)
* date of event – tell us the date the event happened (e.g. 01/01/2022)
* key event (Test Houses) – tell us the name of the key event being reported (e.g. Key event (Test Houses) 1) Winding up of companies)
* summary of event details – provide a summary of the details of the event, including the reasons, if appropriate, and the date when an outcome of change is expected to take place
* contact details – tell us the name and contact details of a person we can contact to discuss the event
* supporting documents – attach any relevant supporting documentation.
On receipt of an email relating to a reportable change or incident we may request additional information.
| Reportable Change or Incident | Description | Guidance |
| --- | --- | --- |
| Key event (Test Houses) 1: Winding up of companies | A Test House must submit a key event report to us if it is presented with a petition for winding up for a company being a direct entity with controlling interest of an approved Test House, the making of a winding up order, or if the direct entity with controlling interest enters administration or receivership. | Provide the reasons behind the events and a copy of the petition, if relevant. Give details of any administrators acting on the company-s behalf. Tell us if the business is continuing to trade, what information that company has provided to its customers, and who is now running the business, or if the company is looking for a buyer, if relevant. |
| Key event (Test Houses) 2: Changes to shareholders | A Test House must submit a key event report to us if any person who (whether or not already a shareholder or member) becomes a shareholder or member holding 10% or more of the issued share capital of the company or its holding company. | Provide the name, date of birth and address of any new shareholders or members with 10% or more of the issued share capital. |
| Key event (Test Houses) 3: Changes to key positions | A Test House must submit a key event report to us if a person is appointed to, or a person ceases to occupy, a key position. | A key person in a Test House includes all directors, board members or anyone with influence who hold key positions with overall authority and responsibility (including, but not limited to) CEO, COO, Head of Finance, Head of Quality Control, Head of Compliance, Technical Director, or equivalent positions. Tell us who has been appointed, or who has left their position. Provide the name, address, and date of birth of the individuals concerned, along with the data of the change. If someone has left a position and has not been replaced, explain how this position be covered. |
| Key event (Test Houses) 4: Organisational changes | A Test House must submit a key event report to us if there is any material change(s) in the Test House structure or the operation of its business, specifically linked to gambling related testing. | A ‘material change- includes (but is not limited to) acquisitions, mergers and significant restructures or redundancies. Provide details of the change and the new arrangements. |
| Key event (Test Houses) 5: Address changes | A Test House must submit a key event report to us if it changes its Head Office or Registered address. | Provide details of the new address and date of the change. |
| Key event (Test Houses) 6: Regulatory investigations | A Test House must submit a key event report to us if it is subject to an investigation by a professional, statutory, regulatory, or government body into its activities which could reasonably be expected to raise doubts about the Test Houses continued suitability to test gambling products. | Tell us the name of the professional, statutory, regulatory, or government body conducting the investigation and details of the investigation and any adverse report, penalties, fines, or sanctions imposed. You need to inform us at the outset of the investigation, when there are initial findings, and at the conclusion of the investigation. Provide copies of reports received from the investigating body. You must tell us about investigations by UK and overseas bodies, but you do not need to inform us of investigations initiated by us. |
| Key event (Test Houses) 7: Criminal investigations | A Test House must submit a key event report to us if it (i.e. the Test House business) is subject to a criminal investigation which may reasonably cause us to question whether the Test House-s measures to keep crime out of gambling had failed. | Tell us the name of the investigating body and details of the investigation and any convictions, sentences, penalties, fines, or sanctions imposed. You need to inform us at the outset of the investigation, when there are initial findings, and at the conclusion of the investigation. Provide copies of reports received from the investigating body. You must tell us about investigations by UK and overseas bodies, but you do not need to inform us of investigations initiated by us. |
| Key event (Test Houses) 8: Loss, suspension or relinquishment of BS/ENISO 17025 accreditation | A Test House must submit a key event report to us if it loses its BS/ENISO 17025 accreditation, that accreditation is suspended, or it ceases to be accredited. | Tell us the date the accreditation was lost, suspended, or relinquished. Explain the reasons for the loss, suspension, or relinquishment of the accreditation. Identify if this change will this affect any licensees testing and, if so, have they been informed. Provide a copy of any applicable reports or correspondence (e.g. notification of loss accreditation from the accreditor). |
| Key event (Test Houses) 9: Customer data security breach | A Test House must submit a key event report to us if any security breach to its environment, has an adverse effect on the confidentiality of customer data. | Tell us the nature of the security breach, how many customers it affected and the impact or potential impact of the breach. If the breach is one which is reportable to the Information Commissioner-s Office, tell us the date you reported it to them. Further details on [notifying security breaches](/licensees-and-businesses/guide/what-you-need-to-tell-us-when-you-hold-an-operating-licence#notification-of-security-breaches) are on our website. |
Should a Test House wish to report something that is not a specified key event but which we may reasonably be expected to know, they should report this to us in the same way.
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1661 | Contents | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/test-house-information-reporting | * [Test House information reporting](#)
* [Key events (Test Houses)](#key-events-test-houses)
[Print this guide](#) |
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1662 | Updated Test House Framework - what this means for operators | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/updated-test-house-framework-what-this-means-for-operators | Following the test house framework consultation the Commission has worked with the United Kingdom Accreditation Service (UKAS) and test houses to implement changes aimed at raising standards in the industry.
Although the new framework is focused on the way in which the Commission approves test houses, we recognise that this might impact on operators and how they gain game approval.
|
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1663 | Updated Test House Framework - what this means for operators | What are the main changes the Commission brought in? | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/updated-test-house-framework-what-this-means-for-operators | * new accreditation requirements
* new approval process, meaning all existing test houses having to re-apply
* introducing immediate notice of and yearly reporting requirements
* introduction of revocation of test house approval.
|
1664 | Updated Test House Framework - what this means for operators | Are we changing the testing process? | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/updated-test-house-framework-what-this-means-for-operators | The Commission is only changing the approval and accreditation process of test houses, not the testing regime of remote and non-remote games.
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1665 | Updated Test House Framework - what this means for operators | Can we see a copy of the new approval and accreditation documents? | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/updated-test-house-framework-what-this-means-for-operators | The Commission will be publishing new application documents along with guidance for how test houses can apply. However due to copyright requirements the full accreditation document is only available to test houses upon application.
|
1666 | Updated Test House Framework - what this means for operators | What will test houses now be accredited too? | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/updated-test-house-framework-what-this-means-for-operators | The new Test House Framework requires approved test houses to be accredited to ISO/IEC 17025 which has not changed. In addition, the approved test houses will now have to be compliant with other requirements taken from ISO/IEC 17065 and ISO/IEC 27001.
|
1667 | Updated Test House Framework - what this means for operators | What happens if my test house does not seek or gain approval? | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/updated-test-house-framework-what-this-means-for-operators |
> You should all contact your test houses to gain assurances that they are continuing to be approved to test games within Britain.
>
>
If they are not continuing to be approved by the Commission, you should find a new approved test house to ensure all of your games are continuing to be tested beyond 1 October.
In the meantime, your games will be tested in the usual way but please make plans for any changes far enough in advance should your current provider be leaving the GB market.
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Last updated: 20 July 2021
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1668 | Notification of information security breaches | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/notification-of-information-security-breaches | You must tell us about any security breach to your environment that could harm the confidentiality of customer data or prevent the licensee-s customers, staff, or legitimate users from accessing accounts for longer than 12 hours.
We use the information you report to monitor ongoing compliance and evaluate risk across the industry. If themes emerge that may be valuable to share (such as specific attacks targeting a number of businesses) this may be fed back to help you deal with emerging threats.
## LCCP Licence Condition 15.2.1 (paragraph 16)
## Types of incidents
## When to report information security breaches
## Which details to provide
## How to notify us of an information security breach
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Last updated: 1 March 2022
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1669 | Notification of information security breaches | LCCP Licence Condition 15.2.1 (paragraph 16) | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/notification-of-information-security-breaches | This guidance relates to [LCCP Licence Condition 15.2.1. This licence condition applies to all operators and would include an information security breach for any operator who holds electronic records of customer information or gambling transactions.](https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/15-2-1-reporting-key-events)
|
1670 | Notification of information security breaches | Types of incidents | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/notification-of-information-security-breaches | These are some common examples of incidents which may impact on the confidentiality of customer data or the availability of accounts:
* infection by viruses or malicious software
* ransomware infection
* theft or damage of computer equipment
* attacks by unauthorised outsiders resulting in network penetration
* unauthorised access (internal or external)
* unauthorised or accidental disclosure of customer data
* staff or third party misuse of customer data
* denial of services attacks
* customer impersonated fraud (identity theft).
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1671 | Notification of information security breaches | When to report information security breaches | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/notification-of-information-security-breaches | Minor incidents should not necessarily be reported. You can decide whether the severity of an incident means it should be reported. You should record and keep your evidence as to how the decision to report or not report was made by the appropriate PML (or in the case of a small scale operator the appropriate ‘qualified person-).
The Information Commissioner-s Office (ICO) provides guidance on when security breaches involving personal data should be reported to them and this should be considered when making a decision to report (both to the ICO and to us). The key considerations are:
* potential detriment that could be caused to the individuals affected
* volume of data that has been affected
* sensitivity of the data that has been affected
* financial loss to customers.
As a general rule, if a large volume of customer data has been affected, this should be reported. If a low volume has been affected but there is the potential for serious detriment or the data is highly sensitive, this should also be reported. Consideration should also be given to notifying affected customers where warranted. Refer again to the ICO guidance in this area.
The ICO is primarily interested in breaches of personal information, our interest has a wider remit such as unavailability of customer accounts for more than 24 hours or the loss, corruption or unauthorised modification of other critical gambling records such as player account balances, prizes or gambling transaction records.
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1672 | Notification of information security breaches | Which details to provide | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/notification-of-information-security-breaches | You should provide sufficient information to describe the incident that has occurred, the severity of the incident and the volume of data affected.
Consider the following when submitting a report:
* the nature of the incident
* the location of the incident
* the services attacked or compromised
* when it first occurred
* when it was detected
* how it was detected and whether you are able to precisely identify the extent of the incident (how many customers affected, whether data was taken, what data and systems were affected)
* what mitigating action has been taken
* whether the root cause been identified
* whether any other parties such as ICO, police, external security consultants or customers been notified and the consideration given to not notifying some or all of the other parties
* what preventative action has been taken or will be taken to prevent future breaches.
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1673 | Notification of information security breaches | How to notify us of an information security breach | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/notification-of-information-security-breaches | Information security breaches are Key Events and must be reported as soon as reasonably practicable and in any event within five working days of the licensee becoming aware of the event-s occurrence.
Our guidance on [Key Events: Customer data security breach](/guidance/lccp-Information-requirements/guidance-to-operators-on-display-of-licensed-status-key-events-gambling) provides further information on submitting this key event.
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1674 | Contents | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/notification-of-information-security-breaches | * [Notification of information security breaches](#)
* [Types of incidents](#types-of-incidents)
* [When to report information security breaches](#when-to-report-severity-of-incident)
* [Which details to provide](#which-details-to-provide)
* [How to notify us of an information security breach](#how-to-notify-us-of-an-information-security-breach)
[Print this guide](#) |
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1675 | Lottery products and particular appeal to children | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lottery-products-and-particular-appeal-to-children-advice-note-july-2019 |
> This is an HTML version of this advice. You can also view or download the [original Lottery products and particular appeal to children advice (PDF)](#6qz2kxBzRNqMCfgKYwJmFQ) published in July 2020.
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1676 | Lottery products and particular appeal to children | Introduction | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lottery-products-and-particular-appeal-to-children-advice-note-july-2019 | Society lottery operators promote lotteries via a range of products, which include the sale of scratchcards (both in non-remote and remote formats). Over the years, society lottery operators have seen the advantages of reaching a wider audience by being able to utilise the growing number of media formats to market and advertise their lottery products. This includes the development of their charity websites, online shops and general use of social media. It also has included providing links or thumbnails of the scratchcard design on their own website and social media platforms to provide further information about the product.
All operators are required to comply with the [Licence conditions and codes of practice (LCCP)](/licensees-and-businesses/lccp/online) and the UK Advertising Codes which require them to market responsibly, with particular regard to the protection of children and young people (under 18s) and others who are vulnerable to being harmed or exploited by gambling advertising. We work very closely with the Advertising Standards Authority (ASA) to enforce the rules.
In October 2017, we published [a joint letter with the ASA and the Remote Gambling Association](#1XEiD65ojh7dtMzNLKStnK) to all remote operators which reminded them of the rules in relation to protecting children and young people, and required them to remove any advertising on websites likely to appeal particularly to those under 18 and which are generally available to view (‘freely accessible-). Furthermore, in August 2018, the ASA banned an advert that promoted a scratchcard on an operator-s website which contained imagery found to be of particular appeal to under 18s.
Although there are already rules in place for various media formats, this advice note clarifies the Gambling Commission-s rules and our expectations when we apply [LCCP social responsibility code 5.1.7 (Compliance with advertising codes – lotteries)](/licensees-and-businesses/lccp/condition/5-1-7-compliance-with-advertising-codes-lotteries) . Operators should consider this advice when developing products such as society lottery scratchcards.
## The rules
## The CAP Code states:
## The CAP code guidance on particular appeal to under 18s
## Files
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1677 | Lottery products and particular appeal to children | The rules | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lottery-products-and-particular-appeal-to-children-advice-note-july-2019 | LCCP 5.1.7 requires all lottery licensees to ensure that the marketing of products and services is undertaken in a socially responsible manner and that they must comply with the UK Advertising Codes issued by the Committees of Advertising Practice (CAP and for broadcast advertising, BCAP). LCCP 5.1.7(2) states that for media not explicitly covered you should apply the principles included in these codes of practice as if they were explicitly covered.
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1678 | Lottery products and particular appeal to children | The CAP Code states: | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lottery-products-and-particular-appeal-to-children-advice-note-july-2019 | **17.12** Marketing communications for lotteries must not exploit the susceptibilities, aspirations, credulity, inexperience or lack of knowledge of children, young persons or other vulnerable persons.
**17.13** Marketing communications for lotteries must not be likely to be of particular appeal to children or young persons, especially by reflecting or being associated with youth culture.
**17.14** Marketing communications for lotteries should not be directed at those aged under 16 years through the selection of media or context in which they appear.
The minimum age limit for purchasing National Lottery products and participating in society lotteries is 16. The rules in section 17 (Lotteries) of the CAP Code are designed to nevertheless ensure that marketing communications for lotteries are socially responsible with particular regard to the need to protect those aged under 18.
The UK Advertising Codes explicitly cover a [a range of media (opens in a new tab)](https://www.asa.org.uk/advice-online/remit-general.html) , but do not extend to in-store communications (other than point of sale material that includes a promotion) or to products, for example a physical lottery scratchcard.
The definition of advertising in the [Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/contents) captures anything which encourages a person to take advantage of gambling facilities or the providing of information about gambling facilities with the intention that that will increase the use of those facilities. We consider that this broad definition applies to the content and design of scratchcards as well as other lottery products.
Accordingly, the provisions under LCCP 5.1.7(2) require operators to have regard to the principles included in the UK Advertising Codes as if they were explicitly covered, when considering the design of scratchcards. These principles include that marketing communications that are freely viewable and accessible should not be of particular appeal to under 18s. For example, we consider that an operator would breach LCCP if its lottery scratchcards were displayed on a supermarket counter and featured content of particular appeal to under 18s.
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1679 | Lottery products and particular appeal to children | The CAP code guidance on particular appeal to under 18s | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lottery-products-and-particular-appeal-to-children-advice-note-july-2019 | We expect society lottery operators to take care with the imagery and wording used in the content of scratchcards as well as in any associated marketing material. The ASA/CAP has published advice titled [Gambling and lotteries guidance - protecting under-18s (opens in a new tab)](https://www.asa.org.uk/resource/protecting-children-and-young-people-gambling-guidance-2022.html) and rulings that identify gambling ads that appeal particularly to under 18s. Content is considered to have ‘particular appeal to children or young persons- if it is likely to appeal more to under 18s than to over 18s. The use of colourful and exaggerated cartoon-style graphics are likely to be considered to have particular appeal to under-18s, as are cartoon animals. Characters from, or similar to those from, children-s TV, films, nursery rhymes and fairy tales are similarly at risk of being particularly appealing to children.
The names of games such as “Piggy Payout”, “Fluffy Favourites”, “Pirate Princess” and “Jack and the Beanstalk”, depending on the context, could also be seen to have particular appeal because they contain elements familiar to children and young persons which may contribute to their appeal to that group.
The ASA has published a number of rulings that identify gambling adverts that appeal particularly to under 18s and which were subsequently banned. Operators should also have regard to these when designing lottery products.
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1680 | Lottery products and particular appeal to children | Files | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lottery-products-and-particular-appeal-to-children-advice-note-july-2019 | 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/) .
[Lottery products and particular appeal to children advice
application/pdf PDF 212.7 kB](//assets.ctfassets.net/j16ev64qyf6l/6qz2kxBzRNqMCfgKYwJmFQ/fc45b88916042fc8ccfb4f376fa187e9/Advice-on-use-of-imagery-on-lottery-scratchcards.pdf) [Joint letter: ASA and Remote Gambling Association
application/pdf PDF 241.6 kB](//assets.ctfassets.net/j16ev64qyf6l/1XEiD65ojh7dtMzNLKStnK/71464504f25f5054ee245af1362a6056/Ltr-from-ASA-CAP-CG-RGA-final.pdf)
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Last updated: 7 June 2021
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1681 | Contents | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lottery-products-and-particular-appeal-to-children-advice-note-july-2019 | * [Lottery products and particular appeal to children](#)
* [The rules](#the-rules)
* [The CAP code guidance on particular appeal to under 18s](#the-cap-code-guidance-on-particular-appeal-to-under-18s)
[Print this guide](#) |
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1682 | External Lottery Managers | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/external-lottery-managers-advice-note-september-2014-updated-july-2020 |
> This is an HTML version of this advice. You can also view or download the [original External Lottery Managers advice (PDF)](#1fMVw9kmwZB2NyaKW4VPzD) published in September 2014, updated July 2020.
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1683 | External Lottery Managers | Introduction | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/external-lottery-managers-advice-note-september-2014-updated-july-2020 | The purpose of this note is to provide advice to External Lottery Managers (ELMs), society and local authority lotteries and others about the requirements of the [Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/contents) (the Act) relating to ELMs.
The interpretation of the Act is ultimately a matter for the courts but it is hoped that this advice note will be helpful to ELMs, societies and local authorities in understanding the requirements and the Gambling Commission-s approach in respect of compliance with those requirements.
This note also contains some advice supplementary to the requirements of the Act, relevant regulations and the [Licence conditions and codes of practice (LCCP)](/licensees-and-businesses/lccp/online) . For further information see [Promoting society and local authority lotteries](/licensees-and-businesses/guide/promoting-society-and-local-authority-lotteries) and the conditions and codes attached to your licence.
We may update this advice from time to time to reflect developments in the sector.
## What is an ELM?
## Licensing requirements
## The purpose of society and local authority lotteries
## The relationship between ELMs and society and local authority lotteries
## The licence conditions and codes of practice relating to ELMs
## Proceeds and profits - ELMs
## Non-compliance
## Footnotes
## Files
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1684 | External Lottery Managers | What is an ELM? | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/external-lottery-managers-advice-note-september-2014-updated-july-2020 | Lotteries within Great Britain are the preserve of good causes and as such the Act did not intend ELMs to be primarily a vehicle to create profit for commercial organisations; rather, the intention was to enable societies and local authorities to raise funds for their own non-commercial purposes.
An ELM is defined in [section 257 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/257) as someone that makes arrangements for a lottery on behalf of a society or local authority but is not a member, officer or employee of the society or local authority. A society or local authority and an ELM must be separate entities and be able to demonstrate that they are independent of each other.
To this end the Commission would not consider ELMs to be independent if, for example, a director or employee of an ELM was also a trustee, director, employee or member of the society whose lottery they are promoting. The Commission might not also consider the ELM and society to be independent if, for example, a director or employee of an ELM was closely connected to someone (e.g. a family member or personal friend or associate) who was a trustee, director orindividual holding a strategic decision making role within the society whose lottery the ELM is promoting.
The Act allows societies and local authorities to employ ELMs to manage all or part of their lotteries so that societies and local authorities may benefit from the experience or economies of scale that come with employing an ELM.
Under [section 252 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/252) , a person promotes a lottery if they make or participate in making the arrangements for a lottery. It states further that a person promotes a lottery in particular if they:
* make arrangements for printing of tickets
* make arrangements for the printing, publication and distribution of promotional material [1](#1)
* make arrangements to advertise a lottery
* invite an individual to participate in a lottery
* sell or supply tickets
* offer to sell or supply tickets
* use premises for the purpose of allocating prizes or for any other purpose connected with the administration of a lottery.
Under [section 258 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/258) a person commits an offence if they carry out any of these activities on behalf of a society or local authority unless they:
* are an officer, employee or a member of a licensed or registered society or local authority
* are a licensed ELM directed by a society or local authority to run all or part of its lottery.
A person also commits an offence if they facilitate a society or local authority lottery unless they act in accordance with an operating licence. Under [section 259 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/259) a person facilitates a lottery if they:
* print lottery tickets for a specified lottery
* print promotional material for a specified lottery
* advertise a specified lottery.
Uncertainty can arise as to whether services provided to societies or local authorities amount to the promotion or facilitation of a lottery or to the provision of services which do not amount to promotion or facilitation. The Commission-s advice note [Promoting society and local authority lotteries](/licensees-and-businesses/guide/promoting-society-and-local-authority-lotteries) gives further guidance on the distinctions between the two, but anyone who is uncertain whether the services provided require the provider to hold an ELM licence should contact the Commission for further guidance.
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1685 | External Lottery Managers | Licensing requirements | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/external-lottery-managers-advice-note-september-2014-updated-july-2020 | An ELM must hold a lottery manager operating licence issued by the Commission before they can promote a society or local authority lottery. The ELM (and the relevant society or local authority) will also need to hold a remote gambling licence if they intend to sell tickets by means of remote communication (eg internet, telephone etc).
It is the responsibility of both the society (or local authority) and the ELM to ensure that the other party holds the relevant operating licence(s) before they enter into any arrangements regarding the promotion of lotteries.
Unless an ELM qualifies as a small scale operator (SSO) [2](#2) , individuals holding key management positions at an ELM may be required to hold a Personal Management Licence (PML) - this may be the managing director, chief executive, finance director, compliance manager, marketing manager and IT manager.
The Commission expects all licensed operators to put in place people and systems to enable them to be compliant with the Act and licence conditions. In general the function of regulatory compliance should be assumed by one individual who will have overall responsibility for ensuring compliance. For large scale operators the person holding responsibility for compliance should have no other function in order to ensure they can carry out their role without the potential for any conflict of interest. The Commission understands and accepts that this may not always be possible for small scale operators who have few employees able to hold key management positions.
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1686 | External Lottery Managers | The purpose of society and local authority lotteries | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/external-lottery-managers-advice-note-september-2014-updated-july-2020 | The intention of the Act is to allow non-commercial societies to use a lottery as a means of raising funds from the public for the cause promoted by the society or for the local authority to raise funds for any purpose for which they have the power to incur expenditure. The provisions are relatively limited in scope. It is not the intention of the Act to allow society or local authority lotteries to be promoted for private or commercial gain although it is accepted that an ELM is a commercial business that usually exists to produce a commercial profit.
The proportion of the proceeds of a lottery that are distributed for the purposes of the society or local authority are called the ‘profits- (see section 7 - Proceeds and profits, and the Commission-s advice note [Lottery proceeds, April 2013](/licensees-and-businesses/guide/lottery-proceeds-advice-note-april-2013-updated-july-2020) for further information. Each society or local authority lottery must return a minimum of 20% of the proceeds to the purposes of the society or local authority.
Under [section 260 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/260) it is an offence to use any part of the ‘profits- of a lottery for a purpose other than that stated by the society or in the promotional material. [Section 261 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/261) applies the same offence to small society lotteries.
Under [section 254 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/254 ) , alongside the profits, the proceeds of a lottery will be split between the payment of prizes and paying reasonable expenses. The expenses can include a payment to an ELM in respect of the services provided in respect of promotion of the lottery. However, that payment must be proportionate and reflect the lawful status of the lottery as a means of raising funds to support a non-commercial society or local authority. The promoting society or local authority must ensure any fees paid to an ELM constitute an expense reasonably incurred organising the lottery.
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1687 | External Lottery Managers | The relationship between ELMs and society and local authority lotteries | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/external-lottery-managers-advice-note-september-2014-updated-july-2020 | As highlighted in [section 257 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/257) the Act allows a society or local authority lottery to employ an ELM to manage all or part of its lottery on its behalf. The intention of these provisions is relatively limited in scope: they are designed to do nothing more than to allow a society to ‘outsource- the running of a lottery to a third party.
The fact that a society or local authority may employ a licensed ELM to manage all or part of its lottery does not absolve the society or local authority from its responsibility for ensuring that the lottery is conducted in such a way as to ensure that it is lawful and fully compliant with the Act, related regulations and all licence conditions and codes of practice.
Under [section 252(4) of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/252#:~:text=252Promoting%20a%20lottery&text=(4)Where%20arrangements%20for%20a,or%20authority%20promote%20the%20lottery.) , where an ELM is employed to make the arrangements for all or part of the lottery including paying prizes and the expenses, the society or the local authority is equally responsible, with the ELM, for the lawful distribution of the proceeds.
This includes the mandatory requirement to return a minimum of 20% of the proceeds of any lottery promoted to the purposes for which the promoting society is conducted or the local authority has the power to incur expenditure (for further information, refer to the Commission-s advice note [Lottery proceeds, April 2013](/licensees-and-businesses/guide/lottery-proceeds-advice-note-april-2013-updated-july-2020) .
If an ELM (or a service provider) is involved in the distribution of the proceeds, the Commission expects that they agree with the society or local authority in advance about how they will be distributed. This should include discussing and agreeing the prize structure, and ensuring that any expenses are reasonably incurred. If involved in the distribution of the profits of a lottery (ie the proportion returned for the purposes of the society or local authority), this must be done in accordance with terms agreed with the society or local authority and in accordance with the society-s or local authority-s purpose. The society or local authority must always retain overall control of the distribution of profits.
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1688 | External Lottery Managers | The licence conditions and codes of practice relating to ELMs | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/external-lottery-managers-advice-note-september-2014-updated-july-2020 | All ELMs licensed by the Commission to run lotteries on behalf of societies and local authorities are required to comply with specific conditions and codes of practice relevant to them. The specific licence conditions are set out at the time a licence is issued and are printed on the licence.
Some of the licence conditions and codes of practice applicable to ELMs are referred in the following paragraphs. Specific details are contained in the [Licence conditions and codes of practice](/licensees-and-businesses/lccp/online) .
### Protection of customer funds and lottery proceeds
There are a number of requirements on ELMs in relation to protecting customer funds as well as the proceeds of lotteries by putting ‘ring-fencing- in place. In relation to customer funds the LCCP requires that:
* ‘Licensees who hold customer funds must ensure that these are held in a separate client bank account or accounts- [Condition 4.1.1 of the Licence Conditions and Codes of Practice](/licensees-and-businesses/lccp/condition/4-1-1-segregation-of-funds)
* ‘Licensees who hold customer funds must set out clearly in the terms and conditions under which they provide facilities for gambling information about whether customer funds are protected in the event of insolvency, the level of such protection and the by which this is achieved.
Such information must be according to such rating system and in such form the Commission may from time to time specify. It must be provided in writing to each customer, in a manner which requires the customer to acknowledge receipt of the information and does not permit the customer to utilise the funds for gambling until they have done so, both on the first occasion on which the customer deposits funds and on the occasion of any subsequent deposit which is the first since a change in the licensee-s terms in relation to protection of such funds. [Condition 4.2.1 of the Licence Conditions and Codes of Practice](/licensees-and-businesses/lccp/condition/4-2-1-disclosure-to-customers) .
The LCCP also sets out a definition of customer funds.
For lottery proceeds, the following applies: ‘Licensees must have arrangements in place to ensure separation between lottery proceeds they hold on behalf of non-commercial societies or local authorities and their own trading income and that such lottery proceeds are legally protected by means of separate bank accounts having trustee status or equivalent legal protection for each society or local authority in the event of the licensee-s insolvency, in which event the proceeds will be paid to the society or local authority.- [Condition 11.2.1 of the Licence Conditions and Codes of Practice](/licensees-and-businesses/lccp/condition/11-2-1-lotteries-managers) .
The second part of the previous paragraph is specific to ELMs who hold the proceeds of a lottery on behalf of a society or local authority prior to or following a lottery draw. It is vital for an ELM to understand that the proceeds of any lottery are proceeds belonging to the society or local authority and that they are holding those funds in trust on behalf of those entities. The Commission places particular importance on the ELM having sufficient arrangements in place to protect those funds (the proceeds) for the society or local authority to ensure that they are not used for any purpose other than that which the Act permits and that they are protected in the event of the ELM-s insolvency or any claim on the ELM-s financial reserves.
[Section 254 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/254) defines ‘proceeds- as ‘the aggregate of amounts paid in respect of the purchase of lottery tickets-. The Commission-s view is that if monies are committed/appropriated to the purchase of a ticket in a specific lottery draw, then the monies are likely to be ‘proceeds-. If monies are held in an account before being ‘allocated to a gamble- (a lottery) then the monies are likely to be customer funds. For example, monies paid in advance by those wishing to partake in lotteries are customer funds until they are committed/appropriated to the purchase of a lottery ticket in a particular draw and thereafter lottery proceeds within the definition in section 254(1). Lottery proceeds also have the potential to revert to being customer funds in the event the draw does not take place, or in the event the subscription is cancelled and where the stake is refunded to the participant.
### Social responsibility
Lotteries are a form of gambling and as such ELMs are required to ensure that children and other vulnerable people are not harmed or exploited by the lotteries they manage. Societies and local authorities have the same requirements placed on them.
The minimum age for participation in a society or local authority lottery is 16 years. A person commits an offence if they invite or allow a child (someone under the age of 16) to enter such a lottery. ELMs, licensed societies and local authorities must have written policies and procedures in place to help prevent and deal with cases of under-age play. They must be able to evidence how these procedures and policies are applied to mitigate any risk to the licensing objectives [3](#3) .
Licence holders must take all reasonable steps to ensure that information about how to gamble responsibly and how to access information and help in respect of problem gambling is readily available, and all marketing material for the lottery must display the begambleaware logo (including a link to the begambleaware website in the case of electronic material).
All licence holders are required to make a contribution to research, education and treatment in relation to problem gambling. ELMs, licensed societies and local authorities should ensure this provision is met either directly or through membership of a trade body that makes a donation to a recognised organisation on behalf of its members. A licensed society must meet this provision and it can be rightly included as an expense of the lottery or can be taken from other non-lottery financial reserves.
ELM-s are also required to make a contribution but it cannot form part of the expenses of a lottery although in the Commission-s view it is permissible for the funds to come from the part of the expenses paid to the ELM by the society for providing their services. While the Commission does not specify the recipient or the amount of the contribution, many licensees choose to make a donation to the Responsible Gambling Trust, based on a percentage of their gross gambling yield.
> Further information about social responsibility requirements is available in the Commission-s [Licence conditions and codes of practice (LCCP)](/licensees-and-businesses/lccp/online) . You can also download sector-specific extracts from the LCCP.
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### Regulatory returns
[Licence condition 15.3](/licensees-and-businesses/lccp/condition/15-3-1-general-and-regulatory-returns) requires that all ELMs submit an annual regulatory return to the Commission. The return must be submitted within 42 days of the end of the annual business period. This must contain all of the necessary information requested by the Commission and is best submitted securely online.
Where the ELM makes the arrangements for any part of the lottery they must record the proportion of the proceeds of the lottery generated by the ELM-s activity and include this in their regulatory return, together with details on the annual managed proceeds split by product type. In some circumstances, the ELM may need to request this information from the society.
For example, if the ELM is only ‘making arrangements- in respect of one aspect of the lottery campaign such as direct mail, the ELM is only required to report the proceeds generated by that aspect of the lottery.
### Lottery Submissions
The licence conditions attached to all lottery operating licences include a requirement that in respect of each lottery promoted a submission must be sent to the Commission within three months of the date of the lottery, showing the total proceeds and how they have been distributed. It is the responsibility of the society and the ELM to ensure that any lottery submission made in respect of the distribution of the proceeds of a lottery is a true and accurate reflection of how those proceeds have been distributed.
Where the ELM is instructed by a society to make lottery submissions on its behalf the ELM must ensure that the society approves every submission before it is made.
### Information to lottery players: proceeds and prizes
Social responsibility codes attached to all lottery operating licences include a requirement to take account of the Commission-s guidance on providing information to lottery players about how proceeds are used and the likelihood of winning a prize and how those prizes are allocated. This information must be available prior to participating in a lottery.
Further information about these requirements can be found in the Commission's guidance [Information to lottery players: proceeds and prizes](/licensees-and-businesses/guide/information-to-lottery-players-proceeds-and-prizes) .
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1689 | External Lottery Managers | Proceeds and profits - ELMs | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/external-lottery-managers-advice-note-september-2014-updated-july-2020 | [Section 254 of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/254) clarifies what is meant by ‘proceeds- and ‘profits- of a lottery. It defines proceeds as ‘the aggregate of amounts paid in respect of the purchase of lottery tickets-. This means that proceeds are the total amount paid for tickets before any deductions.
Profits are defined as the amount of proceeds less any deductions for prizes, rollovers and reasonable expenses incurred in connection with running the lottery.
[Section 99(2) of the Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/99 ) of the Act specifies the way in which the proceeds of a lottery must be distributed, as follows: ‘The first requirement is that at least 20% of the proceeds of any lottery promoted in reliance on the licence are applied:
**a)** in the case of a licence issued to a non-commercial society, to a purpose for which the promoting society is conducted
**b)** in the case of a licence issued to a local authority, for a purpose for which the authority has power to incur expenditure-.
In addition to profits the proceeds can only be used to:
* provide prizes
* pay expenses ‘reasonably incurred- organising the lottery.
Further information regarding lottery proceeds can be found in the Commission-s advice note [Lottery proceeds, April 2013](/licensees-and-businesses/guide/lottery-proceeds-advice-note-april-2013-updated-july-2020) .
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1690 | External Lottery Managers | Non-compliance | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/external-lottery-managers-advice-note-september-2014-updated-july-2020 | The Commission requires all lottery operators to comply with the licensing objectives of the Act and treats any breach of the licence conditions very seriously. In circumstances where either a breach of the Act or the licence conditions occurs the Commission will consider what criminal or regulatory action it needs to take. That could include a review of the ELM-s operating licence, which could result in a formal warning, additional licence conditions, a financial penalty or suspension or revocation of the operating licence. Further details can be found in the Commission-s [Licensing, compliance and enforcement policy statement](/policy/licensing-compliance-and-enforcement-under-the-gambling-act-2005) .
In circumstances whereby the ELM has been deemed to have committed a breach of the Act or the licence conditions the Commission may also consider taking action against the society or societies they promote lotteries for. This would be the case where the society was deemed to have failed to ensure that the lottery was conducted in such a way as to ensure that it was lawful and fully compliant with the Act, related regulations and all licence conditions and codes of practice.
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1691 | External Lottery Managers | Footnotes | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/external-lottery-managers-advice-note-september-2014-updated-july-2020 | 1 Promotional material is defined as a document that advertises, invites participation, contains information about how to participate, or lists winners, in a particular lottery.
2 A gambling operator qualifies as an SSO unless there are four or more persons who have responsibility for any of the key functions.
3 Preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime; ensuring gambling is conducted in a fair and open way; protecting children and other vulnerable persons from being harmed or exploited by gambling [(Section 1 of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/1) .
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1692 | External Lottery Managers | Files | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/external-lottery-managers-advice-note-september-2014-updated-july-2020 | 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/) .
[External lottery managers advice
application/pdf PDF 367.5 kB](//assets.ctfassets.net/j16ev64qyf6l/1fMVw9kmwZB2NyaKW4VPzD/73135deafd36822ed825e144139bc842/External-lottery-managers-advice.pdf)
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Last updated: 7 June 2021
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1693 | Contents | https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/external-lottery-managers-advice-note-september-2014-updated-july-2020 | * [External Lottery Managers](#)
* [What is an ELM?](#what-is-an-elm)
* [Licensing requirements](#licensing-requirements)
* [The purpose of society and local authority lotteries](#the-purpose-of-society-and-local-authority-lotteries)
* [The relationship between ELMs and society and local authority lotteries](#the-relationship-between-elms-and-society-and-local-authority-lotteries)
* [The licence conditions and codes of practice relating to ELMs](#the-licence-conditions-and-codes-of-practice-relating-to-elms)
* [Proceeds and profits - ELMs](#proceeds-and-profits-elms)
* [Non-compliance](#non-compliance)
[Print this guide](#) |
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1694 | 4.3.1 - Publication of percentage of lottery proceeds returned to the purposes of the society or local authority | https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/4-3-1-publication-of-percentage-of-lottery-proceeds-returned-to-the-purposes | Applies to:
All lottery operating licences issued to non-commercial societies and local authorities
**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. Each year, licensees must publish details on the percentage of the total proceeds of lotteries promoted in the previous calendar year in reliance on this licence applied to purposes for which the society is conducted, or purposes for which the local authority has power to incur expenditure. This should be through either their annual report, lottery page of their society website or any other means appropriate to the size and scale of the organisation.
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1695 | Promoting a lottery | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/promoting-a-lottery |
> Lotteries in Great Britain can only be promoted by charities, other good causes and local authorities. They cannot be promoted for private or commercial gain.
>
>
Each society or local authority lottery must return a minimum of 20% of the proceeds to the purposes of the society or local authority (the good cause). They must also provide consumers with information about the proportion of lottery proceeds (ticket sales) returned to good causes or for local authority expenditure, in a calendar year.
Read our guidance for [Promoting society and local authority lotteries](/licensees-and-businesses/guide/promoting-society-and-local-authority-lotteries) .
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1696 | Promoting a lottery | Promoting multiple society lotteries | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/promoting-a-lottery | Our advice on [promoting multiple society lotteries](/licensees-and-businesses/guide/promoting-multiple-society-lotteries) provides advice about some of the factors we are likely to take into account when making decisions about whether the requirements of the Gambling Act 2005 are satisfied in a particular lottery scheme. It contains advice supplementary to the requirements of the Act, relevant regulations and the Licence conditions and codes of practice. It also provides more information on what constitutes a branded lottery scheme, and what operators are required to do when promoting lotteries through such schemes.
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1697 | Promoting a lottery | Promoting individual society lotteries | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/promoting-a-lottery | Society lotteries and external lottery managers (ELMs) that wish to promote individual society lotteries under one umbrella brand must ensure those lotteries are not combined to form one single lottery, which could be a breach of the requirements of the Gambling Act 2005 and relevant regulations.
They must also ensure that consumers are provided with sufficient information for them to make an informed choice as to whether they wish to support that good cause or not. It must be clear to consumers that although there is a common brand, they are participating in individual society lotteries; and which lottery they are participating in. There should therefore be information about the promoting society available in any marketing or advertising material.
[Offering lottery, gaming and betting products under common branding](/licensees-and-businesses/guide/offering-lottery-gaming-and-betting-products-under-common-branding-june-2012) provides advice to lottery promoters and others about the principles we use in licensing and regulating those who wish to combine the promotion of lotteries with provision of facilities for other types of gambling.
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1698 | Promoting a lottery | Promoting your lottery in countries outside of Great Britain | https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/promoting-a-lottery | The Gambling Act 2005 neither permits nor prohibits a lottery lawfully promoted in Great Britain from being promoted in another country. Great Britain is England, Scotland and Wales.
> Northern Ireland, the Channel Islands and the Isle of Man have their own gambling laws.
>
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If you promote a lottery in Great Britain and would like to promote it in another country, including sending tickets, application forms or any other information about the lottery (by a website or by email, post, telephone or other means) you should contact the relevant authorities in that country first to see what is allowed and if there are any special requirements.
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Last updated: 7 June 2021
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1699 | 2.2.1 - Gambling software | https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/2-2-1-gambling-software | Applies to:
All remote casino, bingo and betting licences other than ancillary licences and remote betting intermediary (trading room only) licences
1 All gambling software [1](#221-1) 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.
## References
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1700 | 2.2.1 - Gambling software | References | https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/2-2-1-gambling-software | 1 As defined in section 41(2)&(3) of the Act
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