UK Law and Practice Contributed by: Bahar Alaeddini, David Whyte and Jessica Wilson, Harris Hagan
1. Introduction 1.1 Current Outlook and Recent Changes The White Paper and Recent Changes In April 2023, the government published its long- awaited White Paper, “High Stakes: Gambling Reform for the Digital Age” (the “White Paper”). The highly anticipated White Paper formed part of the review of the Gambling Act 2005 that was launched by the UK government in December 2020 and designed to “pro- tect vulnerable users in [a] smartphone era” by striking a better balance between consumer freedoms and the protection of the vulnerable. The White Paper detailed more than 60 proposals. Since publication, significant progress has been made with a number of White Paper proposals coming into effect through a combination of primary and second- ary legislation, changes to the Licence Conditions and Codes of Practice (LCCP), and voluntary com- mitments. Key changes that have been implemented further to the White Paper include the following. • Statutory levy – a new mandatory statutory levy has been introduced to fund research, educa- tion, and treatment of gambling harms, replacing the current voluntary system. The Gambling Levy Regulations 2005 were signed into law in Febru- ary 2025 and came into effect on 6 April 2025. The levy is calculated at a set rate ranging from 0.1% to 1.1% (depending on licensed product) based on the amount reported in a licensee’s regulatory returns within the previous 12-month period begin- ning on April 1st annually. The first invoices were issued on 1 September 2025 with payment due before October 1st each year. • Financial vulnerability checks – following the Gambling Commission’s consultation response of 1 May 2024, financial vulnerability checks must be conducted on customers pursuant to a new social responsibility code provision (SRCP) 3.4.4, which came into effect on 30 August 2024. From 28 February 2025, remote licensees are required to undertake checks on customers with a net deposit of GPB150 a month. Financial vulnerability checks require licensees to check public record informa-
tion for significant indicators of potential financial vulnerability. The checks can be frictionless, but must include whether the customer is subject to a bankruptcy order, a county court judgment, or an individual voluntary agreement (or similar); propor- tionate action must be taken by the licensee based on the result. • Online game design rules – amendments to the Remote Gambling and Software Technical Stand- ards (“the RTS”) were implemented on 17 January 2025. The changes extended requirements that already applied to slots to other online products. Notably, this includes a ban on speed features such as “turbos” or “slam stops”, a ban on game cycles of less than five seconds on casino prod- ucts, the prohibition of autoplay functions, a ban on celebrations of returns less than or equal to the stake, and a ban on the facilitation of playing multiple simultaneous products. Further updates were made to the RTS on 31 October 2025, requir- ing operators to prompt their customers to set a financial limit on their accounts. • Direct marketing – a new social responsibility code provision came into force on 1 May 2025, requiring online gambling businesses to provide custom- ers with options to opt in to the product type they are interested in, as well as the channels through which they wish to receive marketing. • Land-based reforms – following the UK govern- ment’s consultation response on 16 May 2024, a series of statutory instruments came into effect on 22 July 2025 permitting casino premises licences originally issued under the Gaming Act 1968 to access new entitlements. Entitlements include increased gaming machine entitlements of up to 80 machines on a sliding scale (if certain condi- tions are met) and offering sports betting. The UK government opened a consultation on 15 October 2025 in respect of the categorisations of Category D gaming machines and proposing an age limit on “cash out” slot-style Category D gaming machines. At the time of writing, the consultation is open and is due to close on 9 January 2026. • Online stake limits – the Gambling Act 2005 (Oper- ating Licence Conditions) (Amendment) Regula- tions 2025 were signed into law on 25 February 2025, introducing online slots stake limits for remote operators. On 9 April 2025, the online slots
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