UK Law and Practice Contributed by: Bahar Alaeddini, David Whyte and Jessica Wilson, Harris Hagan
stake limits were introduced at GBP5 per spin for those aged 25 years and above, and a GBP2 limit per spin for those aged under 25 was introduced on the 21 May 2025. • Calculation of financial penalties – following the Gambling Commission’s response to its 2023 consultation, on 10 October 2025, its Statement of Principles for Determining Financial Penalties was updated to bring greater clarity and transpar- ency to how the Gambling Commission calculates financial penalties. Upcoming changes emanating from the White Paper At the time of writing (November 2025), the following changes are scheduled. • Bonus and wagering requirements – from 19 Janu- ary 2026, changes will be made to SRCP 5.1.1, which will ban licensees from offering incentives that include more than one type of gambling prod- uct. Licensees will also be required to cap wager- ing requirements of bonus funds to a maximum of ten times. • Deposit limits – following its response to a supple- mentary consultation on deposit limits, the Gam- bling Commission has confirmed further changes to the RTS to clarify the definition of “deposit limits” and other financial limits that can be set by customers. The changes are due to take effect on 30 June 2026. Awaited changes Several proposals were made in the White Paper that are still awaiting progress. These include the following. • Gambling ombudsman – the creation of a non- statutory gambling ombudsman to handle social responsibility complaints from consumers. The UK government’s clear expectation was that this body would be industry-led and accepting complaints by summer 2024. This was not achieved and, at the time of writing, the position of the new government is unclear. • Gambling Commission fees – at the time of writing, the UK government’s consultation on the Gambling Commission’s fees is awaited. This is expected during 2026, along with an increase in fees.
• Financial key event reporting – at the time of writing, the Gambling Commission’s outstand- ing response to its December 2023 consultation is awaited. The consultation related to proposed changes to financial key event reporting (in par- ticular, to raise the current 3% reporting threshold to 5% in line with requirements of other regulators and jurisdictions). The Gambling Commission’s response is expected to be published before the end of 2025. • Financial risk assessments – the Gambling Com- mission conducted a three-stage pilot to establish how financial risk assessments will work in practice and assess appropriate thresholds. At the time of writing, the outcome of the Gambling Commis- sion’s pilot is awaited. AML In the past year, changes have been made to AML legislation impacting the AML/CFT obligations of licensees. The Proceeds of Crime Act 2002 (POCA) was updated in July 2025 by separate legislation to increase the threshold amount for submitting a defence against money laundering to GBP3,000. In April 2025 and October 2025, the Gambling Com- mission published emerging risk updates, identifying emerging money laundering and terrorist financing risks in the gambling industry. The risks identified include: • risks associated with pre-paid payment methods; • the use of AI to bypass customer due diligence; • money being exchanged for personal details and gambling accounts; • licensed software providers’ games being available on websites not licensed by the Gambling Com- mission; • crypto-assets; • changes to customer demographics in the non- remote sector; • terminals being used to facilitate customer depos- its into non-remote casinos; • increased availability of crash games; and • use of application registration cards as a form of identity documentation.
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