UK Law and Practice Contributed by: Bahar Alaeddini, David Whyte and Jessica Wilson, Harris Hagan
es available. Extended converted casinos premises licences apply to converted casinos that have exer- cised their rights to extended entitlements set out in Schedule 4 of the Gambling Act 2005 (Commence- ment No 6 and Transitional Provisions) Order 2006 (amended by the Gambling Act 2005 (Commencement No 6 and Transitional Provisions) (Amendment) Order 2025). Sixteen “small” and “large” casino premises licences were issued under the Gambling Act 2005 and awarded by the relevant licensing authority area following a public competition. To date, four of the large casino premises licences have been awarded, with one casino since closing. The White Paper pro- poses to reallocate any unused Gambling Act 2005 casino premises licences to other local authority areas (see 4.3 Types of Licences (Premises Licences)). 4.5 Duration of Licences Pursuant to Section 110 of the Gambling Act 2005, operating licences are indefinite in duration, subject to the payment of annual fees and compliance with licence terms and conditions. 4.6 Application Requirements Key Application Requirements for Operators Operating licence applications must be submitted to the Gambling Commission, which will conduct an extensive investigation (having regard to the licensing objectives) in order to determine the applicant’s suita- bility to carry out the licensed activities. The Gambling Commission broadly uses the following principles of suitability to assess any application: • identity and ownership; • finances; • integrity; • competence; and • criminality. Section 69 (2) of the Gambling Act 2005 requires that operating licence applications: • specify the activities to be authorised by the licence; • specify a UK correspondence address; • be made in the form and manner decided by the Gambling Commission (applications must now
be made via the Gambling Commission’s online system); • disclose any relevant offences; • include documents and information requested by the Gambling Commission; and • be accompanied by the prescribed fee. Currently, there are no server location or data storage obligations. Furthermore, the Gambling Commission introduced a strict policy in April 2018 to reject incomplete applica- tions. Key Differences Between Application Requirements for Land-Based and Online Operators Land-based casinos are generally considered to be a high-impact activity in terms of the Gambling Com- mission’s work, which means that applications may attract a high level of scrutiny and interest. In addi- tion, non-remote casino operating licence applica- tions must be accompanied by a casino premises licence application, which must be submitted to the licensing authority of the area in which the premises are situated. 4.7 Application Timing Subject to full information being provided, Gambling Commission guidance indicates that operating licence applications take approximately 16 weeks to process – although the Gambling Commission acknowledg- es on its website that applications may take longer. These timescales may be affected by the quality and complexity of the application, suitability of the appli- cant or those relevant to the application, demand and caseworker availability, links to other applications, and links to any existing licence reviews. In 2024–25, 156 new operating licence applications were submitted and 75% were processed within 16 weeks. 4.8 Application Fees Application fees for operating licences are deter- mined by the types of activities and financial projec- tions for the first year. These can be calculated using the Gambling Commission’s online fees calculator.
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