UK Law and Practice Contributed by: Bahar Alaeddini, David Whyte and Jessica Wilson, Harris Hagan
As announced in the White Paper, fees are expected to increase. At the time of writing (November 2025), a consultation is awaited and likely to take place in 2026. 4.9 Ongoing Annual Fees Annual fees are determined in the same way as appli- cation fees (outlined in 4.8 Application Fees ). Annual fees may be found on the Gambling Commission’s website or may be calculated using the online fees calculator. 4.10 Personal Licensing Types of Authorisations and Licences Personal Licences Personal licences are issued by the Gambling Com- mission under Section 80 and Part 6 of the Gambling Act 2005 and governed by Part 3 of the LCCP. They allow the Gambling Commission to regulate individu- als occupying specific roles and/or responsible for certain activities, and to hold them to account for fail- ings, including any inadvertent or deliberate breaches of the LCCP committed by a gambling business. The two types of personal licences are: • a personal management licence (PML); and • a personal functional licence (PFL). At the time of writing, the LCCP requires persons with responsibility for any of the following specified man- agement offices – as listed in Licence Condition 1.2.1 of the LCCP – to hold a PML: • overall strategy and delivery of gambling opera- tions (this is likely to be the CEO, managing direc- tor or equivalent); • chairperson of the board (where the licensee has such a body), unless that person only holds the position on a transient and short-term basis; • financial planning, control and budgeting; • marketing and commercial development; • regulatory compliance; • gambling-related IT provision and security; • the AML/CFT function, as head of that department; • oversight of the day-to-day management of licensed activities at a number of premises
licensed under Part 8 of the Gambling Act 2005 or across an identified geographical area; and • for casino and bingo licences only, oversight of the day-to-day management of a single set of premis- es licensed under Part 8 of the Gambling Act 2005. The Gambling Commission will also assess, on a case-by-case basis, whether CEOs and directors of “parent companies or subsidiaries in the group” need to hold PMLs. Key individuals for small-scale operators (SSOs) may be exempt from this requirement to hold a PML and instead may continue to apply to hold an Annex A authorisation. Individuals working in a casino who perform any func- tion that enables to influence the outcome of gam- bling, or who are handling cash (eg, croupiers, dealers and cashiers), must hold a PFL. Under Section 133 of the Gambling Act 2005, personal licences may not be issued to individuals who already hold such a licence, but may authorise the performance of more than one function. Annex A authorisation Annex As are a type of Gambling Commission approv- al or authorisation. Individuals who are in manage- ment positions at SSOs, or who are representatives taking bets on behalf of an operator at the tracks, or who are controllers (generally, with 10% or more equity and/or voting rights in an existing or proposed licensee or in its parent company) must apply for an Annex A authorisation from the Gambling Commis- sion. Subject to the Gambling Commission’s discre- tion, operators meeting the SSO exemption may hold Annex As instead of PMLs. Application Process Personal licence and Annex A applications must be submitted to the Gambling Commission, which will assess the application according to the same suit- ability criteria as for operating licences. The requirements for personal licence applications and Annex A applications are broadly the same, but the specific requirements may vary depending on the
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