UK Trends and Developments Contributed by: Bahar Alaeddini, David Whyte and Jessica Wilson, Harris Hagan
Harris Hagan Hamilton House 1 Temple Avenue London EC4Y 0HA UK Tel: 020 3334 8225
Email: info@harrishagan.com Web: www.harrishagan.com
How Changes in the Wake of a White Paper Are Shaping the Gaming Industry’s Regulatory Landscape in Great Britain The regulatory and licensing landscape of the gam- bling industry in Great Britain has evolved significantly during the past 12 months, largely owing to the imple- mentation of many of the proposals set out in the UK government’s 2023 White Paper, “High Stakes: Gam- bling Reform for the Digital Age” (the “White Paper”). Although the move to a post-White Paper era brings much-needed certainty to the regulatory landscape, the proposed reform surrounding tax harmonisation – the outcome of which is not known at the time of writing – seriously threatens to cast gloom over the sector from a commercial perspective. The Gambling Commission is continuing to take regular enforcement action, and failings relating to customer interaction and AML persist, with an appar- ent renewed focus on the latter. Generally speaking, the failings identified have been less egregious and the financial penalties lower than in previous years – although recent enforcement activity, including two operating licence suspensions, might be indicative of a shift in approach. Further, the industry has witnessed an accelerated regulatory focus on tackling the illegal market, including concerns over supplier licensing and the need for licensees to conduct adequate due diligence on their partners. White Paper After the change in UK government in 2024, there was concern as to whether the White Paper proposals – broadly regarded as a fair and balanced response to the previous UK government’s April 2023 review of
the Gambling Act 2005 – would progress as originally envisaged. Concerns were largely unfounded, and implementation has progressed with vigour through- out 2025, bringing much-needed certainty to the industry after a long period of unrest. Noteworthy changes implemented include the follow- ing. • Statutory levy – the annual statutory levy came into force on 6 April 2025. The mandatory levy replaces the voluntary research, prevention and treatment contribution and is collected by the Gambling Commission, based on revenue from licensed activity and calculated using regulatory returns data submitted by licensees. The rate ranges from 0.1% to 1.1% of revenue, with the highest rate applying to remote and gambling software licen- sees. Payments are due annually by October 1st. • Financial vulnerability checks – arguably the most controversial White Paper proposal, the introduc- tion of financial vulnerability checks was a mile- stone for the industry. The requirement that remote licensees conduct a financial vulnerability check on customers with a net deposit threshold of GBP150 per month came into effect on 28 February 2025 after a graduated introduction before then. The check 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). Proportionate action must be taken by the licensee based on the result. • Online stake limits – statutory instruments were introduced imposing a maximum stake limit for online slots of GBP5 (effective as of 9 April 2025),
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