Gaming Law 2025

UK Trends and Developments Contributed by: Bahar Alaeddini, David Whyte and Jessica Wilson, Harris Hagan

reduced to GBP2 for those aged 18–24 years old (effective as of 21 May 2025). • Online game design – new Remote Gambling and Software Technical Standards (“the RTS”) took effect on 17 January 2025. The updated RTS introduced new requirements in respect of online game design, including a minimum spin speed and the display of net spend and time information for casino games, the prohibition of features that may give the illusion of “false wins”, and a ban on offering the ability to play multiple games simulta- neously. • Liberalisation for the land-based sector – convert- ed 1968 Act casino licensees were granted extend- ed gaming machine entitlements (from 20 to up to 80 based on their meeting size requirements) and permitted to offer sports betting when legislative changes took effect on 22 July 2025. The changes bring welcome and long-overdue modernisation to the land-based sector. Despite the progress made to date, some cornerstone proposals are still in the pipeline. There has been lim- ited update on progress in relation to the creation of a gambling ombudsman, which was originally due to start taking claims from summer 2024. The intention is for the gambling ombudsman to be an independent, free-to-use, non-statutory body that will handle social responsibility complaints from consumers. However, there has been limited progress on the creation of the gambling ombudsman. Further, the industry awaits the outcome of the Gam- bling Commission’s pilot testing the practicalities of remote operators using frictionless financial risk assessments to assess the risk of gambling harm for the highest-spending customers. The purpose of the three-stage pilot was to test how financial risk assess- ments would work in practice and to assess appro- priate thresholds. Finally, and in line with the com- mitment in the White Paper to review its funding, the Gambling Commission announced in April 2025 that it will be launching a fees review in 2025. Increases to licence fees can be expected to follow. Illegal gambling Tackling illegal gambling and the unlicensed market is a priority for the Gambling Commission, with its three-

year corporate strategy for 2024–27 citing increased investment, resources and capacity to tackle ille- gal gambling as a key commitment. That focus has accelerated during the past 12 months, with Gambling Commission CEO Andrew Rhodes stating that “the illegal online market is unsafe, unfair and criminal – that is why the [Gambling] Commission has invested heavily in this area in recent years”. One of the White Paper proposals was to increase the Gambling Commission’s powers to tackle the illegal gambling market. On 25 February 2025, the Crime and Policing Bill was introduced to Parliament, which includes provisions for the Gambling Commission to obtain suspension orders to take down IP addresses and domain names associated with unlicensed gam- bling. At the time of writing, the Crime and Policing Bill is at the committee stage in the House of Lords. In the meantime, the Gambling Commission has been continuing its efforts in this area and – in addition to its issuing of cease and desist notices and referring con- cerning URLs to search engines to have unlicensed gambling websites taken down – it has achieved the following. • In December 2024, the Gambling Commission commenced a review of a supplier’s operating licence, having identified that its games were being provided to several unlicensed operators of web- sites accessible from Great Britain. • In January 2025, Andrew Rhodes provided a warn- ing to licensed operators to undertake their own due diligence on third-party suppliers and partners to ensure that those partners and suppliers are not engaged in unlicensed activity in Great Britain. Andrew Rhodes reiterated this warning in Novem- ber 2025. • Between September and November 2025, the Gambling Commission published a four-part series on illegal online gambling, which aimed to under- stand consumer engagement with illegal online gambling, the associated risks posed, and the actions being taken to address it. • In October 2025, the Gambling Commission suspended a supplier’s operating licence on the grounds of suitability, owing to “serious non- compliance with the hosting requirements of the [Gambling Commission’s] licensing framework” –

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