The Gambling Commission have made changes to the Licence Conditions and Code of Practice (LCCP) condition 15.2.1, in relation to the reporting of ‘Key Events’ that will come into force today, 19 March 2026:
Paragraphs 1, 2 & 3 have been expanded and now read as follows:
Condition 15.2.1, Paragraph 1 (new text added to raise the reporting threshold for ‘operator status’ and ‘relevant persons and positions’ from 3 percent to 5 percent)
1. Any of the following applying to a licensee, any person holding a key position for a licensee, a group company or a shareholder or member of the licensee (holding 5% or more of the issued share capital of the licensee or its holding company):
a. presenting of a petition for winding up
b. making of a winding up order
c. entering into administration or receivership
d. bankruptcy (applying to individuals only)
e. sequestration (applicable in Scotland), or
f. an individual voluntary arrangement.
Applies to: All operating licences.
Updated Licence Condition 15.2.1, Paragraph 2 (new text added to expand the application of ‘relevant persons’ to include entities without share capital ((the GC have excluded society lottery licensees from this change))
2. In the case of licensees who are companies, bodies corporate, or other legal entities (but excluding society lottery licensees where stated), the name and address of any person or entity who (whether or not already a shareholder):
a. becomes a shareholder holding 5% or more of the issued share capital of the licensee or its holding company; or
b. controls 5% or more of the voting rights of the licensee or its holding company, excluding society lottery licensees; or
c. is entitled to 5% or more of the dividends or profits of the licensee, excluding society lottery licensees.
Applies to: All operating licences excluding society lottery licensees where stated.
Condition 15.2.1, Paragraph 3 (new text added to ensure that all relevant loans are reported, whether or not agreements are in writing)
3. The taking of any loan by the licensee, or by a group company who then makes an equivalent loan to the licensee, from any person not authorised by the Financial Conduct Authority: a copy of the loan agreement, if any, must be supplied.
Applies to: All operating licences.
In addition, an equivalent amendment will also take effect in the Licensing, Compliance and Enforcement Policy Statement under the Gambling Act 2005 to raise the threshold of shareholders to be listed from 3 percent to 5 percent under the section about Licensing (under the heading, ‘Identity and Ownership’).
Should you wish to discuss any element of the above, please contact Chris at chris@woodswhur.co.uk or your normal Woods Whur contact.