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Sophia and I had the pleasure of attending the Ethical Gambling Forum this year, held at Flutter’s offices in Leeds and hosted by the organisational powerhouses that are Jo Abergal and Adrian Sladdin. Not to mention the hospitality and efficiency of Bridget and her team at Flutter.

Conferences can be strange places, and their purpose can be diluted at best – completely unknown at worst. The best way to describe the EGF is with reference to one of their panels ‘Conference Overload’. This panel did not land. Designed to evoke conversation about whether we should be travelling internationally to attend conferences, and whether they are worthwhile, the panel fell on deaf ears as all attendees shuffled their feet and decided they absolutely wanted to attend this conference. With clear objectives and carefully curated panels, everyone who I have spoken to following the conference have raved of its success – from operators to gambling harms treatment providers.

The buzzwords, because there are always buzzwords, were collaboration, seatbelts and balance.

Collaboration and balance will be well known to all in the industry; collaboration between all major stakeholders within the gaming ecosystem to strike a balance between commerciality and player protection. The overwhelming theme from the EGF was that the best operators are using player protection measures and safer gambling tools like a seatbelt. You never want to use it, but it’s always there just in case.

Sophia and I have picked out some elements of the conference which resonated with us and pieced together some useful information for operators, including the black market, AI, compliance as a commercial advantage and the public perception of gambling.

For any gambling queries, please contact amanda@woodswhur.co.uk, sophia@woodswhur.co.uk  or your usual Woods Whur contact.

 

I recently wrote an article for Eventus International on the importance of annual audits for operators (https://www.eventus-international.com/post/the-importance-of-an-annual-audit), and I was pleased to see a number of these themes echoed by those speaking at the Ethical Gaming Forum this year. Compliance as a central part of gambling is only increasing in importance, and the EGF provided an opportunity for various stakeholders in the gaming ecosystem to come together and discuss how to reassess and reposition compliance, with a particular focus on responsible gambling and player protection.

The first of these proposals comes from the top; ethical corporate governance. This boils down to one simple mantra; do what is right by the customer.  An operator with a healthy relationship with its players is one which has proactive responsible gambling policies, balances policies with execution, and acknowledges the power and influence of certain individuals within the organisation. Audits, staff training and staff mentoring are all helpful ways of achieving ethical corporate governance. Audits can also help to flush out where problems lie; an organisation which is always fighting fires does not have chance to look and figure out where those fires are actually starting.  The biggest disasters hit companies which did not see it coming.

The second method mooted for championing compliance was to rethink who players really are – and who safer gambling tools should be aimed at.

The recognition and acknowledgment that there is a sliding scale of customers should be the starting point. Customers do not fit neatly into two boxes of ‘problem gambler’ and ‘responsible gambler’. This simple recognition has helped a number of operators to reframe their player protection measures and reposition them earlier in the customer journey to assist with harm minimisation by placing friction in the right places. For example some are now implementing an ‘opt out’ process; the guard rails are automatically in place on an account and a customer must actively remove them. Safer gambling tools should be aimed at all customers. In fact – some go as far as to say that safer gambling tools should NOT be aimed at problem gamblers at all – self-exclusion is there for problem gamblers.

A big objective for most operators present was to have every single customer on their platform utilising player protection measures or safer gambling tools, not just those potentially on the riskier end of the scale. A comment I found particularly interesting was a dislike of the phrase ‘ responsible gambling’, because it implies the existence of irresponsible gaming… And whilst that may exist, this leads to stigmatisation of gaming not considered responsible, and can result in a failure to seek assistance in the form of safer gambling tools.

Here is where the ski helmet (or seatbelt) analogy comes into play. Wearing a helmet for winter sports is now considered the norm. It is now strange and somewhat uncomfortable to see someone without a helmet. And yet not too long ago that was the reverse; but most would agree they would rather have it and not need it than need it and not have it!

These changes in the industry do not need to come from the regulator or the legislation, and it is encouraging to see such positive changes coming from the industry itself.

And finally, a reframing of compliance as a commercially beneficial aspect of operations. Compliance as a commercial element may seem either counter intuitive, or even potentially dangerous, to many operators, however it undoubtedly creates opportunity to leverage commercial advantages when utilised correctly. Better customer trust and loyalty, a reason not to stray into the black market, employee retention, brand image and awareness, and – of course- avoiding regulator intervention to name just a few. As a regulatory lawyer, my focus will always be on the latter, but it is important to mention the other benefits too, particularly with a view to ensuring compliance is always considered a cornerstone of the industry.

These benefits also lead me nicely into another theme (and therefore another article!) from the conference; the public perception of gambling.

Amanda Usher

 

 

The illegal online gambling market is growing at pace, taking advantage of regulatory gaps, preying on vulnerable individuals and diverting customer spend from licensed operators. Despite the growing concern throughout the gambling industry, there is still no clear consensus on how to define the black market, or how best to address it.

 

The Ambiguous Market

According to panellists at the EGF, one in five 18-24 year olds who gamble are doing so on an illegal gambling site. Although striking, this figure is only one concern within a broader and rapidly developing pattern of unregulated gambling activity that is beginning to reshape the gambling regulatory landscape. The ‘black market’, a term that in itself is contested, refers to gambling operators targeting customers in countries where they have no legal right to operate, offering little to no consumer protection, no data security and no accountability. Where gambling was previously contained within jurisdictional boundaries, the rapid expansion of the internet has removed a number of the limits on where and how it can take place, allowing a shadow industry to emerge. These operators are typically based offshore, concealed behind private shell companies across multiple jurisdictions, using methods like cryptocurrency for payments and VPNs to hide their true locations. By the time regulators identify a site and move to shut it down, it has already rebranded, rebuilt its platform and resumed operations under a new name.

 

Regulated vs Unregulated

There can be a significant disparity between a regulated gambling site and a site operated by an illegal operator. On a regulated site, customers benefit from a number of protections including data security, affordability checks, intervention mechanisms when spending triggers concern and self-exclusion tools. Operators are bound by law and answerable to the regulator, e.g. The UK Gambling Commission. On an illegal site, however, this tends not to exist. Personal information, such as home addresses, banking details and contact information, is not covered by any protection, meaning it could potentially be accessed by anyone and with no assurance regarding where or how it is stored. Crucially, there are also no limits on spending. The operators’ objective is to extract as much money as possible from the consumer. Customers do not encounter any kind of intervention and the operators are not constrained by any regulations. The framework governing licensed gambling exists to prevent these very forms of exploitation that arise when those safeguards are removed.

The difficulty of differentiating the illegal sites from the legal ones is a prevailing issue at the core of the black market phenomenon. The digital world is now heavily gamified in which points, bonuses, levels and rewards are embedded in everything. As almost every online service is designed to mimic the look and feel of a game, consumers face real challenges in deciphering a licensed gambling operator from an illegal site. In reality, a lot of people will have no idea that they are gambling on an illegal site. Modern gambling has evolved to exploit the biases in human decision making whereby simplicity is desired. Illegal operators have capitalised on this by creating systems of minimal effort with no age verification, no background checks and no self‑exclusion mechanisms. The easiest way to determine the difference between an illegal vs legal site is the fact that every regulated gambling site is registered with its relevant authority and its licence number can be verified against the regulator’s public register. In practice, however, very few users take this step, leaving considerable challenge and risk in this area.

One of the most concerning features of the black market is its deliberate targeting of individuals who have recognised their vulnerability and self-excluded. Self‑exclusion schemes such as GamStop allow people to block access to all licensed operators. Yet some illegal providers actively advertise themselves as “Non‑GamStop” sites, intentionally positioning themselves to attract those actively trying to stop their gambling. Accordingly, the black market is intentionally exploiting the very individuals the regulatory system is designed to protect.

 

Black, white or Grey?

There is also a debate concerning the term ‘black market’, which is not universally accepted. Some members of the industry prefer to include the terms ‘ambiguous market’ or ‘grey market’ as well, considering the fact that what will constitute illegal gambling will vary significantly from jurisdiction to jurisdiction. In some US states, for example, technically all gambling that takes place is illegal.

What is clear is that the challenge is unifying operators and regulators. Twenty years ago, grey markets dominated and white markets were the exception. Today, the dynamic is shifting again, with the licensed, compliant sector increasingly finding itself on the back foot. Some suppliers are already treading the line between the licensed and unlicensed industry. In the US, the political landscape makes it unlikely that major tech firms will be pressured into removing illegal gambling search terms or content. Turning to the UK, the conversation has shifted from elimination to mitigation. The black market cannot be entirely eradicated, but the regulated market could be made more attractive. If licensed gambling genuinely offers a better experience than its illegal counterpart, the appeal of the alternative begins to fade. This, taken in conjunction with better information being made available to players on how to identify an illegal site, represents the most practical solution.

 

Ultimately, there is no silver bullet, but acknowledgement is the starting point. Recognising that the black market is not a minor concern but in fact a threat to the gambling industry as a whole. From there, the solution will lie in collaboration between the gambling operators and the regulators, providing as much information to consumers as possible and working to ensure that the regulated market is not just the legal option, but the more attractive one.

Sophia Anstey

Artificial intelligence is rapidly infiltrating the gambling sector and its influence has already been seen to reshape how operators run their businesses. As AI systems become more deeply embedded in everything from identifying and evaluating customer interactions to marketing operations, the industry faces a pivotal question: how to embrace this technological progress while upholding the standards of responsibility required for such a sensitive landscape.

 

The power of AI

AI’s potential is undeniable. It equips operators with the ability to make processes far more efficient, including detecting early signs of harmful behaviour in consumers. Yet these capabilities bring equally significant concerns. Operators must ensure that human oversight remains central, that data is used ethically and that vulnerable individuals are protected from unintended consequences and feel that their problems are truly being recognised. Used responsibly, Ai can become a powerful tool in building safer, more efficient systems. Used poorly, it risks regulatory breaches and real harm to the people the industry is duty bound to protect.

A huge opportunity AI presents in gambling relates to safer gambling. Modern AI systems are capable of monitoring millions of behavioural signals in real time to track patterns in deposit frequency, session length and chasing losses, able to identify early indicators of gambling harm at a faster rate than the equivalent human team. The tension emerges when AI is brought into the sphere of customer interactions, which is typically divided into three stages. Stage 1 involves identifying whether a customer may be suffering from gambling-related harm; Stage 2 involves interacting with the customer; and Stage 3 involves evaluating the interaction and acting on the information. For the first and final stages, Identify and Evaluate, AI can be an excellent tool. It can process large data quantities, recognise behavioural patterns and produce detailed assessments of risks. This helps operators understand the scale of the potential harm and reduce the likelihood that warning signs go unnoticed. Nevertheless, the second stage, Interaction, is where the controversy lies.

 

Where to draw the line?

Safer gambling has historically relied on human judgement, empathy and the ability to understand contextual factors that an algorithm might miss. When customers are in distress, struggling, reach out or require approaching with care, human interaction is essential. When a customer struggling with a gambling problem reaches out for support, discovering that the person they’re speaking to is actually an algorithm can result in a serious escalation of negative feelings, the adverse effect to the intended purpose of the assistance. This often causes trust in the operator to dissolve whereby the customer disengages and the interaction fails in the moment it is needed the most. For this reason, even as the capabilities of AI continue to expand, operators must remain cautious and, in fact, reluctant to deploy the use of AI at the direct interaction stage with customers at risk. AI should be confined to being a tool to assist in the identification and evaluation functions, but the human conversation must remain human.

 

Turning to Advertising

The efficacy of using AI has also been recognised in the advertising and marketing sector of the gambling industry. It is clear that AI can be advantageous in monitoring marketing trends, tracking engagement and analysing data to better understand the customer and create more tailored and engaging materials. However, this also creates new risks in that the rapid growth of AI generated content for advertising has provided a platform for bad actors and the gambling black market is moving fast to exploit it. Social media has long been a platform for gambling advertising, with pop-up ads on almost every site and influencers promoting gambling sites to their followers. However, increasingly, these adverts are directing audiences towards illegal, unregulated black market platforms where sites are operating outside the protections afforded by licensed operators, with no obligations on responsible gambling, no customer protections and no accountability.

The recent surge in AI generated influencer personas has taken this issue even further. These exist as entirely fabricated personalities that are created by AI with no traceable identity and therefore no accountability. The result is fake personalities promoting illegal gambling platforms, targeting potentially vulnerable users online, thousands of times a day across multiple social media channels simultaneously. This risks the harm of directing people, including those with gambling problems, towards entirely unregulated sites. It is imperative that social media platforms work with the regulators to contain this fast emerging issue.

 

Using AI responsibly offers great potential for gambling operators to get ahead. Operators using AI intelligently, ethically and whilst retaining human oversight can build more responsive and more sustainable businesses. Conversely, the potential for operators to get it wrong is equally as tangible through misplaced algorithms in interactions. Operators must ensure that efficiency is not permitted to override ethics and that humans always have the final say. Taken in conjunction with the AI advertising threats emerging from the black market, the gap between responsible and reckless AI use must be closed.

Sophia Anstey

The public perception of gambling feels like it is at an all time low. Between negative media, recent policy and government decisions, the implementation of the levy and the new English Devolution and Community Empowerment Bill, it is easy to see how often the industry is vilified in the public eye.

The media appears to relish any opportunity to highlight any failings in the industry. If an operator fails in its duties, the Commission fully investigates and punishes as appropriate in due course, but the media reaction is instant… and the political desire to be ‘tough’ tends to result in at least one sound bite at the optimum moment. Gambling often feels like an easy target in these cases, and the stringent responsible gambling requirements places the target squarely on the operators.

Furthermore, from the EGF to the Gambling Commission’s Spring Conference, it has become clear that research into the industry is overwhelmingly targeted on the potential negatives. There is a clear focus on the harms of gambling and how the industry may be failing to prevent such harms – or even increasing the potential for harm. There does not appear to be much, if any, research into any positives of the industry. The fact it can be healthy, sustainable entertainment, a social environment with enjoyment channelled through product innovation. Fun. I am sure there are a multitude of other positives – and I would love to hear from those who agree with what they think are most vital.

There is of course a natural customer bias against gambling simply for the reason it is possible to lose. And it would be irresponsible to discuss gambling in this way without allowing for the statement that players are also accountable for their own actions. That does not in any way detract from an operators requirement to protect its players and do its utmost to reduce the potential for harm.

The Customer Safety Centre of Excellence at Flutter was a fascinating experience. A fully immersive environment designed for education and practical training, the segment on how to deal with family and friends when your job comes up was a refreshing take on something many of us will have experienced. The ability to instil a positive view of the industry thanks to the advances in safer gambling was heartening, and I am sure there will be a number of other operators instilling similar attitudes wherever they can in an attempt to improve the public perception of gambling.

The Statutory Levy

The levy seems to have caused a pivotal shift in this particular corner of the industry. What appeared with great celebration has caused many to scratch their heads and wonder what has happened – or rather what has gone wrong. The old system undoubtedly lacked accountability and was due an overhaul, but the uncertainty which both the industry and the relevant charitable organisations have been left with has been unbearable in some cases.

Aside from the poor management and implementation of the policy which has left many in the lurch, the parameters for funding have also caused much controversy. Any organisations who are entrenched with the operators to help create safer gambling systems are no longer eligible to receive funding. This seems a real shame, and very narrow minded. In the same vein, any organisation who is now receiving funding from the levy cannot have any direct contact with the industry; no direct funding, no data – not even allowed to attend conferences with an industry presence. The word collaboration comes to mind?

The result of this has been a number of fantastic organisations having to make the decision not to apply for funding so that they can continue to collaborate with the industry to create a safe player environment. The industry has a wealth of knowledge of their sector and their players, and most have an increasing desire to put their players first and champion customer safety. Not including them in the conversations seems utterly illogical.

English Devolution and Community Empowerment Bill 2026

This public perception of gambling is echoed across the non-remote sector as well. The English Devolution and Community Empowerment Bill 2026 has now come into force as a result of a great deal of public lobbying. The pertinent section of this Bill is s87 Licensing of gambling premises: impact assessments. The introduction of Gambling Impact Assessments is problematic in so many ways it is hard to list them, but we will be watching closely to see who and when any Licensing Authorities choose to bring these into play. 

Amanda Usher

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.

1. Welcome – Katherine Diamond (Chief Counsel for the Gambling Commission)
2. Opening Remarks – Sarah Gardner (Acting Chief Executive of the Gambling Commission)
3. David Halpern CBE – Key Note Speaker – founding director of the Behavioural Insights Team
   • David made several interesting points about decision making based on choices offered. For example, lowering the maximum deposit limits as the maximum option acts as an anchor – the higher the ‘highest option’ the higher people set their limits. Allowing individuals to type their own deposit limit also lead to lower limits set by customers
   • He also discussed the problems surrounding symmetry of friction within a customer journey- you can dial it up (withdrawing deposit, cancelling accounts) or down (joining, upping thresholds), depending on the aim which can be dangerous.
   • David put forward a proposal of enforced breaks for online operators 3 or 6 seconds enforced. Similar to an app called 1 sec that you can download to your phone. Overall a very interesting key note with some unusual observations which can be easily applied to the industry.
4. Building a Shared Data Future under the Statutory Gambling Levy
   • Facilitator – Ben Haden (Director of Research and Statistics at the GC)
   • Panel – Andy Boyd (Director of UK Longitudinal Linkage Collaboration), Sam McGreggor (Deputy Director of Smart Data Research UK), James Skruton (SRS Head of Data and Environment for the Office of National Statistics) (Partner of ADI UK), Sukriti Verma (the Head of Analysis for Sport and Gambling for DCMS), Dr David Zendal (Director of Smart Data Donation Services)
   • Nothing of much note for the industry within this panel, the key drivers of the conversation were the research bodies discussing how important data sets are and making the case for operators sharing all of their customer data with the research teams to help with evidence backed policy setting. It appears the research bodies are trying to use the statutory levy to access this data. When asked whether such data could in turn be made available to an individual from the industry (as an accredited researcher), the research bodies were extremely hesitant. Reading between the lines – this would be a no.
   • UKRI seem to be in a difficult position regarding the levy due to a reluctance to liaise directly with operators. 
5. Gambling related harm: approaches to measurements and insights from underrepresented groups (Evidence Theme 3: Gambling-related harm and vulnerability)
   • Facilitator: Sue Cox (Member, LEAP)
   • Presenters: Dr Naomi Muggleton (Associate Professor Warwick), James Close (Associate Professor in Medicine and Psychology at Peninsula Medical School), Dr Mercy Denedo (Associate Professor Accounting, Durham), Dr Liz Riley (Head of Research and Evaluation Betknowmore)
   • This sadly related to female victims of domestic abuse, that was linked to Gambling, as well as other issues such as alcohol abuse. They were linking domestic abuse with Gambling addiction, both of partners having spent all family money and indeed women turning to Gambling as both a means to get away from the difficulties of life, as well as seeing it as an opportunity to make money. It was not really of benefit for our work, as these were individual cases per se. It was used just to highlight the issue that it is not just the gambler that is affected.
6. Illegal Gambling – Developing the Evidence Base (Evidence Scheme 6- Illegal Gambling and Crime)
   • Facilitator – Ian Angus (Director of Policy at Gambling Commission)
   • Presenters – Tim Livesley (Head of Data Innovation Hub at the Gambling Commission), Tom Smith (Data Scientist for the Gambling Commission)
   • Panel – Jonathan Heath (Head of Gambling Duties Policy Team at HMRC), Peter Eerligh, Helen Walton (Chief Commercial Officer and Founder of G Gaming)
   • GC and HMRC are working together to try and negotiate where the illegal market sits, including navigating any potential ‘pinch points’ (advertising, social media, payment providers etc) to try and quell the spread of illegal sites
   • The GC’s data on the illegal gambling markets do not include any access through a VPN, which means that they have lowered/levelled off their figures based on their own decisions. Furthermore, all of their data is based off one metric, so they are aware it is not perfect. The Online Safety Act resulted in the doubling of VPN usage back in July/August last year. There was a slight decline towards the end of the period, but it is still a 40% increase on before.
   • There is a clear distinction within the illegal gambling conversation between an unlicensed operator and an operator licensed in another jurisdiction. An example was given of Stake.com who are not using malicious advertising techniques but still received a huge amount of traction due to the level of customer service they offer. This is partly due to the low friction for customers, but also the higher RTP and bonus structures.
   • Questions were asked about whether the plan to disrupt illegal markets by targeting suppliers would be effective, as any non-UK centric suppliers would simply switch off the UK. Overall a very interesting conversation which highlighted the nuances of this area.
7. Gambling, AI and the Consumer Experience – (Evidence Theme 5  Product, Characteristics and Risk)
   • Facilitator – Brad Enright (Director of Strategy at the Gambling Commission) (not AI expert)
   • Panel – Sandy Chidley (Evidence Lead for Gambling and Lotteries for DCMS) (not AI expert), Leon Green (Member of the Lived Experience Advisory Panel) (not AI Expert) and Daphne Tsatsoulis (Head of Data Science at Flutter) (AI Expert)
   • AI has been used to personalise customers experiences for many years now, and there were discussions around the boundary between helpful suggestions versus predatory tactics. Using AI to flag worrying customer behaviour and then interact can be helpful, but it must be explainable and transparent. For this reason, Gen AI has actually not got very far for customer facing activity, although some operators are using it to provide summaries of a customer’s profile/journey to help inform interactions.
   • Concerns about chatbots were raised, particularly the fact they can’t pick up on emotions and shouldn’t be ‘left alone’ to liaise directly with customers.
   • Safety by design and good collaboration should at the heart of gambling innovation. For example, a good use of AI could be summaries of Terms and Conditions to customers to help operators ensure they are fair and open.
   • Talk of ‘Safety profiles’, in which operators let customers see their safety profiles and any concerns. This seems short sighted – and gives customers the knowledge of how to avoid being detected.
8. Growing up online: children and young people’s digital footprints and pathways to gambling (Evidence Theme 1: Early gambling experiences and gateway products)
   • Facilitator: Matt Losing (Member, LEAP)
   • Presenters: Sumita Deb (Senior Online Audience Analyst OffCom), George Webster (Director Humankind Research)
   • Panel: Donna Bateman (Strategy and Engagement Manager, GC), Bal Kaur (Member LEAP)
   • This concentrated on a study from 12 to 17-year-olds. However, Gambling was not the focus and just looked at how addictive social media and online content could be. Interestingly, YouTube was deemed to be less harmful than Snapchat and Instagram, for example.
   • Focus from a separate speaker, linked loot boxes to Gambling in later life. There was also a strong link with football, with people taking social benefit from placing a bet on teams as it was part of their Saturday social and conversation with other friends.
9. Engagement with Purpose – how operator practices impact consumer experiences. (Evidence theme 4 – The Impact of Operator Practices)
   • Facilitator – Kirsty Caldwell (Interim Chair of the Industry Forum)
   • Presenter – Dr Maris Catania (Director of Fair Sustainability for Leo Vegas), Nigel Chamberlain (Operations Director for Retail Support Entain), Sue Wade (Head of Gambling Policy at Flutter)
   • Customer research is seen as vital to ensure genuine engagement, a current problem area for most operators. Emails are seen as day to day and non-urgent (and often deleted), but text or push notifications are seen as more urgent or event lead. Over messaging makes people check out and leave to go to other operators and personalisation is more important than volume. Control and boundaries are seen as non-negotiable, operators have to earn the right and build the trust to be able to have the conversations that you need to have for customer protection. Phone calls tend not to work for younger generations (who do not answer the phone), but voice notes may be explored as a better option
   • Several operators have seen a big take up of safer gambling tools when they have changed the way they interact with their customers. For example emailing a survey once a year received 1% response rate, whereas an in-product version produced 17% responses.  Timing has also helped for safer gambling interactions – when a customer is actually on the site (and consequently in the frame of mind to think about gambling) is the best time.
   • Customers can also be incentivised to use safer gambling tools, for example a campaign was run with Pure Gym where if you signed up to the safer gambling tools, you got a free gym pass. This doubled the use of a profit and loss campaign from 12.6% to 21.5% (compared to just using a standard SG prompt). Wellness and safety connections are viewed as very positive, generally agreed that free spins or similar in exchange for signing up to SG tools would not be helpful (or appropriate)
   • Some CI/SG suggestions:
     • Providing customers with a clock of how much time they are spending on a siteIndividualised outcomes from interactionsTailored approaches to interactions based on thresholds/triggersEnhanced staff training for those dealing with interactionsEvaluate effectiveness of CI’s by comparing pre and post CI behaviour 
10. Closing Remarks
    • Closing remarks from Charles Counsell (Interim Chair of Gambling Commission) and Tim Miller (Director of Research and Policy at the Gambling Commission)
    • The research posters generally all had central anti-gambling themes:
      • Proximity to gambling shops and gambling harms
      • Effects of Interventional public health laws and regulations intended to reduce gambling-related harms: a narrative systematic review
      • Matched Betting: Risk-free Opportunity or emerging source of gambling harm?
      • Gambling behaviour, disordered gambling and commodities
      • Using complex system dynamics to analyse the relationship between contemporary gambling policy and big data
      • Consent Banners, Dark Patterns and GDPR infringements in online gambling: evidence from a systematic audit and online experiment
    • Tim Miller – closed with statements including we “have to get comfortable with nuance” because that’s what the data and evidence shows, and “Uncertainty can never be irradicated, we have to find ways to live with it”.

The government has announced plans to relax licensing hours for select Home Nation matches in anticipation of the FIFA Men’s World Cup 2026 this summer. This follows shortly after the Home Office held a consultation on a proposed Licensing Hours Order under Section 172 of the Licensing Act 2003 at the end of last year. Under Section 172, the Home Secretary may extend permitted hours for events of exceptional national significance. Previous Orders were made for the 2010 and 2014 World Cups, with the latter offering the largest extensions due to the Brazil time difference.

The recent press release, published 27 January 2026, broadens the scope of the suggested relaxation as part of a larger support package for the hospitality sector ahead of the tournament.

 

England & Wales: Proposed licensing hours order and Government update

The Home Office’s original consultation proposed a national relaxation of licensing hours for the semi‑finals and final, provided a Home Nation (England, Wales, Scotland or Northern Ireland) reaches those stages. The consultation closed on 15 January 2026 and is currently under review.

A new Government press release confirms that the proposed relaxation will now also apply to quarter‑final matches. The extension will allow pubs in England and Wales to open later without applying for a Temporary Event Notice for the following:

• Premises may remain open until 1am for any quarter‑final, semi‑final or the final if the match starts at or before 9pm BST.
• Premises may remain open until 2am for any quarter‑final starting at 10pm BST.

However, matches beginning after 10pm BST will not benefit from this extension so premises will need to rely on existing permissions or apply for a TEN if they wish to open later.

For all other games, operators will still need to rely on existing licence hours or submit a TEN where later opening times are required. The Government has confirmed that it is exploring options to extend opening hours for additional Home Nation matches, though no further details have yet been published.

Please see the following link to the January 2026 Press release: https://www.gov.uk/government/news/government-announces-support-package-that-backs-british-pubs

 

Scotland: Local licensing board extensions

Scotland operates under a separate licensing framework. Section 67 of the Licensing (Scotland) Act 2005 allows Licensing Boards to grant general extensions for events of local or national significance.

Several boards have already announced their positions:

• Aberdeen City Licensing Board has approved a blanket extension to 03:00 for Scotland matches, with additional time permitted if a match runs beyond that.
• East Ayrshire Licensing Board has indicated it is likely to adopt a similar approach.
• Glasgow City licencing board has also approved an extension lasting until 30 minutes after the final whistle for all matches.
• City of Edinburgh Licensing Board is consulting on a general extension for matches falling outside normal licensed hours. The consultation closed on 9 February 2026, with a decision expected on 23 February. Edinburgh adopted a similar extension for the 2014 World Cup.

Approaches may vary across Scotland, so operators should monitor local Board decisions closely.

 

What next?

Although the final Licensing Hours Order has not yet been published, operators can begin preparing by reviewing existing licence hours and identifying the matches that may still require TENs. It would also benefit operators to begin planning staff, security and dispersal arrangements for extended hours.

We will continue to monitor Government developments and provide further updates as soon as information becomes available.

What a start to 2026. Andy, Chris, Amanda and I kick started the year at ICE in Barcelona and we didn’t stop. I feel that Barcelona has really breathed life into ICE and our relationship with iGB Executive is really bearing fruits. It is a fantastic opportunity for networking. On the first night Chris and I took part in a networking Paella cooking competition in an old restaurant in the Gothic Quarter of Barcelona. This was a great opportunity to meet new people and the vino blanco helped to get people chatting. On the last night we hosted several clients for drinks and food, where? What says Barcelona more than an Irish bar….of course.

On the second morning we hosted a “Compliance Open Space” in the iGB Executive Lounge. This was a great concept. We each took a table of 10 people and asked all to write on a post it note the issues they would like to discuss in the session. We had operators from all over the world and the three areas chosen to look at closely in the 2 hour session were:

• Operators relationship with the Regulator–what are the levels of compliance required.
• AI and how it will factor into the gambling market from the operator and the regulator perspective.
• Crypto currencies. How are they viewed from different regulator perspectives.

We teased out some fantastic debate and a report is currently being drafted which we will circulate.

What we did conclude was that the UKGC seems to be ahead of the curve on AML KYC and customer interaction requirements to avoid vulnerable people being affected by problem gambling. In fact many international operators were surprised to learn of the UKGC requirements.

As a result of this I thought it was worthwhile refreshing our minds on Regulatory Compliance in the UK.

Our session reconfirmed that the UK gambling market is one of the most tightly regulated in the world. Compliance with the UK Gambling Act is not just a legal obligation—it is central to maintaining a licence, protecting consumers, and preserving brand reputation.

1. Legislative Framework

The foundation of UK gambling regulation is the Gambling Act 2005, which established a comprehensive licensing and regulatory system. The Act has been updated through subsequent legislation and regulatory reforms, including the Gambling (Licensing and Advertising) Act 2014. We will always follow these amendments as the legislation changes and advise clients in advance of them.

Oversight and enforcement are carried out by the UK Gambling Commission (UKGC), which issues licences, sets regulatory standards, and imposes sanctions for non-compliance. From a personal perspective I have seen a considerable swing to the regulatory and enforcement roles of the Commission in recent times.

2. The Three Licensing Objectives

Under the Gambling Act 2005, all licensed operators must uphold three core objectives:

• Preventing gambling from being a source of crime or disorder
• Ensuring gambling is conducted fairly and openly
• Protecting children and vulnerable persons from harm or exploitation

Every compliance requirement ultimately ties back to one or more of these objectives. They should always be a prime focus to operators and the Regulator.

3. Licensing Requirements

Operators offering gambling services to customers in Great Britain must obtain the appropriate operating licence from the UKGC. The process of applying can be time consuming and the level of detail required is high. Managing client’s expectations through this process is often difficult.

Personal management licences (PMLs) are also required for key personnel in specified management roles.

Failure to obtain the correct licence before offering services to UK consumers is a criminal offense.

4. Licence Conditions and Codes of Practice (LCCP)

The UKGC enforces compliance through the Licence Conditions and Codes of Practice (LCCP). It is well worth regularly assessing your operating systems to check whether you are in compliance with the LCCP and if needed bring in external consultants to audit. It is much better to exhibit good compliance than risk regulatory enforcement action.

These contain:

• Social responsibility requirements
• Anti-money laundering (AML) obligations
• Customer interaction mandates
• Advertising standards
• Reporting and key event notifications

Non-compliance can result in financial penalties, licence suspension, or revocation.

5. Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF)

Operators must comply with UK AML legislation and conduct risk-based customer due diligence (CDD). Core obligations include:

• Customer identity verification
• Source of funds/source of wealth checks (when appropriate)
• Ongoing transaction monitoring
• Suspicious Activity Reports (SARs) to authorities
• Maintaining an up to date AML Risk Assessment

AML compliance must be proportionate to the operator’s risk profile and regularly reviewed. This is an area where the Commission are keen. You risk your operating licence if you do not have robust AML systems.

6. Safer Gambling and Social Responsibility

The UKGC has increasingly focused on consumer protection. Operators must:

• Monitor customer behaviour for indicators of gambling harm
• Implement timely and meaningful customer interactions
• Offer deposit limits, time-outs, and self-exclusion tools
• Participate in the national self-exclusion scheme
• Regularly assess their customer interaction procedures as a whole to monitor genuine effectiveness and appropriate outcomes

Affordability assessments and financial risk checks are evolving areas of regulatory focus.

From our ICE session this is where we noticed the main points of difference between the UK regulatory framework and all other jurisdictions we discussed.

7. Advertising and Marketing Compliance

All gambling advertising in the UK must comply with:

• UKGC requirements
• The UK Advertising Codes (CAP and BCAP)
• Rules prohibiting targeting of children or vulnerable individuals

Marketing communications must be socially responsible, transparent, and not misleading—especially regarding bonuses and free bets.

8. Reporting and Regulatory Engagement

Operators must report:

• Key events (e.g., regulatory investigations, financial difficulties)
• Regulatory returns (periodic financial and operational data)
• Suspicious gambling activity
• Proactive engagement with the UKGC and transparent reporting can mitigate enforcement risks.

9. Enforcement and Sanctions

The UKGC has broad enforcement powers, including:

• Financial penalties (which have reached multi-million-pound sums)
• Licence suspension or revocation
• Formal warnings
• Personal licence reviews

Public statements accompanying enforcement actions can significantly impact reputation and investor confidence.

Most enforcement action starts life as a compliance assessment. Operator’s whose policies and procedures are in good working order and being effectively implemented tend to come out of compliance assessments well.

10. Best Practice for Sustainable Compliance

To maintain effective compliance, operators should:

• Establish a strong compliance culture from board level downward
• Conduct regular risk assessments
• Maintain comprehensive policies and procedures
• Invest in compliance technology and monitoring systems
• Provide ongoing staff training
• Perform independent audits

Compliance should not be reactive—it must be embedded into daily operations

In Conclusion

UK Gambling Act compliance is a dynamic and evolving obligation. With increasing regulatory scrutiny and heightened expectations around consumer protection, operators must adopt a proactive, risk-based approach.

A well-structured compliance framework not only protects a gambling license but also builds trust with regulators, customers, and stakeholders. In the UK’s mature gambling market, compliance is not just a requirement—it is a competitive advantage.

If anyone requires bespoke compliance advice I can be reached at paddy@woodswhur.co.uk

It feels like every time we mention Gambling in the UK, whether in an article, a presentation or a training session, we say now is more important than ever to keep up to date with changes… Whatever you do make sure you’re signed up to the e-bulletin’s, check the GC News page and look out for consultations.

It’s safe to say the start of 2026 has not broken this trend! The following is a quick run down of the current or incoming changes to be prepared for, including the open consultations to respond to.

Increase to operator fees

Perhaps the most important for some operators? The consultation launched by DCMS on 29 January 2026 is open until 29 March 2026 with any changes coming into effect from 01 October 2026.

There are three options for the increase of fees:

Option 1: 30%

Option 2: 20%

Option 3: 20% + 10% ringfenced for tackling illegal markets and protecting licensed operators’ revenue from criminal activity.

These relate to new applications, annual fees, personal licences, variations, change of corporate control applications… the lot.

These are overall increases though, with the actual fees being calculated based on market share and weighted by regulatory risk (other than General Betting Limited, ELM’s and Society Lotteries).

https://www.gov.uk/government/consultations/proposed-changes-to-gambling-commission-fees/proposed-changes-to-gambling-commission-fees

Illegal Gambling Taskforce announced

Another announcement at the end of January, tying in quite nearly with Option 3 above, the UK Gambling Minister Baroness Twycross has announced the formation of an Illegal Gambling Taskforce in an attempt to tackle the increasing risk of black market operators.

Between the tax increase and the proposed increase in fees, the GC look to be setting aside serious funding to assist this ongoing battle. This is likely to include a holistic look at the gambling industry as a whole – from the software manufacturers to payment providers. It is clear that GC operators will be expected to play their role; the GC do not really have direct access to the unregulated market, but they can attempt to starve it out by ensuring their regulated operators blacklist any of their own providers who are linked to the black market.

Tighter restrictions on removal of machines in AGCs

Last month it was announced that from 29 July 2026 all AGC operators must immediately remove any machines from their premises if the GC informs them that any aspect of the machine – from the manufacture to the repairs- has not been correctly carried out in reliance on a gaming machine technical operating licence.

Of course AGC operators should already be ensuring their gaming machines are fully compliant, but this appears to be focusing on the speed at which the GC (and AGC operators) can protect customers.

Consultation on update to the destination of regulatory settlements

The most recent consultation to be launched relates to the regulatory settlements. This may seem like a tick box exercise, with the introduction of the Statutory Levy and the winddown of GambleAware, but for anyone affected by these payments it is critical to get involved and have your say. At the moment, the main proposal is to simply align the regulatory settlements with the other financial penalties and put them straight into the Consolidated Fund.

https://consult.gamblingcommission.gov.uk/policy/consultation-sop-destination-reg-settlements/

Key Event Reporting

From 19 March 2026 the new LCCP 15.2.1 comes into force, raising the reporting thresholds for relevant persons and expanding its definition to include entities without share capital (excluding lotteries)

Digital Markets, Competition and Consumer Act 2024

The DMCCA 2024 will result in an update to LCCP 7.1.1 and SR Code 5.1.9 from 06 April 2026 – replacing the wording relating to the Unfair Trading Regulations 2008.

The DMCCA may also result in changes to SR Code 6.1.1 relating to ADR regulations, however there is no date for this yet.

 

For any further information on any of these changes or proposals please contact Amanda@woodswhur.co.uk or your usual WW contact.