The Home Office released revised Section 182 Guidance on 26 November 2025. The guidance is provided to support licensing authorities to carry out their functions under the Licensing Act 2003.

Normally the Home Office confirms what changes have been made, but for this revision, they merely confirm ‘The Guidance has been updated’.

The two major updates are as follows:

-A new Paragraph 1.18, that states: “When making licensing decisions, all licensing authorities should consider the need to promote growth and deliver economic benefits.” This ties in with the newly published National Licensing Policy Framework, whereby the Home Office are possibly looking to add “making growth of the hospitality sector a licensing objective.

-The consideration of ‘spiking’ is also an update, at Paragraph 10.10 stating: “Licensing authorities may also wish to consider placing additional conditions on licences to safeguard patrons against spiking, if deemed appropriate and proportionate for a specific venue where there is evidence to justify such action (a definition of spiking can be found in para 2.7).”

 

Please see the following link to the November 2025 revised Guidance: https://assets.publishing.service.gov.uk/media/69270f872a37784b16ecf54e/Revised_guidance_issued_under_section_182_of_the_Licensing_Act_2003__November_2025_.pdf

 

Should you wish to discuss the revised Guidance with Chris, please email Chris@woodswhur.co.uk or please do reach out to your normal Woods Whur contact.

The Commission have been making concerted efforts in recent months to work with the industry, both with operators and industry lawyers, to work cooperatively and establish good practice protocols. It may not have felt like this to all operators, but the introduction of new policies, guidance and LCCP updates speak for themselves. The general direction of the Commission has very clearly been policy updates this year, however it has been made clear that this is slowing down – and enforcement will be ramping up.

 

Enforcement action

There has been a very marked increase in enforcement action recently, particularly with licence suspensions. Whilst not explicitly confirmed, the number of suspensions has shot up and the feeling at the Commission very much seems to be despair at what they call ‘repeat offenders’. If a fine has not proved fruitful in the first instance, it is now to be expected that a licence suspension is looming – and that PML reviews will also be considered.

On the back of the increased requirements for PML holders, PML reviews are also on the up. The Commission have confirmed that it remains unlikely that PML holders will be fined, however it remains a distinct possibility that PML holders may have their licence suspended or revoked.

The next sectors which can expect increased scrutiny (aside from simply smaller or independent operators…) are the motorway service AGCs and B2B operators. Motorway services have long been considered troublesome, with lack of staffing and customer interactions frequently cited – along with AML concerns. The B2B sector has not been looked at for some time now, but again the concerns are evident. B2B’s frequently work internationally, in grey and black markets alongside the UK. Any operators contracting with B2Bs should ensure their due diligence is up to date and expect to answer questions as to their relationship and whether they are satisfied it is appropriate as a licensed operator.

AGCs

The AGC sector has been heavily reviewed this year, with the catalyst being a combination of bad press, industry murmurings and a multi-operator self-exclusion scheme report. The latter revealed that a number of operators, despite stating that they had the scheme in place in their Compliance Questionnaire, were not actually part of any such scheme. Six licences were suspended immediately, many others investigated. The letter sent out at the start of the summer has been described as ‘warning shot’ to the AGC sector; failure to comply with the concerns set out will be considered aggravating factors in the future.

A similar concern that the Commission has, particularly amongst smaller operators, is a failure to properly engage with their own policies. If as an operator you have any policies that have not been reviewed and updated within the last year – dust them off and have a read. There will absolutely be revisions required after the last 12 months.

Local Authority Inspections

Another hot topic – from both the GC Industry lawyers meeting and the IOL National Training Conference – is the role of Local Authorities in the gaming industry. There is much talk about the potential to give Local Authorities greater power, but many are starting to point out that a major power already held is not being used to its full potential. With the gambling application fees that must be used for gambling matters, more and more authorities are being reminded of the need to conduct inspections of their premises. It is safe to say that anyone operating in the non-remote sphere can expect this in the not so distant future.

Black Markets

The Budget, alongside many, many other elements, allowed for £26m investment into the tackling of the gambling black market. It is not yet clear how these funds will be spent, but it is likely the focus will be on litigation and prosecution funding. The current aim, rightly or wrongly, is not to completely prevent the black market but instead to try and ensure that none can operate successfully or at scale.

The Crime and Policing Bill, currently at House of Lords committee level, is expected to bring in measures to help with IP disruption. This multi-level targeted approach is hoped to bring more success in damaging the black market- but at the moment these appear to be the only plans in the pipeline. The Commission will not be publishing any lists of black market sites, with a view that they could be seen to be ‘advertising’ them, despite this being the operational model in France (in recognition of the fact consumers can very easily find the black market sites with a simple google search – having confirmation that they are illegal and consequently lacking in customer fund protections can be useful).

 

Overall, it has been stressed (and not for the first time) that an awareness, willingness and ability to comply with the regulations is paramount to all operators. Where there is a live and present risk to consumers, the Commission will not hesitate to enforce an immediate suspension. What became very clear from the conversation surrounding AGCs was the need to get the basics right; check all LCCP requirements and review the policies and procedures in place. Now more than ever is the time to get your house in order, whether that is through an internal or external audit.

As a final note, keep an eye out for a GLA consultation next year… it sounds like we can expect it.

For any more information on any of the above topics, please email Amanda or your usual Woods Whur contact.

Last week Woods Whur attended the IOL National Training Conference in Stratford – upon – Avon. A fabulous week as always, and Paddy provided an update on the latest Gambling Reforms…. 

We have started to see some Gambling Act reforms. I have set the recent changes out in my presentation I gave at the Institute of Licensing National Conference. Please click on the link to see the presentation.

Download now

The Gambling White Paper first alluded to more regulation for prize draws back in April 2023. Prize draws represent the side of the lotteries sector cleverly skirting the need for an operating licence by removing one of the key elements of a lottery – the requirement to pay to enter.

The White Paper stated-

We will consult on the potential for regulating large scale prize draws with a view to identifying options and developing an evidence base against which their impact and the extent to which different regulatory measures would be proportionate can be properly assessed. The options will be focused on those prize draws whose scale resembles that of a large society lottery and may be confused with them.

On 21 November 2025 the Voluntary Code of Good Practice for Prize Draw Operators was published. So far it has 47 industry signatories. This is not exactly a large portion of the prize draw operators in existence-  but it is a start and does include some of the major players.

Prize draws have become increasingly lucrative in recent years, with a growing number of organisations choosing this route as opposed to the regulatory minefield of lotteries. The Code is not legally binding, but it is a marked improvement on the previous position.

The code is succinct and covers the following:

Player Protections

• Credit cards should not be accepted in excess of £250 per month per player
• Maximum monthly spend limits (or individual monthly spend limits, including £0)
• Ability for players to suspend or permanently close accounts
• Customer monitoring and interventions for vulnerabilities or suspicious activity
• Available support for those suffering from gambling harms clearly signposted
• Appropriate length of competition periods
• Instant wins must be cautious to maintain compliance with free and paid entry routes
• Care and caution given to marketing and advertising

Transparency

• Clear summary of rules and mechanisms for each prize draw to be provided
• Terms and Conditions must be adopted and enforced
• Likelihood of winning to be published where possible
• Free entry route clearly publicised and be a genuine option
• Prizes to be provided promptly
• Charitable contributions clearly outlined and expectations met

Accountability

• Processes and systems to monitor and review compliance with the code
• Third party contracts carefully managed, with due diligence undertaken where needed
• Best practice across operators should be shared
• Work with DCMS to ensure the code remains fit for purpose

For most in the lotteries sector this will feel like the bare minimum, however the codification of these basic principals will be welcomed by all.

Any prize draw organisations who choose note to comply with the Code will likely fall under scrutiny at some stage, and become part of a the ever increasing demand for the loophole to be closed and prize draws be regulated the same as a lottery. I would not be surprised to see a change in regulation of these prize draws in the not so distant future; this is simply the beginning.

For those who think it should go further, the DCMS are welcoming shared learnings or challenges on the code, or if you would like to discuss further please contact Amanda Usher or your usual Woods Whur contact.

WoodsWhur, in partnership with iGB Executive, has released a landmark report exposing the urgent compliance challenges and bold innovations reshaping the gambling and gaming industry worldwide.  
 

Operators, regulators, and safer gambling leaders convened in two exclusive roundtables, revealing: –
 
• Sanctions screening system weaknesses producing over 80% false positives, threatening operational resilience  
• The rise of fintech and cryptocurrency introducing novel AML risks amid fragmented regulatory frameworks  
• The stark contrasts in regulator approaches, from collaborative to adversarial, underscoring trust and transparency as cornerstones of success  
• Real-time player protection challenges merging advanced technology with critical human judgment, alongside pioneering suicide prevention protocols  
• Six operationally critical challenges for entering new jurisdictions — from ownership transparency to responsible gambling frameworks  

Bonus: An exclusive, in-depth interview with Iain O’Donnell, VP International Gaming Compliance at Wynn Al Marjan Island, shares pioneering insights from one of the fastest-evolving gaming markets globally.  

This report is an urgent call to action: the era of compliance as a box-ticking exercise is over. The future demands modernised, data-driven systems, open regulator collaboration, and industry-wide leadership to build safer, more sustainable growth foundations.  

DOWNLOAD the full report now to equip your organisation with the knowledge and tools needed to navigate this complex landscape with confidence and integrity.  

On 26 November 2025 the Home Office and Department for Business and Trade published the National Licensing Policy Framework. The document is 13 pages and is worth reading to get an understanding of the general direction the Govt is trying to head in to help the industry.  The Framework applies exclusively to on-trade premises, that is, premises authorised under the Licensing Act 2003 for on-sales of alcohol, regulated entertainment or late-night refreshment.

The Framework is designed to be a tool for enabling innovation and investment, not just managing risk, with the government’s target to reduce administrative costs of regulatory burdens by 25%.  It is considering making growth of the hospitality sector a statutory licensing objective, although no real detail is given as to what this would mean.

 

Strategic Steer

The Framework provides a strategic steer for licensing authorities, central government and the industry to work together in support of the following key areas:

• Business resilience and growth – licensing should be proportionate, evidence-based and responsive, giving responsible operators the freedom and flexibility to meet changing consumer expectations, diversify their offer, and invest in innovation

• Place-making and regeneration – licensing and planning policy should work in harmony to support vibrant, mixed-use areas, revitalise high streets, and unlock investment in the night-time economy. Licensing should be a tool for shaping successful places, not just managing risks

• Cultural and community life – licensing should help facilitate live music, theatre, dancing and other forms of entertainment that enrich local identity and bring people together — whether in rural villages or city centres

• Consumer choice and tourism – licensing should support a diverse range of venues and experiences that reflect the UK’s rich hospitality and leisure offer and meet the needs of both domestic and international visitors

 

Further information is set out in relation to the above points, that are of real interest:

Agent of Change: The Framework confirms that the Agent of Change principle should be applied, ensuring new developments near existing licensed premises take responsibility for mitigating impacts such as noise, rather than placing undue burdens on established venues. Authorities are encouraged to embed this principle in local licensing guidance and collaborate with planning colleagues to protect the viability of pubs, music venues, cultural spaces and events.

 

Licences Granted Under Terms Sought – Premises should be granted licences under the terms sought, with the existence of guideline hours alone not grounds to refuse. This would be a major change for many licensing authorities who seek to rely on ‘Core Hours’.

 

Licensing Decisions – should be based on clear, relevant evidence and proportionate to the risks identified. This includes both specific risks (for example, noise complaints, crime hotspots) and broader contextual risks, such as the known prevalence of violence against women and girls (VAWG) in the night-time economy. This indeed is not something new, but again can be seen as a welcome reminder to Licensing Committees.

 

CIAs: Where Cumulative Impact Assessment Policies are used, these should be evidenced based, not blanket bans. This again, would be a major change for many licensing authorities, if adopted.

 

Legal Status of the Framework

The framework is non-statutory guidance designed to support consistent, lawful and proportionate licensing. Licensing authorities must have regard to the Secretary of State’s Guidance under section 182 of the Licensing Act 2003 and to their Statements of Licensing Policy. The framework does not displace those duties, create new legal

obligations, or restrict authorities’ discretion to determine each application on its merits.

 

Conclusion

Many of the principles set out in the Framework, should really be a reminder to licensing authorities, as many points made are not new.  However, the Framework will add extra weight to apply pressure to licensing authorities to adopt a pro-industry approach.  The Framework should be seen as a positive step taken by the Govt for the industry.

 

To see the full document, please follow this link:  https://assets.publishing.service.gov.uk/media/6925dc5f22424e25e6bc31a3/national-licensing-policy-framework-for-hospitality-and-leisure-sectors.pdf

 

Should you wish to discuss the Framework with Chris, please email Chris@woodswhur.co.uk or please do reach out to your normal Woods Whur contact.

It has taken some time but we are on the verge of seeing the Gambling Act reforms for land based casinos finally about to become effective. It has been a long wait since the White Paper suggested reforms have come to practical effect.

Representing Casinos operators we have been trying to ready ourselves to make the necessary applications for them to vary their 1968 converted casino premises licences which will allow them to gain the advantage in the increased machine offer.

A reminder of what the new permissions are, and the space criteria needed to increase the number of machines can be found in the Gambling Commission legislative changes guidance and the link below will take you to it:

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/non-remote-casino-sector-legislative-changes-guidance

It hasn’t been the simplest of tasks getting from the proposed changes back in 2023 to now. Frustratingly, the run up to the introduction of the changes has been just as slow and the lack of clear and timely guidance as to the procedure seems to replicate all of the changes in legislation I have been involved in whilst I have been a licensing lawyer.

We now move into the practicalities of the process of application. The Statutory Instruments below come into effect on 22nd July 2025 which means we are about to submit a raft of applications.

https://www.legislation.gov.uk/uksi/2025/503/made
https://www.legislation.gov.uk/uksi/2009/1970/contents/made

We have had plans prepared in readiness for the applications we are about to lodge. Of course they need public notices on the premises and in the newspaper. This is a pre-consulted change to the primary legislation which could have been undertaken without the need for a variation application to premises licences… but we are where we are. The consultation has concluded and the DCMS have formed the view that these changes can happen in such a regulated and well run environment. We are sure that Responsible Authorities will check the layout plans and be content that these applications can be permitted without additional interaction. The concern is if members of the public misunderstand that these changes have already been accepted by Government ,if space permits, and there would be no potential risk to the licensing objectives being compromised. It would be very frustrating if these changes are held up due to public representations on an individual basis.

What is interesting is the number of “parked” premises licenses this will lead to across the casino sector. With the potential increase to a maximum of 80 machines per casino there will not be the need for some of the multiple premises licensed sites we currently see. It is hope that these licences will be viable to use in the future and of course operators will want to retain them for this potential future use. To that effect the licences will be mothballed for the time being until we see future changes to the regulatory framework for casinos.

It will be a busy week for us ensuring these applications are timely lodged with the Licensing Authorities.

Some Clarity on Gambling Commission Fine Levels – Finally

The Gambling Commission’s method of calculating financial penalties has always felt like a dark art, with the lack of clear guidelines and starting figures making it nearly impossible to predict or negotiate the level of a fine levied at an operator. The introduction of a seven step process, with promised transparency, will therefore be a welcomed improvement for most operators.

The levels of fines in recent years has only increased, and it shows no signs of slowing down. The latest fines include £170,000 levied at Taichi Tech Limited, for terms and conditions which ‘may’ lead to unfair outcomes for consumers, along with the typical comments on customer interaction and money laundering policies. Spreadex received a £2,000,000 fine for AML failings and SR failings; another £375,000 to Football Pools Limited, which runs 4 online sites; and £686,070 to Corbett Bookmakers, a family owned betting operator based in Wales. All within the last 5 months.

As a quick reminder – don’t forget to use these decisions to help tailor future policies. Whilst not all of them contain a great deal information as to the actual breaches, there are some helpful and practical comments – for example within the public statement for Football Pools Limited.

Moving forwards, the following will be in force:

• providing a clear and distinct seven step process the Commission will follow when assessing and imposing a financial penalty
• providing transparency on how the Commission will determine the level of seriousness of the breach, and the introduction of five levels of seriousness
• determining the starting point for the penal element of the penalty by reference to the seriousness of the breach and a percentage of Gross Gambling Yield (GGY) or equivalent income generated during the period of the breach
• making adjustments to the penalty for aggravating and mitigating factors, deterrence and early resolution.

This is welcomed clarity, particularly against a landscape of ever increasing fines. However there is some skepticism in the industry so far as to whether ‘clarity and transparency’ will yield, we will have to wait and see.

Lottery Limits remain limited, but Prize Competitions will face increased regulation

A recent statement made by Baroness Twycross, the Minister for Gambling and Heritage, contained two crucial announcements for the world of prize led fundraising.

Firstly, despite vocal opposition from a number of major lottery operators, the decision has been made to retain the current annual lottery limit of £50,000,000. The reason for this decision appears to be predominantly to protect the National Lottery, with concerns that allowing society lotteries the ability to increase their fundraising potential for good causes would negatively affect the National Lottery.

This seems somewhat counterintuitive when the Report, commissioned by the government, opens with-

The knock-on impact on good causes funding is estimated to decrease National Lottery contributions by between £5 million and £30 million, whereas it would increase contributions from PPL by between £17 million and £157 million. Overall, this would lead to a net increase in returns to good causes of between £16 million and £132 million – up by between 0.8% and 6.5% on current returns to good causes.

In 2023/2024 the National Lottery donated 20% of its income, a total of £1,572million, to its good causes. Society Lotteries raised £462million, 44% of its income, for its good causes within the same time period.
A key difference between the two is of course the tax paid by each; the National Lottery paid £937million in Lottery Duty in 2023/2024, whereas Society Lotteries do not pay Lottery Duty.

The full report can be found here – https://www.gov.uk/government/publications/research-report-assessing-the-impacts-of-changes-to-the-society-lotteries-sales-limit

A new Voluntary Code will be introduced for Prize Draws, often referred to as ‘free draws’ or ‘prize competitions’. These draws are not currently regulated under the Gambling Commission, despite the prize draw market currently being worth £1.3billion annually.

The Voluntary Code is due to be released later this year and is aiming to increase player protection, transparency of play and the accountability of the operators. This will be a very decisive time for the prize draw industry, it is clear from the statement that this is being seen as a first step towards regulation, with the potential for further regulation to come if the code does not have the desired effect.

The full report on prize draws and competitions can be found here – https://www.gov.uk/government/publications/research-report-online-prize-draws-and-competitions-market-study-assessment-of-harm-and-review-of-potential-interventions

For more information on the above please contact Amanda Usher on amanda@woodswhur.co.uk, or your usual Woods Whur contact.

The enactment of the Gambling Regulation Act 2024 signified a major development in Ireland’s approach to gambling legislation. Replacing nearly a century’s worth of fragmented, piecemeal legislation, the Act introduces a streamlined framework aimed at protecting consumers against gambling harm, consolidating compliance standards, and bringing the necessary clarity to Ireland’s gambling landscape.

Signed into law on 23 October 2024 after two years of legislative development, the Act repeals prior statutes, such as the Totalisator Act 1929 and the Betting Act 1931. It facilitates a modern regime governed by the newly established Gambling Regulatory Authority of Ireland (GRAI). Operational since March 2025, the GRAI serves as the sole licensing and regulatory body for all gambling activities across Ireland, both online and offline.

A Streamlined Licensing Regime

The Act introduced three distinct licence categories:

1. Business-to-Consumer (B2C) licences are required for any operator offering gambling services directly to Irish customers. This includes betting, lotteries and gaming, both in-person and remote.
2. Business-to-Business (B2B) licences are mandatory for suppliers offering gambling-related services or products, including software providers, hosting platforms and those providing odds.
3. Charitable and philanthropic licences are tailored to non-profit organisations conducting gambling activities for fundraising purposes. Such licences benefit from exemptions to advertising restrictions and stake limits.

The Act provides strict limitations on stakes and winnings. For example, casino games are subject to a €10 maximum stake and a €3,000 winnings cap, with separate thresholds for lotteries.
Transitional provisions under Part 10 of the Act allow existing licence holders to continue operating until their current licences expire, at which point they must reapply under the new regime. Remote operators with no physical presence in Ireland will also be required to obtain Irish licences if they are targeting Irish consumers.

Advertising & Social Responsibility
One of the Act’s most notable reforms lies in its regulation of gambling advertising. A broadcast watershed prohibits gambling advertisements between 05:30 – 21:00, and advertisements must not target children or mislead consumers with promises of financial gain. Restrictions extend to digital marketing and sponsorship as well as individual consent and opt-out mechanisms now required for electronic marketing communications. The Act also bans targeted inducements based on demographics or interests (e.g. VIP schemes aimed at sports fans), though broad promotional incentives are still permitted.

Another significant development was the establishment of a National Gambling Exclusion Register, which permits users to voluntarily self-exclude from gambling platforms, with operators required to check the register in real time or else suspend services.

Financial Duties & Enforcement

Currently, licence fees start at €10,000 and, depending on turnover, renewals can reach up to €200,000. However, the GRAI are set to prescribe these rates definitively as part of their new regulations. Licensees are also required to contribute annually to a Social Impact Fund, which finances education, training and research related to problem gambling. Eventually, the GRAI will be funded by regulated licensee fees after an initial three-year period of government funding.
Crucially, the GRAI has been granted extensive enforcement powers. Non-compliance may result in administrative fines of up to €20 million or 10% of a licensee’s annual turnover, whichever is greater, as well as the risk of criminal sanctions (including up to eight years’ imprisonment) for serious breaches such as unlawful gambling operations or allowing child participation.

Looking Ahead

As Ireland remains in the midst of reforming its gambling legislation on a phased basis under the executive powers of the GRAI, we can expect the role of this authority to evolve as it facilitates an efficient transition from the current licensing regime to new processes. The GRAI currently intends to gradually implement the guidelines for licence applications, starting with betting licences in December 2025 and progressing to gaming licences in 2026.

Whilst such regulatory details are still developing, it is clear that Ireland is committed to building a more transparent and socially responsible gambling environment. Legal professionals and stakeholders should closely monitor upcoming GRAI consultations and regulation changes to remain compliant and proactive under the new regime.

The Data (Use and Access) Act received Royal Assent on 19 June 2025. For those who have been following the Bill through Parliament, the granting of the Bill will mean significant changes for both alcohol and gambling operators. The Act, for the first time, will allow Digital ID to be used for age verification purposes, rather than the standard physical forms of ID such as a driving licence or passport. Although the Act has been granted, the ICO have reported that the Act will come into effect in phases, with different phases expected to commence at two, six and twelve months after Royal Assent.

How it will work
The Act creates a legislative foundation for Digital Verification Services (DVS). Standards, governance and oversight of digital identity services in the UK are therefore now grounded in law, ensuring they are trusted and secure. The DVS will receive a ‘Trust Mark’ similar to a ‘Kite Mark’. Similar to the GOV.UKID App, it is believed that when operators check customers’ digital ID, it will be done by way of QR codes, and so will be simple and timely for both parties.

It should be noted that accepting Digital ID is not compulsory for operators. However, in this modern day and age where everything is on a ‘smartphone’ it would be odd that operators would not embrace this and possibly alienate customers if they didn’t use digital verification. As with current age verification, it will be for the operator to ensure that they check the digital ID against the customer providing it.

Premises Licence Conditions
Operators will need to check their premises licences, as some stipulate the specific types of ID that can be accepted. Obviously, Digital ID will not be listed. Therefore, should an operator wish to accept Digital ID, they may need to submit a minor variation application or it may be dealt with in secondary legislation.

We will keep you updated as the different phases commence.

Should you want any further information on this, please email Chris@woodswhur.co.uk , or your normal Woods Whur contact.