You will all be aware, the Football World Cup 2026 started yesterday in Mexico at the Estadio Azteca Stadium. It is an exciting time for all, especially for those in the licensed trade!

The Government has extended hours due to the time differences across the four different time zones. The extensions only apply for premises in England and Wales.  For Scotland, it is for individual Licensing Boards to determine.

When a home nation (England or Scotland) is playing, there will be a national extension to licensing hours:

• from 11:00pm to 1:00am for kick-offs from 5:00pm up to 9:00pm
• from 11:00pm to 2:00am for kick-offs after 9:00pm up to 10:00pm

but only for the following matches:

• round of 32
• round of 16
• quarter-finals
• semi-finals
• bronze medal match
• final

Importantly, this national extension will allow licensed premises in England and Wales that are already licensed to 11:00pm, and subject to their existing licence conditions, to remain open for the sale and supply of alcohol for consumption on the premises and provision of late-night refreshment.

The BBPA have produce a handy guidance note for those in the trade, please see link https://admin.beerandpub.com/media/elcluv1v/world-cup-2026-guidance.pdf

It is not too late for TENs (if required)

Should they be required, hopefully they will already be in place, but you can apply for TENs to extend your trading hours.

It is too late to apply for the first England game, however, you could still apply for the following key matches:

• 1 X LATE TEN for 23 June and 27 June 2026 (England Games)
• 1 X TEN for Quarter and Semi Finals on 11/12 July and 14/15 July 2026
• 1 X TEN for the Final on 19 July 2026

Or variations of this.  Please see Heidi’s article on TENs for further information on these notices.

Should you have any questions, please do contact Chris on chris@woodswhur.co.uk or your normal Woods Whur contact.

Hopefully, if required, you will have your temporary event notices now in place…

Temporary Event Notices (TENs) are an important feature of the licensing regime under the Licensing Act 2003. They provide a flexible and relatively straightforward process for individuals and premises to carry out licensable activities on a temporary basis without the need to obtain a full premises licence.

The TEN system was designed as a light-touch process to enable small-scale or one off events to take place while still promoting the four licensing objectives:

• The prevention of crime and disorder
• Public safety
• The prevention of public nuisance
• The protection of children from harm

TENs can be used for all a number of different events such as local community events, charity fundraisers, weddings, private parties, sporting celebrations, food festivals and temporary bars.

What is a Temporary Event Notice?

A Temporary Event Notice is a notification given to a local licensing authority by an individual who wishes to carry out licensable activities for a limited period.

Licensable activities include:

• The sale of alcohol by retail
• The supply of alcohol by or on behalf of a club
• The provision of regulated entertainment, such as live music, recorded music or dancing
• The provision of late-night refreshment between 11pm and 5am

A TEN may be used by a premises that does not have the benefit of a premises licence or where an event falls outside the scope of an existing premises licence.

A TEN can only be used where:

• No more than 499 people are present at any one time, including staff and performers.
• The event lasts for no more than 168 hours (seven consecutive days).

If either of these limits are exceeded, a premises licence or other authorisation may be required instead.

Who can apply?

Any individual aged 18 years or over may submit a Temporary Event Notice.

The applicant, known as the “premises user”, does not need to hold a personal licence. A non-personal licence holder may submit up to five TENs per year, however, personal licence holders are permitted to apply for up to fifty TENs each calendar year.

The Process

There are two types of Temporary Event Notice, a standard TEN which must be submitted at least ten clear working days before the event. This excludes the day the application is received and the day of the event itself and a late TEN, which may be submitted between five and nine clear working days before the event.

While Late TENs provide flexibility for organisers, they do carry greater risk. If either the local Police Licensing Team or Environmental Health Authority object to a Late TEN, the notice automatically fails and the event cannot proceed under that notice.

Once a TEN has been submitted, the Police and Environmental Health Authority have an opportunity to review the application. Objections can only be made where the responsible authority believes the event may undermine one or more of the licensing objectives.

Where an objection is received for a standard TEN, the Licensing Authority may hold a hearing to determine whether the event can go ahead, require conditions to be added to the notice or refuse the TEN.

Unlike a premises licence application, a TEN is not “granted” by the licensing authority. Instead, it is deemed accepted unless an objection is made.

Practical Uses of Temporary Event Notices

TENs are widely used to facilitate a variety of temporary activities.

Examples include:

• A village hall hosting a fundraising beer festival.
• A community centre holding a wedding reception with alcohol sales.
• A licensed premises wishing to extend its hours for a special or sporting event.
• A food festival offering alcohol sales from temporary bars.
• A charity event providing live entertainment and refreshments.
• A seasonal event such as a Christmas market, summer festival or New Years Eve.

The flexibility of the TEN process allows organisers to respond quickly to opportunities while ensuring appropriate safeguards remain in place.

Benefits of a TEN

The Temporary Event Notice process offers several advantages:

• Reduces the administrative burden compared with a full premises licence application.
• Significantly lower application costs (£21).
• Greater flexibility for small businesses and community groups.
• The ability to test new events before committing to a permanent licence or change in an existing licence.

The system has become an essential tool for event organisers, particularly where events are infrequent or temporary in nature.

Temporary Event Notices play a vital role within the licensing framework. They provide a practical and proportionate means of authorising licensable activities while maintaining safeguards to protect the surrounding local area, businesses residents.

By balancing flexibility with regulation, the TEN regime enables a wide range of events to take place safely, with the necessary permissions. For event organisers, understanding the scope, limitations and requirements of a Temporary Event Notice is essential to ensuring successful and compliant events.

There is an array of regulatory responsibilities attaching to all gambling premises, whether a casino, betting shop, adult gaming centre, bingo hall or family entertainment centre. Local Authorities play an essential role in making sure there is compliance with these regulatory responsibilities, and many already have a robust inspection agenda.

Whilst each type of premises has slightly different requirements, and it should be immediately obviously what type of premises they are the moment you walk in, there are a number of elements true to all gambling establishments. The Gambling Commission have a toolkit and guide – including a handy form for each premises- which is fantastic place to start. But to go beyond a form, here are our top 5 things to look out for….

1. Signage

All gambling premises have to display a number of documents within their premises and checking that these are up is a great first step to an inspection.

The Premises Licence Summary should be clearly displayed, and you can immediately check whether the premises are complying with any licence conditions which have been attached to their licence.

Underage signage, including No Under 18s and any challenge 25 posters, should all be very clearly visible and should be acting as a deterrent by the main entrance.

Problem gambling signposting is vital in all premises, the right information should be available to customers in a discreet fashion. Problem Gambling Leaflets should be capable of being picked up and taken away, with information on how to seek help prominently available.

Depending on the type of establishment, the rules for each type of gambling on offer should also be readily available, along with any Terms and Conditions.

2. Staff Awareness

Speaking to members of staff is a really good way to get a feel for the overall professionalism and compliance of a venue. Do they seem confident in their role and their knowledge? Can they talk you through their policies and procedures?

Watching what staff do when a customer walks in is a great opportunity to see them in action; how they observe and interact with customers to make sure they are playing in a safe and responsible manner. You can also ask staff various questions to test their knowledge, ask to see different documents and make sure they know who to call or what to do if there is a problem.

A very important question to ask – when were the staff last trained? What were they trained on and did they find it useful? Staff training is one of the most valuable aspects of any gambling premises.

3. Key Documentation 

We’ve already covered the key documents which need to be displayed in the premises, but there are also a number of other documents which should be on hand within the venue that you can ask to see.

The Full Premises Licence, Summary and Plan should be on site, and should be the most up to date version. The plan should match the layout, and it is important to check that gambling is only taking place within the designated area. The Local Area Risk Assessment is probably the second most important document. This should set out the local risks and any mitigating factors deployed by the operator, the first thing you should check is when it was last updated! The LARA should take into account all local risks and evaluate them in relation to the premises. Have they missed any?

Various policies and procedures, including Customer Interaction, Anti-Money Laundering and Customer complaints, should all be readily available. Staff should all know where they are – and more importantly know which one to look in if they encounter any problems.

Record keeping is another vital part of gambling premises, from under 18s attempting access to customer interactions, these should be accurate and up to date. The records might be manual or electronic, but either way the staff should be able to show you where they are and how to complete them. There should also be a record of training logs in the premises, are all members of staff up to date on their training?

4. Licensing Objectives

The three licensing objectives should be a constant mantra for any gambling premises:

The protection of children and vulnerable persons should be achieved through staff training, clear policies and procedures, careful shop design and customer monitoring. Does the operator have robust underage gambling prevention measures in place? How have their last few age verification tests gone, any failures? Arey they effectively interacting with customers and are they able to identify and protect vulnerable customers? Is there a proper self-exclusion scheme in place?

The prevention of crime and disorder is borne out through policies and staff training. Do they have an AML Policy and risk assessment? Is there anything suspicious in the premises, do you know of any links to known crime or disorder in the area? Have they have any issues involving the police?

Keeping gambling fair and open – are the machines all properly maintained? Do they have the right number and category of machines? Is the customer complaints procedure available and easy to follow? Do they have correct ADR provisions? Do the machines display everything they should (category, RTP, problem gambling information etc)? Are there any reward schemes at play?

All operators should be able to answer these questions to your satisfaction, with the licensing objectives underpinning every aspect of the operation.

5. Collaboration and Transparency

And lastly, responsible operators will welcome a Local Authority Officer into their premises with open arms. They want you to come and see what a good job they are doing, they are proud of their premises and proud of their staff.

They are also normally very aware that it is their specialty, but it might not be yours. Questions are welcome and they will gladly walk you through any areas of their operation which might be new to you. It should be a positive and collaborative experience, and if there are any areas you think they need to improve (or where they are not compliant!) the operator should be following up to make sure those changes and quickly and efficiently implemented.

Any operators who resist inspections, are difficult to work with or refuse to cooperate are likely to be treated with suspicion. Keeping a good, open relationship between local authorities and operators is a vital part of the gambling industry and it is very much a two way street.

This is by no means an exhaustive list, and for further information or guidance please do contact amanda@woodswhur.co.uk or your usual Woods Whur contact.

Lotteries tend to fall into three categories:

1. Unregulated prize competitions or Free Draws
2. Local Authority Registered Small Society Lotteries
3. Gambling Commission Licensed Large Society Lotteries

We regularly handle all three types of lotteries, however for National Licensing Week we wanted to provide a reminder of what often feels like the least common type; the Local Authority Registered lotteries.

As a quick recap, a lottery must have payment to enter and prizes which are awarded solely by chance. Take away any of these elements (for example payment to enter) and it is no longer  a lottery, and is likely to be a free draw or prize competition. A lottery which exceeds £250,000 in proceeds in a year, or £20,000 of tickets in a single draw, requires a Gambling Commission operating licence. Following the same path as all other forms of gambling, these operating licences can be expensive, hard to obtain and difficult to maintain (although of course still doable!).

A Local Authority Registered lottery, or small society lottery, provides a neat halfway house. Any lotteries which are below the £250,000 threshold simply require registration. A small society lottery must still be promoted by a non-commercial society for charitable purposes- or any other purpose not for private gain – and a minimum of 20% of proceeds must go to this good cause (with up to 80% able to be claimed for prizes and expenses).

The registration itself must be with the society’s Local Authority, and is normally a simple form with a fee of £40. An application might be refused if the society has previously held a GC licence which was refused or revoked, and any individuals associated with the running of the lottery must declare any relevant convictions. The lottery must be registered for its lifespan and there is normally an annual fee of £20.

There is a common misconception that this is where the role of the Local Authority ends. However, lottery returns must be submitted to the authority within three months of the date of the lottery draw, be signed by two members of the society, and will usually include:

• Dates of tickets sales and draws
  • Arrangement for prizes (rollovers, donations)
  • Proceeds
    • Amounts applied to expenses (promoters etc)
    • Amounts applied to the good cause
    • Amount paid for prizes
  • Any promoters (or change in promoter)

Furthermore, the society must retain written records of all draws, including unsold tickets, must be retained and can be inspected. The authority will inspect the returns, may request other documents to inspect too, and can revoke the licence if they see fit. It is important for local authorities to understand and review returns as they are submitted (and to make sure they were submitted in time).

One or more individuals in the society must ensure they are responsible for the compliance of the lottery, they must be open and honest with the local authority, and will be the ones named on the lottery tickets and signing the returns. They are also the ones who should be making sure that clear policies and procedures are in place to protect the lottery, the society and its customers – from both potential money laundering and the harms of gambling. Any training should be conducted by this individual – and they are the ones who would be called to answer questions from the authority.

A small society lottery, whilst not quite as hotly regulated as a GC operating licence, still has a number of rules it must follow…

The Tickets

• The ticket price must be the same for all tickets and all tickets must be paid for before entry to the draw is allowed. Caution and consideration should be given to payment methods
• Tickets must only be sold to individuals over 16
• Tickets must show the name of the society, the price, the organiser and the draw date
• If it is not a fixed date for the draw then the ticket must have information about how the date will be decided
• Tickets can be sold door to door, online, over the telephone or face to face but they cannot be sold in the street
• Draws must take place when advertised, and results should be communicated to players using the method by which they entered, or the method which they choose

The Prizes

• No single prize may be worth more than £25,000, even if it is donated
• Prizes can be rolled over another lottery run by your society, but that prize cannot be worth more than £25,000

Overall small society lotteries can be a great way to get started, but charities must be aware of the regulatory responsibilities that come with it.

Lots of small societies use External Lottery Managers to help run their lotteries, or feel free to reach out to amanda@woodswhur.co.uk or your usual Woods Whur contact for any help setting up or running a lottery.

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.