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Gambling Commission Consultation on proposed changes to Licence Conditions and Codes of Practice (LCCP), Remote Gambling and Software Technical Standards (RTS), and arrangements for Regulatory Panels Published Date: 27/07/2023


The consultation will close on 18th October 2023 (opened 26 July 2023)

The Gambling Commission is consulting on a series of proposed changes to the requirements on gambling businesses, through the Licence Conditions and Codes of Practice (LCCP) and Remote Gambling and Software Technical Standards (RTS).   They are also consulting on proposed changes to arrangements for Regulatory Panels.

All stakeholders, including consumers, gambling operators and members of the public are invited to share their views on these proposals.

Why your views matter

In April 2023 the government published its white paper High stakes: gambling reform for the digital age, which set out a plan for reform of gambling regulation following the review of the Gambling Act 2005.

This consultation package includes the first set of proposed changes to the regulatory framework required to implement the Gambling Commission’s commitments as part of the review.

The consultation

The following four areas form the first set of proposed changes to the regulatory framework following on from the Gambling Act Review:

Improving consumer choice on direct marketing

The Commission want to empower customers by giving them more control over the direct gambling marketing they wish to receive.  They are consulting on introducing a new LCCP requirement to provide customers with options to opt-in to the product type they are interested in and the channels through which they wish to receive marketing.

Strengthening age verification in premises

The Commission are consulting on removing the current exemption from carrying out age verification test purchasing for the smallest gambling premises and changing the relevant ordinary code (good practice) elements of the LCCP to say that licensees should have procedures that require their staff to check the age of any customer who appears to be under 25, rather than under 21.

They are also seeking views on how licensees make sure they have effective age verification procedures where their premises may not be directly supervised. 

Remote game design

The Commission are consulting on a series of changes to existing Remote Gambling and Software Technical Standards and new requirements, in order to reduce the speed and intensity on online products while making them fairer and increasing consumer understanding about game play.  

They are proposing:

  • a 5s min game speed which targets the fastest versions of non-slots products.
  • removing features which can speed up play to reduce the harm experienced by consumers who are gambling particularly quickly or intensely.
  • removing features which may mislead consumers or create dissociation from awareness of play.
  • a technical update to RTS security requirements to reflect the 2022 update to ISO 27001.

Remote gambling: financial vulnerability and financial risk

The Commission are consulting on new obligations on operators to conduct checks to understand if a customer’s gambling is likely to be harmful in the context of their financial circumstances, in the form of financial vulnerability checks and financial risk assessments.

They are proposing to include the new codes for these measures in the Customer Interaction section of LCCP, because while they are proposing new specific requirements on operators in relation to financial risk, operators should use the information obtained within their overall approach of identifying risk of harm and taking action to prevent gambling harm. 


The Commission are also consulting on the following areas:

Extending Personal Management Licences requirements

Gambling licensees must ensure that an employee holds a personal management licence (PML) if they are responsible for one of the ‘specified management offices’ defined in Licence Condition 1.2.1.   The Commission are consulting on changes to this licence condition which would both clarify and extend the roles captured by this definition.

Changes to Regulatory Panels

The Commission are consulting on a number of changes to the composition and decision-making processes of the Commission’s Regulatory Panels.

The consultation will close on 18th October 2023 (opened 26 July 2023)

Source / more information

IoL Response

The IoL will be responding to the consultation. If you would like to contribute to the IoL response, please contact the team via email to

IoL Consultation Panels

We are working with small groups of IoL members on all relevant consultations.  These consultation panels allow us to have discussions on consultation proposals and to develop an IoL response hearing from a sample of practitioners.

In some cases, we will still conduct member surveys, but if anyone wants to feed into the IoL response on any open consultation, please contact Sue Nelson via