What activities are covered by the term 'manufacture, supply, install, or adapt' for gambling software?
It is an offence to manufacture supply, install, or adapt
gambling software, in the course of business without an operating
licence from the Gambling Commission.
The Gambling Commission cannot provide a definitive
interpretation of the words “manufactures, supplies, installs or
adapts”, which is a matter for the courts. However, we can
set out some examples of which activities require a gambling software
licence under the Gambling Act 2005.
You should seek your own legal advice on the specific activities
you undertake to determine whether you need a gambling software
When a licence may be needed
The following are examples of activities that we consider do
need a gambling software licence:
- Supplying or offering the same off-the-shelf gambling software
to a number of different operators
- Where a software developer makes amendments to their
off-the-shelf product for a specific gambling operator.
In these circumstances it would be expected that the software
developer retains intellectual property rights for the software
supplied to an operator.
When a licence may not be needed
The following are examples of activities that we consider are
unlikely to need a gambling software licence:
- Where an individual is contracted by a gambling operator to
contribute to software development and where that individual's work
is only part of the development process
- Where a company is sub-contracted by a gambling operator to
contribute to software development or to provide custom
In these circumstances it would be expected that the gambling
operator held intellectual property rights to the software.
Page last reviewed: July 2013