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Request date: 27 February 2026
This version was printed or saved on: 31 May 2026
Online version: https://www.gamblingcommission.gov.uk/about-us/freedomofinformation/application-by-fame-ventures-limited
The Independent Review into Football Index stated "following an unsuccessful application for the business to operate under an umbrella licence, Fame Ventures took the decision to incorporate Betindex"
Please release the following information, redacted where appropriate, to protect individual names:
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have referred to the Independent Review into Football Index which stated "following an unsuccessful application for the business to operate under an umbrella licence, Fame Ventures took the decision to incorporate Betindex."
You have requested release of the following information, redacted where appropriate, to protect individual names:
The Gambling Commission have recently published information that we are able to disclose falling within the scope of this request. Please see the following link to the published information: The application by Fame Ventures Limited.
The following exemptions apply to some of the information that we hold.
Section 40(2)
We have redacted from the attached, information relating to identifiable individuals that would constitute personal data. This includes names, email addresses, addresses, phone numbers and banking information.
The Data Protection Act 2018 requires personal data to be processed lawfully, fairly and in a transparent manner in relation to the data subject. It is the view of the Commission that disclosing the personal information within the attached documents would constitute the disclosure of personal data and would contravene this principle.
This information is therefore exempt under section 40(2) of the Freedom of Information Act 2000.
Section 31
Section 31(1)(g) exempts information whose disclosure would, or would be likely to, prejudice the exercise by any public authority of its functions for any of the purposes specified in subsection (2).
Please also note that the Information Commissioners Office (ICO) did previously uphold a complaint leading to the disclosure of due diligence carried out by the Gambling Commission on Bet Index Limited. In that specific case the decision notice did confirm that the S31 – Law Enforcement exemption was correctly engaged by the Commission. However, due to the sensitive nature of the collapse of BetIndex and the number of people who have been impacted by its closure, the public interest, although finely balanced, was found to be in favour of disclosure. The information was exempt, but the public interest in disclosure was found to outweigh the application of the exemption in this specific case.
The Licence held by Fame Ventures (Index Labs) was revoked due to Non-Payment of Fee after the collapse of BetIndex, preventing them from facilitating gambling in Great Britian. This licence was held from 27 March 2015 to 14 June 2022. This is a different scenario to the BetIndex request and as such, the public interest in disclosure will be different. Public interest test decisions are request specific and cannot simply be applied to other requests. The public interest test has to be conducted specifically to each individual request.
In relation to this request, the Commission considers the subsections below apply and therefore the information is exempt from disclosure:
Public interest test
The factors the Commission has considered when applying the public interest test have been detailed below.
Arguments in favour of disclosure:
Arguments in favour of maintaining the exemption:
Weighing the balance
The Commission acknowledges that there is a public interest in promoting the accountability and transparency of public authorities and the importance of having sufficient information in the public domain to support consumers with their choice of operator, however, disclosure of the information would be damaging to the Commission as a regulatory body which ultimately serves to protect the wider public interest.
It is important that the public are assured that the Commission is carrying out its functions in ensuring that any individuals/organisations who are involved in providing gambling facilities to the public have undergone the necessary assessments and will uphold the licencing objectives ensuring that consumers are protected.
However, there is a strong public interest in preserving the processes that the Commission has in place to assess operators’ compliance with the LCCP and identify any operators who will be unable to comply with the licensing requirements.
The public trust that the Commission has robust processes in place to assess operators so that when they use the services provided by an operator, they are confident that there has been sufficient scrutiny of that operator to ensure that they are protected. If this information were released it would undermine that confidence.
We consider that the public interest is better served by withholding this information, ensuring that consumers are protected through our processes rather than releasing information about our processes which in our view will not benefit the public as a whole.
If you are unhappy with the service you have received in relation to your Freedom of Information request you are entitled to an internal review of our decision. You should write to FOI Team, Gambling Commission, 4th floor, Victoria Square House, Victoria Square, Birmingham, B2 4BP or by reply to this email.
Please note, internal review requests should be made within 40 working days of the initial response. Requests made outside this timeframe will not be processed.
If you are not content with the outcome of our review, you may then apply directly to the Information Commissioner (ICO) for a decision. Generally, the ICO cannot make a decision unless you have already exhausted the review procedure provided by the Gambling Commission.
It should be noted that if you wish to raise a complaint with the ICO about the Commission’s handling of your request for information, then you are required to do so within six weeks of receiving your final response or last substantive contact with us.
The ICO can be contacted at: The Information Commissioner’s Office (opens in a new tab), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Information Management Team
Gambling Commission
I am writing to request an internal review of the Gambling Commission's response dated 27 March 2026 to my Freedom of Information request concerning the unsuccessful application by Fame Ventures Limited (Index Labs) to operate under an umbrella licence, as referenced in the Independent Review into the regulation of BetIndex Limited (Football Index).
I am dissatisfied with the decision to withhold the requested information specifically the application form(s), supporting documents, and all written or electronic correspondence relating to the application process under section 31(1)(g) (with subsection 31(2)(d)) of the Freedom of Information Act 2000. While I accept that personal data has been correctly withheld under section 40(2), I believe the public interest test has not been correctly applied in respect of section 31.
Your response acknowledged the strong public interest arguments in favour of disclosure, including the need for transparency and accountability in the Commission's regulatory functions. However, I submit that these arguments have been significantly under-weighted given the specific circumstances of this case:
The application is explicitly referenced in the Independent Review into the regulation of BetIndex Limited and forms part of the background to the subsequent collapse of the Football Index platform, which caused substantial financial harm to thousands of consumers.
The Commission has previously accepted (and the Information Commissioner has upheld in related cases) that the section 31 exemption was engaged in relation to due diligence on BetIndex Limited, yet the public interest in disclosure outweighed the exemption because of the scale of consumer harm and the need for transparency around regulatory decision-making.
The licence held by Fame Ventures Limited (Index Labs) was revoked on 14 June 2022 due to non-payment of fees, and the operator has been inactive for several years. Any prejudice to the Commission's future regulatory functions from disclosure of this historical material is therefore minimal or non-existent.
There is a clear and compelling public interest in understanding precisely how the Commission assessed the applicant's fitness and competence at the application stage, why the umbrella licence application was unsuccessful, and what information was provided by the applicant. Full transparency on these matters would materially assist public confidence in the Commission's processes following a high-profile regulatory failure that has already been the subject of an independent review.
I refer to Freedom of Information Request 202500311, which was also subject to internal review and resulted in the release of some documentation despite section 31(1)(g) being engaged. In light of the above, I ask that you carry out a fresh public interest balancing exercise, giving appropriate weight to the significant public interest factors identified. I believe the arguments for maintaining the exemption do not outweigh the very strong public interest in disclosure in this specific case.
I am writing to you further to your Freedom of Information request dated 27/02/206 which we responded to on 27/03/2023, and your subsequent request for an internal review received on 30/03/2026.
We have now concluded our review, and our findings are detailed below.
This internal review was conducted by someone who was not involved in the processing of your original request.
In your initial email you requested the following information:
The Independent Review into Football Index stated "following an unsuccessful application for the business to operate under an umbrella licence, Fame Ventures took the decision to incorporate Betindex"
Please release the following information, redacted where appropriate, to protect individual names:
In our initial response we advised that the Gambling Commission had recently published information that we are able to disclose falling within the scope of this request. Please see the following link to the published information: The application by Fame Ventures Limited. We had redacted information relating to identifiable individuals that would constitute personal data. This includes names, email addresses, addresses, phone numbers and banking information under section 40(2) of the FOIA.
Further to this we were able to confirm that some further information in the scope of your request was held by the Gambling Commission. However, this information was considered to be exempt under section 31(1)(g) of the FOIA.
In your request for an internal review you have raised concerns with the application of section 31.
Internal Review
After reviewing your request and our response, I uphold our original decision to engage the section 31(1)g exemption. My considerations for this decision are detailed below.
The Commission is a regulatory body with licensing, compliance, and enforcement functions and through our regulatory activity, the Commission aims to protect consumers and the wider public, and to raise standards in the gambling industry.
Gambling operators are required to hold a licence from the Commission in order to offer facilities for gambling to customers located in Great Britain. The Commission goes through a licence application process as part of this and makes an assessment of suitability against criteria set out in the Act. Part 5 of the Gambling Act 2005 details the Commission’s statutory functions in relation to the licensing requirements. The Licence conditions and codes of practice (LCCP) set out the requirements all licensees must meet in order to hold a Gambling Commission licence.
Licence Conditions and Codes of Practice
When we receive licence applications an assessment is made on whether a business will uphold the licensing objectives and also the suitability of the applicant to carry out the activities that the licence allows. As part of this assessment the Commission will request the following evidence to support the application and the individuals who are relevant to the application, such as:
Details with regards to how we process a licence application can be found on our website:
These checks are carried out to ensure that we meet our obligations under the Act and our Statement of Principles.
Information collated as part of this process is used to assess whether a person or entity is fit to hold a licence
Section 31(1)(g) exempts information whose disclosure would, or would be likely to, prejudice the exercise by any public authority of its functions for any of the purposes specified in subsection (2). I consider that subsection 31(2)(d), which refers to the purpose of ascertaining a person’s fitness or competence in relation to the management of bodies corporate or in relation to any profession or other activity which he is, or seeks to become, authorised to carry on, is engaged.
I recognise that it is important that the public are assured that the Commission is carrying out its functions in ensuring that any individuals or organisations who are or were involved in providing gambling facilities to the public have undergone the necessary assessments and will uphold the licencing objectives ensuring that consumers are protected.
However, there is an expectation of confidence in much of the Commission’s work, particularly when discussing areas of a potential licensee’s compliance with the LCCP. It is the impact on this work of the Commission which is more likely to be affected by disclosure.
The amount of information the Commission can release relating to our specific discussions about a potential licensee could lead to potentially non-compliant licensees altering their behaviour specifically to meet the Commission’s standards purely for assessment purposes. This in turn may impact on the Commission’s function of ascertaining a gambling operator’s fitness to carry out gambling activities.
Further to this, the Commission does not disclose information submitted by individual operators as the Commission relies on their submissions at the application, assessment and review stages of our licensing processes. Ultimately, disclosure of information at the level of detail you have requested would be likely to impact on the voluntary supply of information from other operators.
The Commission requires licensees to make full and candid submissions throughout the life of the license. We provide assurance that we will respect the confidentiality of information that we are provided with. Establishing trust with operators is key to having open and frank exchanges and this, in turn, will make operators more inclined to provide sensitive information on the basis it is trusted to be kept in confidence.
The Commission also takes the view that disclosure is likely to reduce the overall standards in the gambling industry because releasing this information would undermine our relationship with operators as the information that they provide to us is done so on the understanding that this will not be released into the public domain. If this information was disclosed, it would damage the relationship that we have formed with operators which would result in them being less likely to share information with us in the future which would undermine our regulatory functions and, as a consequence, have a detrimental impact on the wider public.
Disclosure of this information would also undermine the Commission's ability to uphold the licensing objectives which would impact on the trust and confidence of the public in it as a regulator. Further, disclosure of the requested information would prejudice the outcome of future assessments by the Commission by exposing assessment techniques and practices to the detriment of the public interest.
There is a strong public interest in preserving the processes that the Commission has in place to assess potential operators’ ability to comply with the LCCP and identify any operators who will be unable to comply with the licensing requirements. The public trust that the Commission has robust processes in place to assess licence applicants so that when they use the services provided by an operator, they are confident that there has been sufficient scrutiny of that operator to ensure that they are protected. If this information were released it would undermine that confidence.
It should be noted that the Information Commissioners Office (ICO) did previously uphold a complaint leading to the disclosure of due diligence carried out by the Gambling Commission on Bet Index Limited.
In that specific case the decision notice did confirm that the section 31 exemption was correctly engaged by the Commission. However, due to the sensitive nature of the collapse of BetIndex and the number of people who have been impacted by its closure, the public interest, although finely balanced, was found to be in favour of disclosure. The information was exempt, but the public interest in disclosure was found to outweigh the application of the exemption in this specific case.
The Licence held by Fame Ventures (Index Labs) was revoked due to Non-Payment of Fee after the collapse of BetIndex, preventing them from facilitating gambling in Great Britian. This licence was held from 27 March 2015 to 14 June 2022. This is a different scenario to the BetIndex request and as such, the public interest in disclosure will be different. Public interest test decisions are request specific and cannot simply be applied to other requests. The public interest test has to be conducted specifically to each individual request.
As such, I still consider that the public interest is better served by withholding this information, ensuring that consumers are protected through our processes rather than releasing information which in our view will not benefit the public.
If you are not content with the outcome of your review, you may apply directly to the Information Commissioner (ICO) for a decision. Generally, the ICO cannot make a decision unless you have exhausted the complaints procedure provided by the Gambling Commission. The ICO can be contacted at www.ico.gov.uk.