Companies placed into special measures

Request

Could the Gambling Commission please provide a list of occasions when companies were placed into special measures by the Gambling Commission in the last three calendar years (2022, 2023, 2024) and in 2025 so far. For each entry, please provide:

• the name of the company
• the date the company entered / exited special measures
• the reason (/s) why the company was placed in special measures
• whether money was divested as part of the special measures agreement and if so, the amount divested

Response

Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).

In your email you have requested a list of occasions when companies were placed into special measures by the Gambling Commission in the last three calendar years (2022, 2023, 2024) and in 2025 so far.

The Commission is a regulatory body with licensing, compliance, and enforcement functions; through our regulatory activity, the Commission aims to protect consumers and the wider public, and to raise standards in the gambling industry. A key aim of the Commission is to ensure that licensed businesses are compliant in the shortest possible time - this protects consumers fastest and reduces the chances of crime entering businesses.

Once licensed, gambling operators are subject to ongoing compliance requirements and are subject to regulatory action should they fail to meet their licence requirements. Information collated as part of this process is used to assess whether a person or entity is fit to hold a licence.

The Commission has robust and effective processes and procedures in place which are utilised when assessing licensees. These procedures and processes are put in place to minimise the risk of an operator being allowed to continue to offer gambling facilities where they do not meet the required standards. This demonstrates to the public at large that they can have confidence in the Commission’s licence assessment processes.

One of the tools we use to ensure operators who need to make key improvements are swiftly compliant is to place them into special measures.

Any information that we can publicly disclose in relation to particular regulatory activities is made available on our website at the appropriate time so as not to disclose any information that could impact on our ability to make enquiries and conduct investigations.

Whilst the Commission has formal powers to compel the provision of information from licence holders in certain circumstances, the Commission relies heavily on the provision of information on a voluntary basis across several of the Commission’s functions (including licensing, compliance and enforcement and other aspects of its regulatory remit which include the provision of information by licensees).

The voluntary supply of information enables the Commission to obtain information:

(i) without the cost and delays occasioned by reliance on formal enforcement powers,

(ii) in circumstances where no formal powers exist or are limited in scope, and

(iii) which is pro-actively shared by operators on an open and transparent basis.

Law enforcement (Section 31)

The Gambling Commission can confirm that information is held falling within the scope of your request.

Section 31(1) of the FOIA provides that information which is not exempt information by virtue of section 30 is exempt information if its disclosure under this Act would, or would be likely to, prejudice -

(g) the exercise by any public authority of its functions for any of the purposes specified in subsection (2).

The relevant purposes referred to in subsection (2) are

a) the purpose of ascertaining whether any person has failed to comply with the law,

b) the purpose of ascertaining whether any person is responsible for any conduct which is improper,

c) the purpose of ascertaining whether circumstances which would justify regulatory action in pursuance of any enactment exist or may arise,

d) 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.

Public interest test

Along with assessing whether releasing the information requested would, or is likely to, prejudice its regulatory functions, the Commission also has a duty under FOIA to consider whether, despite that prejudice, it is in the public interest to disclose this information.

The factors the Commission has considered when applying the public interest test have been detailed below. Our view is that the public interest lies in favour of applying the exemption.

In favour of disclosure

• The Commission is a public body which is required to regulate the gambling industry in the public interest. There is therefore a public interest in members of the public having confidence the Commission is being open and honest with the information it holds so that it can be held to account.
• 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.
• Disclosure of the requested information could demonstrate to stakeholders and relevant parties how the Commission is assessing licensees and, furthermore, this disclosure may encourage stakeholders to work with us and contribute to our programme of work, increasing confidence in the Commission as a regulator and its ability to uphold the law.

In favour of maintaining the exemption

• Disclosing information which makes specific individuals or events identifiable could alert individuals involved to the fact that the Commission was/is or alternatively wasn’t/isn’t investigating a particular case and provide them with an opportunity to alter their behaviours or evade detection. This would result in making it more difficult for the Commission to achieve its aims.
• There is an expectation of confidence in much of the Commission’s work, particularly regarding the techniques used to ascertain if action is required where an operator is concerned. It is the impact on this work of the Commission which is more likely to be affected by disclosure.
• Further to this, identifying specific operators prematurely would impact on the openness of stakeholders when sharing important information with us or other law enforcement agencies. Fulfilling this request may prejudice the outcome of any future investigation by the Commission, or another body, to the detriment of the public interest.
• The amount of information released is carefully considered in order to protect the integrity of investigations and individuals or operators from being unfairly associated with unsubstantiated allegations.
• 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.
• Finally, once a formal regulatory decision has been made or there is agreement of a regulatory settlement the Commission will ordinarily publish all such decisions in full.

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.

In order to promote transparency, there is information that is publicly available on our website, via the Licence Conditions and Codes of Practice which clearly sets out the required standards with which operator licensees are expected to comply.

The Commission also publishes other information in relation to how it assesses licensees, including its Statement of principles for licensing and regulation. Therefore, to the extent that there is a public interest in transparency around the assessment of a licensee’s suitability to provide gambling facilities, this is already met by the material the Commission proactively publishes.

We consider that the public interest is better served by withholding the requested information.

Review of the decision

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