The application by Fame Ventures Limited
Request
Under the Freedom of Information Act 2000, I request the following information relating to the application by Fame Ventures Limited (Index Labs) for licences applied for on 8 January 2015 and granted on 27 March 2015:
- All copies of the application form(s).
- All supporting documents submitted with the application.
- Any written or electronic correspondence between the Gambling Commission
- and the applicant (or their representatives) relating to the application process.
For reference, similar information was disclosed for Betindex Limited (Licence Number 2665) following an ICO-upheld complaint. Identical or similar requests for Fame Ventures have been made previously on 14 October 2021, 2 January 2022, and 6 June 2023, but were declined citing exemptions under Sections 31 and 40 of the FOIA.
Public Interest Justification There is significant public interest in disclosing this historical information, given Fame Ventures' role as the 100% parent company of Betindex Limited, which operated the Football Index platform that collapsed in 2021, affecting thousands of consumers. Disclosure would promote transparency in the
Commission's licensing decisions, particularly for novel products like Football Index, and allow scrutiny of whether robust procedures were applied. This aligns with the Commission's stated commitment to accountability in its 2021-2024 Corporate Strategy and post-Betindex reforms.
Supporting evidence includes:
Chapter 5, Paragraph 24 of the Independent Review by Malcolm Sheehan KC (September 2021), which notes an internal email stating "the operational model for Betindex had already been approved under the Fame Ventures application and was therefore not significantly re-examined."
Paragraph 26 of the Sheehan Report, confirming SMP Partners' reliance on the Fame Ventures business plan.
The "Betindex Assessment 2015" file (02.210316-AC_1), which repeatedly references the Fame Ventures application.
Page 31 of the "Lessons from Betindex" report (September 2021, released via FOI on 6 November 2025), stating that "having granted the license for Fame Ventures it was felt that there was little scope to deny the license shortly afterwards."
These references confirm the need for the Fame Ventures documents to enable a full comparison and public understanding of the licensing process.
Addressing Potential Exemptions I acknowledge that Fame Ventures is no longer an active licensee. Given the 11 years since the 2015 grant, I request confirmation that the following exemptions do not apply, or a detailed public interest balancing test if they are invoked:
Section 31 (Law Enforcement): Disclosure of 2015-era assessments would not prejudice current regulatory functions, as licensing techniques have evolved (e.g., post-2021 enhancements noted in the Commission's annual reports). Per ICO guidance (e.g., Decision Notice FER0896742), historical data loses prejudicial impact over time, and no subsections of 31(2) appear relevant here.
The unique circumstances of Fame Ventures (superseded by Betindex for a derivative product, as confirmed by Leading Counsel for the Commission and FCA) further reduce any risk to operator relationships or enforcement.
Section 40 (Personal Data): Any personal information can be redacted, as was done in the Betindex disclosure, ensuring compliance with data protection principles.
If full disclosure is not possible, please provide redacted versions or partial releases.
Please also confirm post-licence measures in place in 2015 to prevent platform launch before the independent website review (e.g., the Website Review Letter for Account ID 43061, issued 12 August 2015).
Response
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have requested information relating to the application by Fame Ventures Limited (Index Labs) for licences applied for on 8 January 2015 and granted on 27 March 2015:
- All copies of the application form(s).
- All supporting documents submitted with the application.
- Any written or electronic correspondence between the Gambling Commission and the applicant (or their representatives) relating to the application process.
Firstly, it should be noted that the Licence held by Fame Ventures (Index Labs) was revoked due to Non-Payment of Fee. This licence was held from 27 March 2015 to 14 June 2022.
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:
- the identity of the individuals,
- financial and other circumstances including resources available to carry out licensed activities
- integrity – honesty and trustworthiness
- competence – experience, expertise, qualifications and history
- criminality – criminal record
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.
https://www.gamblingcommission.gov.uk/policy/statement-of-principles-for-licensing-and-regulation
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.
I can confirm that information falling within the scope of your request is held. However, the Commission is of the view that information in relation to specific operators (even once their licence has lapsed), other than what is made publicly available, is exempt from disclosure under section 31(1)g of the FOIA (‘law enforcement’) and therefore will not be released.
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 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.
As previously mentioned, 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 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.
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).
The Commission considers the subsections below apply and therefore the information is exempt from disclosure:
- Subsection 31(2)(d) 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 Public interest test
The factors the Commission has considered when applying the public interest test have been detailed below.
Arguments 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 or 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.
Arguments in favour of maintaining the exemption:
- The Commission has robust and effective processes and procedures in place which are utilised when assessing existing licensees. These procedures and processes have been put in place to minimise the risk of an operator continuing to provide gambling services where they do not meet the required standards. This demonstrates to the public at large that they can have confidence in the Commission’s compliance assessment processes.
- There is an expectation of confidence in much of the Commission’s work, particularly when discussing areas of a 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 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.
- 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.
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.
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