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The milestones we plan to complete within the Interim Business Plan 2022 to 2023.
Published: 7 April 2022
Last updated: 3 April 2023
This version was printed or saved on: 29 April 2024
Online version: https://www.gamblingcommission.gov.uk/about-us/guide/interim-business-plan-2022-to-2023
Overview: ## Foreword from Andrew Rhodes, Chief Executive The Gambling Commission was established in 2007 to regulate the gambling market. Over the last 15 years, the sector has changed extensively. It is now generating £14 billion in Gross Gambling Yield (GGY) annually and has an online sector that is larger than bricks and mortar, premises-based gambling. Whilst the Commission has been adapting to these changes, our three statutory objectives - to keep crime out of gambling, ensure that gambling is conducted fairly and openly and protecting people from gambling related harms - remain as important now as they did when we were created.
In 2020 Government announced its Gambling Act Review and as a statutory advisor to Government we continue to input to that review and prepare for any actions required of us that come out of it. Since I joined in June 2021, we have also welcomed a new Chair, Marcus Boyle, and our new leadership team has already shaped and refocussed our priorities for 2022 to 2023.
This business plan reflects the reality of needing to deliver our existing programme of work, as well as adapting to the relevant recommendations and initiatives set out in the Government’s White Paper, resulting from the Gambling Act Review, as well as several emerging areas which will present themselves during the year. As a result, the Commission will deliver everything set out in this plan, but the plan does not represent everything we will deliver in the coming year and beyond. As we assimilate the outcomes of the White Paper and further develop our plans in relation to other areas, such as the use of technology, research and statistics and our regulatory approach, our plans will naturally need to adapt and be augmented.
We are on track to deliver a nationally significant programme, the fourth National Lottery Competition. The Commission has delivered a fair, open and robust competition and have announced the Preferred Applicant to operate the next National Lottery licence. In 2022 to 2023 the Programme commences its Implementation Period of 22 months with the new licence scheduled to begin in February 2024 with a 10-year licence term ending January 2034. We are working with all parties to ensure a smooth transition from the third to the fourth licence.
Overall, I am incredibly proud of the work the Commission has achieved in 2021 to 2022, but also acknowledge there is some positive change still required. In some areas we have had some hard lessons to learn, from which we have already made significant changes.
As the regulator of gambling activity in Great Britain, our mission is to make gambling fairer and safer. We do that by licensing and regulating in the public interest and providing advice and guidance.
Our vision is for a fairer and safer gambling market where all consumers and the interests of the wider public are protected.
To achieve this we have five strategic objectives:
Read more details about this objective in our corporate strategy.
Read more details about this objective in our corporate strategy.
Read more details about this objective in our corporate strategy.
Read more details about this objective in our corporate strategy.
Read more details about this objective in our corporate strategy.
This Interim Business Plan and Budget sets out the plans and resources for the present circumstances. During the coming year, we expect the Gambling Act Review White Paper to identify a range of additional work and priorities that we will need to build into our plan and budget for the remainder of the year and beyond. Therefore, we plan to revisit the detailed Business Plan and Budget at the mid-year. At the same time, we will incorporate any additional activities arising from the ongoing strategic review being undertaken by our Board through a series of sprints and the data projects arising from our scoping activity.
In the next year we will focus on five key priorities:
Completing the competition for the fourth National Lottery licence and ensuring a successful transition from the current licence, which expires in January 2024.
Responding to the Government’s White Paper on the Gambling Act (due in the Spring), and working with the Department for Digital, Culture, Media and Sport (DCMS) to develop and implement changes to regulation of the gambling sector.
Continuing to develop Licensing, Compliance, Enforcement and Intelligence activities effectively, ensuring that gambling is conducted in a fair and open way, preventing gambling being a source of crime and disorder, and protecting children and vulnerable people from being harmed by gambling.
Implementing the new Economic Crime Levy, taking on the function of collecting the levy from April 2023 with liability commencing April 2022.
Managing the accounts of over 2,600 operators and determining the applications which generate the Gambling Commission’s income.
Carrying out 30 full compliance assessments, alongside further activity including targeted assessments, website reviews, security audits and review of personal licences.
Conducting regulatory and criminal investigations, carrying out intelligence-led disruption and enforcement initiatives relating to illegal gambling.
Managing large volumes of international request for help from overseas regulators and stakeholders across government.
Supporting several major sporting tournaments including the Women’s Euro 2022, the Commonwealth Games and the Rugby World Cup.
Providing specialist input into operational and casework matters, undertaking responsibilities as statutory supervisor duties for the regulated sector to prevent Money Laundering and Terrorist Financing.
Increasing the effective use of data by the Commission and the gambling industry to provide the information and insight necessary to meet these regulatory goals.
Continuously improving our organisational effectiveness by ensuring we have the necessary resources, skills, technology and culture to make the Commission a great place to work.
Supporting the Executive and Board to ensure a clear strategy is in place and that our work fits the strategy and is coordinated.
Providing insight to the business on how the supply (industry) and demand (consumer) sides of the gambling market work and the risks to the public.
Giving strategic communications support to the Commission and operating a high quality Contact Centre.
Offering secretariat support to the Board, Committees, advisory groups, and internal governance groups to ensure high quality assurance and decision-making.
Advising on public law, prosecutions and regulatory law, contracts and employment law across all areas of the Commission’s activities.
Providing timely, accurate and insightful financial and management information within the Commission and to its external stakeholders.
Keeping all our digital services up to date and compliant with current legislation and contributing to work to improve regulatory data collection.
Providing professional and considered advice and guidance on all people related matters, including policy.
Supporting organisational understanding and informed decision making.
Since its launch in 1994, the National Lottery has raised more than £43 billion for 660,000 good causes, transforming lives through its contribution to the arts, sport, heritage, and communities up and down the United Kingdom (UK).
The Gambling Commission is the UK’s independent, statutory body responsible for awarding the licence to run the National Lottery. In relation to the National Lottery, the Secretary of State for Department for Digital, Culture, Media and Sport (DCMS) and the Commission share three Statutory Duties:
The third National Lottery licence is due to expire on 31 January 2024 and in March 2022, the Commission named Allwyn Entertainment UK (“Allwyn”) as Preferred Applicant for the fourth National Lottery licence.
We will continue to monitor the current National Lottery licence holder’s performance, applying increasing focus on the end-of-licence management and transition from the third to the fourth National Lottery licence.
We also expect to continue to receive and assess marketing investment proposals until the end of the third licence. Finally, we will progress our work relating to the licence extension, considering and agreeing the associated incremental costs with the operator.
To ensure a smooth transition between the third and fourth National Lottery licences, the Full Business Case for the fourth National Lottery was approved by DCMS in January 2022 and by HM Treasury in February.
The Gambling Commission welcomes the government’s review of the Gambling Act which is also considering our powers and resources.
There are three key deliverables for our initial work as part of the Gambling Act Review:
We expect the Gambling Act Review White Paper to introduce several fundamental and far-reaching changes, implementation of which is likely to require significant effort from teams across the Commission.
As many of the actions arising from the White Paper will likely require consultation, we also recognise the resource impacts upon those stakeholders that will want to engage with consultation processes. Our approach will be to seek to publish a timetable of proposed consultations, make our consultations more thematic in nature and limit the number of individual consultations to avoid overburdening stakeholders and minimise consultation fatigue.
Licensing, Compliance, Enforcement and Intelligence together make up Operations which is responsible for:
In addition to our business-as-usual work we will implement a revised Regulatory Strategy. Acting on the recommendations of the National Audit Office (NAO), our approach will aim to proactively influence licensees to protect consumers, deploying a range of measures to drive operators to compliance at pace and to drive up standards in the market. We will also deliver further process efficiencies.
The strategy includes:
This year the Anti-Money Laundering team are leading the Commission's work to implement the new Economic Crime Levy. The new levy on regulated financial businesses, including some licensed casino operators, provides a new funding arrangement for the United Kingdom Financial Intelligence Unit (FIU). The levy was introduced in the Financial Services Act 2021. The Commission is one of the Supervisory Authorities, along with Her Majesty’s Revenue and Customs (HMRC) and The Financial Conduct Authority (FCA). We are required to take on the function of collecting the levy from April 2023 with liability commencing April 2022.
We estimate that around 48 (out of 186) casino licensees would be in scope for the fixed fee levy which is based on turnover. By comparison, HMRC must account for around 1,000 entities and the FCA around 3,000 entities.
The Licensing team manages the accounts of around 2,600 operators and determine the applications which generates the Commission's income. We are forecasting 200 new operating licence applications, 400 variation applications and 300 CoCC applications in the year. The team also deal with 2,000 new personal licence applications and 3,500 maintenance applications supported by automated services resulting in a more streamlined process. In addition to casework applications, the Licensing team also responds to 6,000 contacts from licensees.
The complexity and volume of the work continues to be a challenge, due in part to continued merger and acquisition activity in addition to more complex business and finance structures, which require detailed review. For example, in relation to identity and ownership and source of funds checks.
We expect to carry out 30 full compliance assessments, plus a further 1,000 items of other planned activity to include targeted assessments, thematic assessments, website reviews, security audits and review of personal licences.
We will continue to conduct regulatory and criminal investigations and to carry out intelligence led disruption and enforcement initiatives relating to illegal gambling. The outcome of our work will be made available through our Annual Report and the Compliance and Enforcement Report.
Typically, the team deal with around 3,300 intelligence reports a year. We will continue to manage the large volumes of international requests for help from overseas regulators and manage a broad range of stakeholders across government.
We expect to deal with around 700 suspicious betting reports in the next 12 months.
We will be supporting several major sporting tournaments including the Women’s Euro 2022, the Commonwealth Games and the Rugby World Cup.
The team will continue to provide specialist input into operational and casework matters as well as undertaking responsibilities as statutory supervisor duties for the regulated sector to prevent Money Laundering and Terrorist Financing.
We are expanding the Forensic Accountancy team recognising the greater complexity of work. This is because of increased merger and acquisition activity and increasingly complex business structures. We are seeing more examples of opaqueness around ultimate Beneficial Owners and a lack of transparency around source of funds.
Data and insight will be a primary focus for the Gambling Commission next year. We will lay the foundations to make significant improvements in how the Commission acquires and holds an increased range of data and leverages this to assist with its regulatory operations, as well as providing an open-source repository for stakeholders. We are investing in the initial phase of our data improvements from the recent uplift in operators’ fees.
We will be looking at how the Commission sources, analyses and stores data and how data can help us bring fresh insight to how we are delivering our strategic goals. Alongside this, we will review our internal structures, ensuring we have appropriate skills and resources available to deliver the new data programme.
To achieve this we will:
To accelerate our data agenda, £1.1m of investment funding has been allocated from the recent increase in operators’ fees. In the interim plan, we have allocated £250,000 to source specialist advice to help shape our data strategy and support our scoping activities in the first half of the year.
The remaining funds will be allocated for the second half of the year following further scoping activities. This may include additional specialist staff. We have also allocated £370,000 to extend our sample sizes for our Participation and Prevalence research.
Our people make our work possible. With 286 people across 2 sites in London and Birmingham, expanding to 317 during 2022 to 2023, we’re committed to making the Gambling Commission a great place to work and to improve our Trust Index from 56 percent to 65 percent in our 2022 annual colleague survey.
Three priority areas for improvement were identified in the 2021 annual survey:
In 2022 to 2023, we will focus on:
We will continue to follow government guidelines for ensuring COVID-19 safe workplaces and embrace the hybrid approach that we have embedded into our ways of working for the benefit of our people, ensuring everyone has the right support in place. We will also review our office spaces, in partnership with the Government Property Agency (GPA), to make best use of them.
We will manage and maintain our health and wellbeing offer to colleagues as well as reviewing our reward and benefits package.
We aim to improve our recruitment offer by developing our work in equality, diversity, and inclusion.
The Strategy team supports the Executive and Board to ensure a clear strategy is in place, and that our work fits that strategy and is coordinated. They also provide market and regulatory insight.
The Strategy team will continue to work closely with policy colleagues in the Department for Digital, Culture, Media and Sport (DCMS) and coordinate related activity. The team will continue to liaise with the National Audit Office (NAO) on the implementation of their recommendations on gambling regulation.
The Research and Statistics team provides insight to the business on how the supply (industry) and demand (consumer) sides of the gambling market work and the risks to the public presented.
The core development initiatives are our data improvement programme - covering both consumer and industry data - and the development of a three-year research plan focused on evidence related to regulatory risks.
Focused on the priorities of the fourth National Lottery licence transition and the Gambling Act Review White Paper, we will provide strategic communications support to the Commission. To support our ambition to achieve Great Place to Work accreditation by October 2022, we will undertake a comprehensive communications programme that builds a sense of trust, authenticity, and community.
Our Contact Centre will continue to operate in line with our Service Level Agreements (SLAs) and we will also improve the way we record the reasons we are contacted. This will help us better identify consumer harm and provide an additional source of intelligence.
The Governance team will offer secretariat support to the Board, Committees, advisory groups, and internal governance groupings to ensure high quality assurance and decision-making. The Governance team will also maintain our role co-ordinating Regulatory Panels and responses to complaints against the Commission.
Most of the Commission’s legal service requirements are met from an in-house legal team, including public law, prosecutions and regulatory law, contracts and employment law advice across all areas of the Commission’s activities. The team also provides legal advice to the Board and its Committees, except Regulatory Panels which are normally advised by external lawyers.
The Finance team will continue to deliver timely, accurate and insightful financial and management information within the Commission and to its external stakeholders. We will work hard to ensure that the Commission's costs for United Kingdom (UK) regulation are understood and fully recovered in the fees charged, whilst ensuring sufficient reserves are in place for utilisation should the circumstances arise.
The Commission cannot influence the number or varieties of licences held by operators within the industry, but nevertheless remains predominately dependent on this funding. As a result, there is a need for Finance to increase its focus and expertise on the respective income streams that generate all its fees, to effectively identify opportunities to generate new or incremental income streams and provide greater expertise when refreshing or establishing new fees frameworks.
The Information Technology (IT) helpdesk service and infrastructure management teams will deliver the final components of our cloud migration.
The Digital team will create a new online confidential reporting service and start the work to develop a regulatory systems replacement roadmap. The team will also perform a discovery and analysis workstream looking at new internal communications tools. A continuous improvement, maintenance, and content management workstream will keep all our digital services up to date and compliant with current legislation. We will commence and contribute to work to improve regulatory data collection.
The Information Management and Security team will continue processing of Freedom of Information (FOI) and Data Protection Act (DPA) requests in line with statutory timeframes. We will refresh our publication scheme, so that all FOI requests are published, along with the Commission’s response and other transparency information.
In accordance with our latest Internal Audit recommendations on cyber security, we will increase the frequency of our cybersecurity scanning, audit and remediation and conduct a cybersecurity business continuity exercise and response playbooks. We will also improve our documentation around vulnerability and incident management. The output will help inform a full review and redesign of the Commission’s business continuity plans.
The People Services team will continue to provide professional and considered advice and guidance on all people related matters, including policy.
We will focus on providing more self-service tools to managers, so they can readily access the information they need to manage their people.
The Programme Management Office will provide regular reporting to the Executive team, including meaningful Key Performance Indicators (KPIs) and performance dashboards, risk and assurance management all of which contribute to and support organisational understanding and informed decision making.
Our budget for 2022 to 2023 will support the successful delivery of our regulatory responsibilities and our five priorities. Mindful of the timings associated with the outcome and insights provided by the Gambling Act Review White Paper, our data scoping evaluation and the sprints, we believe it prudent to prepare a half year (6=+6) forecast to define our spending more accurately in the third (Q3) and fourth quarters (Q4) of the financial year.
Our budget for 2023 to 2023 will be the first year of a rolling three-year Costed Corporate Plan for 2023 to 2026, which we will prepare to provide meaningful context and horizon scanning of the Gambling Commission’s opportunities and challenges faced in the short and medium term.
Our financial management arrangements reflect the principles set out within Managing Public Money and to ensure that we comply with accounting standards as set out in HM Treasury’s Financial Reporting Manual (FReM) and our Management Agreement with the Department for Digital, Culture, Media and Sport (DCMS).
We are budgeting to receive total income of £51.5m, of which £25.1m is fees charged to gambling operators. Total expenditure is budgeted at £51.0m, leaving a small surplus which will be transferred to reserves.
| £m | Gambling Regulation | The National Lottery | Commission Total |
|---|---|---|---|
| Fee income | 25.1 | 25.1 | |
| Grant in Aid income from DCMS | 0.8 | 25.6 | 26.4 |
| Total income | 25.9 | 25.6 | 51.5 |
| Operating expenditure | 25.4 | 25.6 | 51.0 |
| Surplus transferred to reserves | 0.5 | 0.5 |
The breakdown of our fee income (excluding The National Lottery, which is funded by grant-in-aid) is as follows.
Annual fee income by sector (percentage).
| Sector | Amount (percentage) |
|---|---|
| Betting | 33 |
| Casino | 22 |
| Software | 19 |
| Bingo | 10 |
| Lottery | 6 |
| Machine | 6 |
| Arcades | 4 |
Annual fee income by remote and non-remote (percentage).
| Channel income | Amount (percentage) |
|---|---|
| Remote | 71 |
| Non-remote | 29 |
Please note that it is only by financial year 2023 to 2024 that the Commission will have its first full year of income at the revised fee rates.