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Industry Forum minutes for 9 September 2025

Minutes of the meeting of the Industry Forum, 9 September 2025.

[Remote] Industry Forum Meeting.

Members:

  • Nick Rust (Chair)
  • Tony Boulton
  • Kirsty Caldwell (item 4)
  • Charles Cohen
  • Ashley Padgett
  • Leo Walker
  • Helen Walton
  • David Williams.

In attendance: REDACTED.

Apologies:

  • Mark Pearson
  • Nigel Roddis.

1. Welcome, apologies and declarations of interest

Apologies for the meeting were noted, no new declarations of interest.

2. Approval of minutes

Members would like some amendments made to the minutes.

REDACTED.

3. CMS transition and implementation update

The REDACTED gave an overview of the Gambling Commission’s new Case Management System (CMS), the reasons for the change to the new CMS, and how the new CMS will impact operators. The new system will improve processes internally for colleagues and give them the opportunity to improve the experience of the operators and other industry stakeholders; for example, the response times to license enquiries should be more efficient as a result of this work.

  1. Further improvements will be made at a later stage to the Commission’s online services; for example, the licensing application process. Industry Forum (IF) will be approached for input in this project.
  2. Forum members are welcome to provide feedback and suggestions on CMS now but will also be given further opportunities to provide feedback at future stages.
  3. The REDACTED confirmed that a team will be dedicated to responding to technical issues during the early launch phases.

IF members provided positive feedback on the changes. They added that the Commission should ensure operators are aware of the process and what to do if they need to access e-services during the downtime period due to regulatory deadlines.

4. Customer led tools update

The REDACTED gave an update on upcoming changes to the Remote Gambling Software Technical Standards (RTS), in relation to customer led tools.

The update began with a timeline that covered the origins of this work and key milestones. There was also a recap of the related policy intentions set out in the White Paper.

Discussion moved on to the response to the supplementary consultation on the definitions of deposit limits, which is due to be published shortly. In summary:

  • as a minimum, all operators must offer gross deposit limits. Only gross deposit limits may be called 'deposit limits' and must be called 'deposit limits'
  • net deposit limits can also be offered as an option (implementation guidance)
  • gross deposit limits must be offered with at least equal prominence as other types of financial limit
  • the Commission will be renaming ‘spend limits’ as ‘stake limits’ in the RTS.

Whilst the Commission have considered operators’ responses to the consultation relating to implementation of the changes, the REDACTED welcomed further feedback from IF members about any other factors or potential issues that should be considered:

  • IF members stated that some operators will have to rebuild their infrastructure to implement these changes, which will be expensive. They asked whether this has been considered by the Commission along with the potentially lengthy time it would take to complete
  • one IF member suggested that changes could take between 6 to 9 months to be made and changes generated from other consultations should also be considered when determining an implementation period for this work
  • the Commission acknowledged that it could take some time for some operators to implement these changes and will give this consideration when deciding on an appropriate implementation timeline
  • net deposit limits can continue to be offered as an additional option, but all operators must offer gross deposit limits
  • members then discussed the RTS changes due to come into effect on 31 October, noting that if operators replace ‘drop down’ options with free text it will allow customers to type a limit beyond their affordability, which could result in compliance problems
  • the Commission is not setting a mandatory upper limit for customer-set financial limits but that does not prevent operators from considering an appropriate limit. Operators should already have measures in place to identify very high levels of spend
  • a member commented that operators now have a global limit and there are software thresholds and controls that monitor this.

The IF Chair asked what the communications for this look will look like and is there a risk of customers receiving too many emails? Is there also the risk that new customers might be at an advantage if they have access to both types of deposit limits from a set day when existing customer accounts still have net deposit limits?:

The Commission does not expect operators to increase communication with customers ahead of the changes coming into effect. From the implementation date, all new customers must be presented with gross deposit limits as an option with at least equal prominence to any other limits, if offered by the operator, at sign up. Deposit limits and any other types of financial limits offered by operators should be made available to existing customers to access from the implementation date and at relevant review points.

Regarding the supplementary consultation, an IF member asked why the Commission decided not to align terminology for the various deposit types?:

  • the Policy team decided that would have created unnecessary disruption in relation to types of limits named in implementation guidance rather than as requirements
  • members were thanked for their feedback, it has been very helpful.

The work on this project received positive feedback from members who felt that this was a good way to engage with industry and allow the Commission to understand some of the challenges for operators. This approach should be considered for future consultations.

5. GAR Evaluation – operator survey

REDACTED provided a summary of the recent survey that was sent out to operators and how it fits into the wider evaluation plan. The survey was issued by NatCen as part of work to evaluate several Gambling Act Review (GAR) policies. The collective impact of the policies is a focus of the evaluation. REDACTED explained how the survey received a below target response rate and opened some questions to the forum for their feedback on how to improve the response rate for the second wave of the survey taking place in 2026:

  • IF members questioned the independence of NatCen, the role of the Evaluation Advisory Panel and how they will use the information collected in the survey. It is the opinion of IF members that the evaluation advisory panel contains people whom they deem to hold strong pre-held opinions of industry and the GAR process. Operators want to understand that the survey is impartial. REDACTED assured members that the Advisory Panel does not access the collected data and is a collection of individuals who will advise on the most appropriate methodological approaches to a complex evaluation
  • members also said that the survey was not sufficiently highlighted to smaller operators, and factors that could have impacted their responses were; the timing of the survey (during peak holiday season), the recipient of the survey not being the relevant person, and the importance of the survey not being expressed clearly enough. The Commission should consider raising awareness in a wider range of forums
  • trade associations can be of great assistance in making people aware of the survey and encouraging them to participate; for example, they have a newsletter and a forum. Not all operators will visit the Commission website or newsletter frequently
  • game suppliers should not have been excluded from the survey (in relation to the non-slots game design changes)
  • although REDACTED explained to IF members survey questions were phrased to allow both positive and negative feedback, they were still concerned that the questions were set in a way that would receive a specific response; for example, that the measures have been successful. There is the feeling that responses are not examined in sufficient detail and instead there are ‘intended outcomes’
  • there is a lot more work to be done in regard to the GAR, so it seems too early to be evaluating. REDACTED responded that data is being collected at different points
  • understanding unintended consequences should be a more significant aspect of the evaluation process.

REDACTED.

REDACTED.

6. Update from KnowNow conference

The IF member that attended the event said that it went well. They received questions about the IF chair’s decision not to renew his term, and a question of how the forum can be truly representative of industry if it has bigger operators on the forum.

7. HM Treasury Consultation: unintended consequences

Nick has been asked to update the Commission’s Board on several topics at their pre-board meeting next week, including the industry view of HM Treasury's consultation on the taxation of gambling operators. IF members have been asked to send their thoughts and feedback.

REDACTED.

8. AOB

An IF member offered positive feedback on Commission’s work on unlicensed affiliates. Cease and desists are being made.

There was no other business to discuss.

REDACTED.

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