Pubs and clubs toolkit
Working closely with local police, licensing officers and local groups like PubWatch, the Gambling Commission is stressing that pubs and clubs need to make sure they meet their legal obligations in providing gambling facilities. That compliance will prevent the need for enforcement action.
But when it is required those who are facilitating betting or those exceeding exempt gaming limits in alcohol licensed premises can have the exemption which permits gaming in pubs removed, have their alcohol licence reviewed, be cautioned, ordered to carry out unpaid work, ordered to pay costs or fined.
Working with HMRC to ensure any tax issues are also addressed can be an extra deterrent.
The guidance to licensing authorities on clubs is available.
The guidance to licensing authorities on premises licensed to sell alcohol is available.
Pubs and clubs toolkit - Facilitating betting in pubs and clubs
Facilitating betting in pubs and clubs is illegal
No commercial betting at all, regardless of the level of stakes, is allowed in pubs and clubs. It is not socially responsible and those who facilitate such betting in pubs and clubs – whether publicans, designated premises supervisors or club officials – are providing illegal facilities for gambling and are breaking the law.
Even where publicans, designated premises supervisors or club officials accept bets on behalf of licensed bookmakers, or just facilitate betting through their own telephone accounts, they are acting as betting intermediaries and could be prosecuted.
Licensed bookmakers who knowingly accept bets from pub customers through a single account are encouraging illegal gambling. They may be in breach of the Gambling Act 2005 and could risk losing their licence.
Licensed bookmakers with a remote or ancillary licence may accept telephone bets from a customer watching an event in a pub or club, as long as that customer has an individual account with them.
Agents cannot take bets
It is illegal for bookmakers or their agents to sit in the pub taking bets themselves. Similarly, it is also illegal for operators to put their agent in clubs, for example, in a working men’s club on a Saturday, to take bets.
Be vigilant
Licensed bookmakers should be vigilant. Where they suspect an individual telephone account is being used to transact business for a number of pub customers they should be alert to the possibility that it is being used to facilitate betting and where appropriate take steps to close the account.
Be responsible
Anyone betting and drinking alcohol at the same time may lose their inhibitions and place more than they can afford on a bet. It is the responsibility of all licensed bookmakers to ensure gambling is carried out in a socially responsible manner.
Individuals who engage in the facilitation of illegal betting risk up to 51 weeks imprisonment (six months in Scotland) and/or up to a £5,000 fine.
Customers can watch sport on the television and engage in betting activities as long as they place the bet using their own telephone account or take a betting slip to the bookmaker themselves.
It is not illegal to have betting slips or coupons in a pub or club, so long as when the customer completes the slip or coupon, they take it to the bookmaker themselves.
You may not take betting slips members of a club have completed or the stake money to the bookmakers before a sporting event. You will be acting as a betting intermediary and risk prosecution.
You may not phone all the bets though to the bookmaker as you will be acting as a betting intermediary by providing illegal facilities for gambling and risk prosecution.
You may not take bets in a working mens club, even if you are a licensed book maker. You can only take bets in your licensed premises or over the telephone if you have an ancillary remote or full remote licence.
Pubs and clubs - Case studies
Working with HMRC on illegal betting in pubs
A pub in St. Helens was subject to a multi-agency operation and subsequent investigation involving officers from St. Helens Council, the Gambling Commission, Merseyside Police and HM Revenue & Customs.
The pub manager pleaded guilty to providing illegal gambling under s37 of the Gambling Act 2005 (opens in new tab) at St. Helens Magistrates Court. He was sentenced to 100 hours of unpaid work and ordered to pay costs of £930.
HMRC also imposed back-dated tax of £2,952 and penalties totalling £9,750 for general betting duty, failure to declare betting income and submit betting duty returns.
Bookmaker and pub landlord fined for illegal betting
Cumbria police entered pub premises and found the landlord at a table with racing papers, betting slips, a mobile phone, drinks and pens. He had been recording horse racing bets for customers.
The case was prosecuted by Allerdale Borough Council who were supported in their enforcement action by both the Gambling Commission and Cumbria police. The landlord and bookmaker pleaded guilty to two counts:
- aiding and abetting the use of premises to provide facilities for betting when no appropriate licence was in force
- providing facilities for gaming not holding a licence or being exempt.
The betting company, which no longer operates any betting premises, was fined a total of £4,500 and ordered to pay court costs of £625 and a £15 victim’s surcharge.
Pubs and clubs - Equal chance gaming in pubs and clubs
In order to help determine premises applications and when inspecting premises we have brought together all the gambling codes of practice in one place.
The codes specify a number of requirements related to social responsibility issues and these may be of particular interest where you are concerned about, for example, protection of the young and vulnerable.
The codes also apply to situations in which gambling is being offered without an operator’s licence from the Gambling Commission. For example, equal chance gaming and gaming machines in clubs and premises with an alcohol licence.
The Code of practice for equal chance gaming in clubs and premises with an alcohol licence is available.
The Code of practice for gaming machines in clubs and premises with an alcohol licence is available.
Bingo in pubs and clubs
Bingo can be offered on alcohol licensed premises, members' clubs, miners’ welfare institutes and commercial clubs without an operating licence. However, the games must:
- be for adults only
- not be linked with games played on other premises.
Guidance for businesses and individuals on how to run bingo legally is available.
Pubs must ensure that:
- no participation fee is charged
- they remain within the stake limit of charging a maximum of £5 per person, per game.
Both alcohol licensed premises and clubs must ensure they do not exceed the maximum of £2,000 per week in stakes/prizes. Those wishing to exceed this limit need to apply for a bingo operating licence.
Bingo as prize gaming
When we say ‘prize gaming’ we mean neither the nature nor the size of the prize is determined by:
- the number of people playing
- the amount paid for or raised by the game.
You can run bingo as a prize game without the need for a bingo operating licence in adult gaming centres, family entertainment centres, unlicensed family entertainment centres and travelling fairs.
To comply with the rules for prize gaming, the bingo games offered in these venues must:
- have a maximum stake of £1 and a prize worth no more than £70 per game
- offer no more than £500 of prizes per game
- have no more than £500 in stakes per game.
Club gaming and machine permits
Information about the renewal process for club gaming and club machine permits.
Guidance to licensing authorities on clubs.
Club gaming permit (CGP)
A club gaming permit is available to members’ clubs or miners’ welfare institutes, but not commercial clubs. It allows the club to offer:
- equal chance gaming such as poker and bingo
- games of chance (pontoon and chemin de fer only)
- up to three gaming machines in total of categories B3A, B4, C or D, but by agreement, only one machine can be of category B3A.
Restrictions on the gaming are:
- no limits on stakes and prizes, except bingo where there is a stakes and prizes limit of £2,000 in any seven day period
- limit on participation fees per person per day - £20 for bridge and or whist (if played on a day on which no facilities of any kinds of gaming (other than bridge or whist) are provided by the relevant club on that day), £3 for other gaming (including poker) in any other circumstances
Club machine permit (CMP)
A club machine permit is available to members’ clubs, miners’ welfare institutes, and commercial clubs. It allows the club to offer:
- equal chance gaming such as poker and bingo
- up to three gaming machines in total of categories B3A, B4, C or D, but by agreement, only one machine can be of category B3A (B3A not permitted for commercial clubs).
Restrictions on the gaming are:
- limit on stakes and prizes for bingo is £2,000 in any seven day period
- limit on stakes for poker - £10 per person per game, within a premises limit of £250 in stakes per day and £1,000 per week
- limit on prizes for poker - £250 per game
- limit on participation fees per person per day - £18 for bridge/whist (if played on a day on which no facilities of any kind of gaming (other than bridge or whist) are provided by the relevant club on that day), £1 for other gaming (including poker), £3 where it’s a commercial club.
Issuing of CGP and CMP flowchart (PDF).
Information that should accompany the permit application form
Whilst the application form itself does not ask for evidence of how ‘club’ status is being achieved, you must be satisfied that the information provided by the applicant demonstrates that the premises meets the necessary requirements to be either a members’ club or miners welfare institute or a commercial club. See Members club or commercial club for more information.
The distinction between the two types of club is important as it reflects the type of gaming that is permitted. Genuine members’ clubs can apply for a club gaming permit or a club machine permit, while commercial clubs can only apply for a club machine permit.
Clubs must also demonstrate that they are complying with the statutory codes of practice, namely, the Code of practice for equal chance gaming in clubs and premises with an alcohol licence and the Code of practice for gaming machines in clubs and premises with an alcohol licence.
More information is available on our Members' clubs and commercial clubs page.
The Gambling Commission has produced a set of Quick Guides which licensing officers and pubs and clubs can use to make sure they comply with the Gambling Act 2005 when providing facilities for gambling. These are available at Quick guides and template letters.
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Last updated: 28 November 2024
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