Consultation response
2023 Consultation on proposed changes related to financial penalties: Consultation Response
This response sets out our position in relation to the consultation on the proposed changes to the Statement of Principles for Determining Financial Penalties.
Contents
- Executive summary
- Introduction
- Summary of responses and our position
-
- Proposal 1: Principles for determining financial penalties
- Proposal 2: The framework of policies and procedures
- Proposal 3: The legal framework
- Proposal 4: The scope of this document
- Proposal 5: Key considerations
- Proposal 6: The purpose of imposing a financial penalty
- Proposal 7: Criteria for the imposition of a financial penalty
- Proposal 8: Criteria for determining the quantum of a financial penalty
- Proposal 9: Step 1 - Detriment to consumers and/or financial gain to the licensee
- Proposal 10: Step 2 (a) - The seriousness of the breach to determine the starting point of the penal element
- Proposal 11: Step 2 (b) - Determining the starting point of the penal element of the fine
- Proposal 12: Step 3 - Mitigating and aggravating factors
- Proposal 13: Step 4 - Adjustment for deterrence
- Proposal 14: Step 5 - Discount for early resolution
- Proposal 15: Step 6 - Affordability
- Proposal 16: Step 7 - Proportionality
- Proposal 17: Procedural matters, payment plans, time limits and payments in lieu of financial penalties
- Proposal 18: Indicative sanctions guidance
- Proposal 19: Impact of the proposals on protected characteristics stated in the Equality Act 2010
- Annex
Annex 1 - List of organisations that responded and consented to the publication of their name
Annex 1 lists organisations that consented to the publication of their name when responding to the consultation. If the organisation name was not available, the name of the individual who submitted the response and consented to the publication of their name has been listed. All names of organisations or individuals have been presented as provided by the respondents that submitted the response.
Organisations and individuals representing organisations that consented to the publication of their name when responding to the consultation.
- 888 / William Hill Group
- Bacta
- Betting and Gaming Council
- BoyleSports
- BV Gaming Limited
- Entain Plc
- GambleAware
- Gambling Business Group GBG
- Gambling with Lives
- Gamesys Operations Ltd
- GamFederation
- Hospice Lotteries Association (HLA)
- Macmillan Cancer Support
- Merkur.com AG
- Noovomatic UK
- People's Postcode Lottery
- Petfre (Gibraltar) limited
- Star Racing Ltd and Playbook Gaming Ltd
- The Bingo Association
- The Football Pools (The Pools)
- The Health and Social Care Alliance Scotland
- The Lotteries Council.
Annex 2 - Questions asked in the Winter 2023 consultation on proposed changes to the Statement of Principles for Determining Financial Penalties
Last updated: 10 July 2025
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