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
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- 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
Proposal 19: Impact of the proposals on protected characteristics stated in the Equality Act 2010
As the proposals in the amended Statement of Principles for Determining Financial Penalties (SoPfDFP) constitute a new approach and methodology regarding how the Gambling Commission will determine financial penalties, we gave consideration as to whether the proposals had an impact on the protected characteristics stated in the Equality Act 2010.
Our assessment was that the proposals do not present a negative impact on the protected characteristics stated in the Equality Act 2010, nor do they contribute towards unlawful discrimination, harassment or victimisation, or other conduct prohibited by the Equality Act 2010.
We sought views regarding whether any respondents had any evidence or information which might assist the Commission in considering any equalities impacts, within the meaning of section 149 of the Equality Act 2010, in the context of any of the proposals outlined in the consultation document.
Consultation questions
Question 61, as detailed in Annex 2, related to this consideration.
Respondents’ views
We received 14 responses, and 2 respondents shared personal insights and comments which are unrelated to the question poised.
Our position
There was nothing for the Commission to action in relation to the comments received.
Proposal 18: Indicative sanctions guidance
Last updated: 10 July 2025
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