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  3. Amendments to LCCP due to the Digital Markets, Competition and Consumers Act 2024: Consultation Response

Consultation response

Amendments to LCCP due to the Digital Markets, Competition and Consumers Act 2024: Consultation Response

This response sets out our position in relation to the consultation on the proposed amendments to LCCP due to the introduction of the DMCC Act 2024.

Published
18 December 2025

Last updated
18 December 2025 - Changes

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Contents

Executive summary

The Digital Markets, Competition and Consumers (DMCC) Act 2024 (opens in new tab) is a new UK law that aims to update and strengthen consumer rights and protections and improve access to alternative dispute resolution for consumer contract disputes. The Act revoked and replaced the Consumer Protection from Unfair Trading Regulations (CPUTR) 2008 and will lead to the revocation of the Alternative Dispute Resolution for Consumer Disputes (Competent Authorities and Information) Regulations (ADRR) 2015, replacing them with new provisions.

Both the CPUTR 2008 and the ADRR 2015 are referenced in our Licence Conditions and Codes of Practice (LCCP). These sections will need to be amended or removed and replaced with references to the new DMCC Act 2024. The LCCP changes required only reflect the changes in legislation and will not extend beyond the legal obligations on licensees. To make these changes, a consultation was required.

On 18 August 2025 we published a consultation which made proposals to amend or remove wording in sections of the LCCP and replace them with references to the DMCC Act 2024. Stakeholders were invited to share their views on these proposals and provide a response to the proposed LCCP amendments.

This response sets out our position now that the consultation has closed and all 14 responses submitted have been considered.

We asked

We consulted on 4 proposals to amend the LCCP and to reflect changes in legislation (opens in new tab):

  1. Remove the reference to CPUTR 2008 from paragraph 4 of Licence Condition (LC) 7.1.1 (Fair and transparent terms and practices) and replace it with the DMCC Act 2024.
  2. Remove the reference to CPUTR 2008 from Social Responsibility Code Provision (SRCP) 5.1.9 (1) (Other marketing requirements) and replace it with the DMCC Act 2024.
  3. Amend footnote ‘a’ of SRCP 6.1.1 (Complaints and disputes) so that it refers to the accreditation procedure under the DMCC Act 2024 rather than the ADRR 2015.
  4. Remove footnote ‘b’ of SRCP 6.1.1 (Complaints and disputes) which refers to ‘a list of providers that meet the Gambling Commission’s additional standards’ as this will no longer be applicable. Also remove the sentence under footnote ‘b’ which states, ‘Both lists are on the Commission’s website and will be updated from time to time’ and delete number 3 of the references, which refers to the Commission’s list of approved ADR providers.

We also stated that we would amend the parts of our website and guidance documents that refer to the CPUTR 2008 and the ADRR 2015. Amendments to our website and guidance documents do not need to be consulted on but we mentioned them for information in the consultation document.

You said

On 18 August 2025 we published our consultation ‘Proposed amendments to Licence Conditions and Codes of Practice (LCCP) due to the Digital Markets, Competition and Consumers Act 2024’.

Stakeholders were invited to share their views on these proposals and provide a response to the proposed LCCP amendments.

The consultation ran until the 29 September 2025.

Responses from stakeholders included:

  • most agreed or strongly agreed with the proposals with a smaller percentage stating they neither agreed nor disagreed. None of the respondents disagreed
  • two respondents expressed concern around whether the new legislation might carry new definitions resulting in new requirements for gambling operators
  • one respondent expressed concern around those consumers experiencing vulnerability and whether the legislation change alone will guarantee meaningful protection unless the LCCP explicitly requires gambling operators to implement policies and processes that recognise and respond to vulnerability
  • three respondents suggested that consideration should be given to the timing of implementation for these proposals as there is a potential for gambling operators to be in breach of the updated LCCP provisions
  • a trade association asked whether the Commission would be providing a link or signposting gambling operators to a list of the new Alternative Dispute Resolution (ADR) providers
  • one trade association and 2 gambling businesses commented that they hoped the removal of the Commission from the accreditation process would not have an adverse impact on standards or an undue effect on current ADR providers
  • a trade association asked us to consider whether the outcome of this consultation may change the future direction of creating an ombudsman.

Annex 1 lists organisations that consented to the publication of their name when responding to the consultation.

We did

Following careful consideration and review of the responses received during the consultation, we have decided to proceed with all 4 proposals:

  1. Remove the reference to CPUTR 2008 from paragraph 4 of LC 7.1.1 (Fair and transparent terms and practices) and replace it with the DMCC Act 2024.
  2. Remove the reference to CPUTR 2008 from SRCP 5.1.9 (1) (Other marketing requirements) and replace it with the DMCC Act 2024.
  3. Amend footnote ‘a’ of SRCP 6.1.1 (Complaints and disputes) so that it refers to the accreditation procedure under the DMCC Act 2024 rather than the ADRR 2015.
  4. Remove footnote ‘b’ of SRCP 6.1.1 (Complaints and disputes) which refers to ‘a list of providers that meet the Gambling Commission’s additional standards’ as this will no longer be applicable. Also remove the sentence under footnote ‘b’ which states, ‘Both lists are on the Commission’s website and will be updated from time to time’ and delete number 3 of the references, which refers to the Commission’s list of approved ADR providers.

Proposals 1 and 2 will come into force on the 6 April 2026. We anticipate that the implementation of proposals 3 and 4 will take place in Spring 2026, however, these changes depend upon when the Department for Business and Trade (DBT) can enact the changes in the DMCC Act that will abolish the ADR regulations. That date has not been confirmed. We will update our website with the date when we can.

Following the consultation, we identified a typographical error in SRCP 5.1.9. The word ‘advertisement’ should read ‘advertisements’ and is therefore being amended as part of this consultation. This correction does not change the meaning of the provision.

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