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.
Proposals 1 and 2: Amendment to LCCP Licence Condition 7.1.1 and amendment to LCCP Social Responsibility Code Provision 5.1.9
Proposals 1 and 2 were as follows:
- Remove the reference to Consumer Protection from Unfair Trading Regulations (CPUTR) 2008 from paragraph 4 of Licence Condition (LC) 7.1.1 (Fair and transparent terms and practices) and replace it with the Digital Markets, Competition and Consumers (DMCC) Act 2024.
- 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.
The intention behind these proposals was to ensure that the Licence Conditions and Codes of Practice (LCCP) reflects the new consumer legislation, which provides updated definitions for the relevant terms referenced in LC 7.1.1 and SRCP 5.1.9.
Consultation questions relevant to these proposals
- To what extent do you agree with the proposed changes to Licence Condition 7.1.1 of the LCCP to refer to the Digital Markets, Competition and Consumers Act 2024? Please give your reasons for your answer.
- To what extent do you agree with the proposed changes to social responsibility Code Provision 5.1.9 of the LCCP to refer to the Digital Markets, Competition and Consumers Act 2024? Please give your reasons for your answer.
Respondents’ views
Most respondents were supportive and positive about the proposed changes in proposals 1 and 2. Positive responses included one that strongly agreed with the amendments, stating that the changes would ensure that the LCCP is aligned with new legislation and enhance clarity and transparency.
Two respondents indicated that they neither agreed nor disagreed with the proposals but did not provide any further information to support this view.
Two respondents expressed some concerns around whether the DMCC Act 2024 might carry some new definitions, tests or considerations when compared to the previous legislation and asked that the Gambling Commission provide some guidance if the Act extends the current scope of responsibilities for licensed gambling operators within the LCCP.
One respondent raised concerns about those consumers who are experiencing vulnerability and highlighted that this legislative change alone will not guarantee meaningful protection unless the LCCP explicitly requires gambling operators to implement policies and processes that recognise and respond to vulnerability.
Our position
We have considered all comments and acknowledge the concerns raised by stakeholders in the consultation responses.
We maintain the view that we need to amend the wording of both LC 7.1.1 (4) and SRCP 5.1.9 (1) of the LCCP to reflect new legislation, namely the DMCC Act 2024, which has already revoked and replaced the CPUTR 2008.
The DMCC Act 2024 provides updated definitions for key terms, but the concepts themselves are broadly the same. Our assessment was that while there are likely to be aspects in which duties on licensees are enhanced by the DMCC Act 2024, the overall effect is to streamline the requirements rather than hold licensees to a new set of standards. Licensees will be directly bound by the DMCC Act 2024, regardless of whether we make changes to the LCCP.
We note the concerns around consumer vulnerability in one of the responses. However, the aim of this consultation and resulting changes to the LCCP is only to make the necessary consequential changes due to the DMCC Act 2024. Any policy changes regarding licensees recognising and responding to vulnerability fall outside its scope.
Final wording
This requirement will come into force on 6 April 2026.
Applies to: All operating licenses except gaming machine technical and gambling software licences.
Paragraph 4 - LC 7.1.1 - Fair and transparent terms and practices
“Licensees must ensure that they do not commit any unfair commercial practices within the meaning of the Digital Markets, Competition and Consumers Act 2024 at any stage of their interactions with consumers”.
Paragraphs 1 to 3 of LC 7.1.1 will be unchanged.
This requirement will come into force on 6 April 2026.
Applies to: All licences.
Paragraph 1 - SRCP 5.1.9 - Other marketing requirements
“Licensees must ensure that their marketing communications, advertisements, and invitations to purchase (within the meaning of the Digital Markets, Competition and Consumers Act 2024) do not amount to or involve misleading actions or misleading omissions within the meaning of this Act”.
Paragraphs 2 and 3 of SRCP 5.1.9 will be unchanged.
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.
Where appropriate, any references on our website to the Consumer Protection from Unfair Trading Regulations 2008 will be replaced with the DMCC Act 2024 at the time these changes come into effect.
Next sectionProposals 3 and 4: Amendments to LCCP Social Responsibility Code Provision 6.1.1
Last updated: 18 December 2025
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