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 3 and 4: Amendments to LCCP Social Responsibility Code Provision 6.1.1
Proposals 3 and 4 were as follows:
- Amend footnote ‘a’ of Social Responsibility Code Provision (SRCP) 6.1.1 (Complaints and disputes) so that it refers to the accreditation procedure under the Digital Markets, Competition and Consumers (DMCC) Act 2024 rather than the Alternative Dispute Resolution for Consumer Disputes (Competent Authorities and Information) Regulations (ADRR) 2015.
- 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 Alternative Dispute Resolution (ADR) providers.
The ADRR 2015 designates the Commission as a ‘competent authority’ for ADR in the gambling sector. The DMCC Act 2024 will bring in provisions which will fully revoke the ADRR 2015, meaning the Commission will no longer be the competent authority for gambling ADR and will not be able to approve ADR providers, or set additional standards for them. Anyone wishing to carry out ADR in the gambling sector will be required to apply to the Secretary of State for Business and Trade for accreditation.
The intention behind these proposals is to amend and remove wording within the footnote linked to section 6.1.1 of the Licence Conditions and Codes of Practice (LCCP) to reflect the fact that the DMCC Act 2024 will fully revoke the ADRR 2015 and the Commission will no longer be responsible for ADR accreditation.
Consultation question relevant to these proposals
- To what extent do you agree with the proposed changes to update SRCP 6.1.1 of the LCCP to take account of the Digital Markets, Competition and Consumers Act 2024? Please give your reasons for your answer.
Respondents’ views
Ten respondents were supportive and positive about the proposed changes in proposals 3 and 4, with 4 respondents neither agreeing nor disagreeing. One example of a positive response highlighted the need for the LCCP to reflect legislative changes and that these proposals will help licensees maintain compliance. A larger number of concerns were expressed by respondents in this section of the consultation.
Three respondents suggested that consideration ought to be given to the timing of implementation to avoid the potential for operators to be in breach of the updated LCCP provisions. There was a suggestion that amendments to the LCCP should not take effect until all existing ADR providers are approved under the new regime by the Secretary of State. There was also some concern about whether those ADR providers currently approved by the Commission would automatically be accredited under the DMCC Act 2024. If not, would time be allowed for a gambling operator to transition to a new ADR provider in the unlikely event that their current ADR provider did not receive accreditation under the new scheme.
One respondent asked whether the Commission would provide a link or signposting to the new list of accredited gambling ADR providers.
Respondents suggested that removing the Commission as a ‘competent authority’ with extensive experience and industry knowledge may have an adverse impact on the standards for gambling specific dispute resolution or an undue effect on current ADR providers who are well versed on industry specific issues. Respondents hoped that those current ADR providers approved by the Commission would go on to receive accreditation under the new Act.
One respondent queried whether the outcome of this consultation could significantly change the landscape for customer dispute resolution within the gambling industry and might therefore impact on the potential creation of an ombudsman scheme.
Our position
We have considered all comments raised by stakeholders in the consultation responses.
We maintain the view that we need to amend and remove wording in the footnotes of Social Responsibility Code Provision 6.1.1 of the LCCP to reflect a change in legislation, namely the introduction of a new accreditation scheme for ADR providers in the gambling sector.
We will continue to work closely with the Department for Business and Trade (DBT) to make sure that any changes it implements, that will have a direct impact on the gambling industry, are clearly communicated to avoid confusion, particularly around the implementation of the new accreditation process.
The DBT plans to put in place transitional arrangements whereby existing ADR providers accredited under the 2015 regulations will be subject to simplified accreditation under the new scheme brought about by the DMCC Act 2024. It envisages that the 2 frameworks will run concurrently for a period of time to provide continuity while the switch to the new system is completed. In doing this, it aims to ensure continuity of ADR provisions for consumer and business users and minimise any additional administrative burden on existing providers.
We will amend LCCP wording, as per the proposals, at the point at which the provisions covering ADR in the DMCC Act 2024 come into effect. We do not envisage licensees finding themselves unintentionally in breach of the LCCP because their ADR provider has not yet been accredited. The DBT intends to operate the ‘fast track’ procedure explained previously including a period where both frameworks operate concurrently.
The DBT has advised the Commission that it will be able to signpost gambling operators to the new list of accredited ADR providers. The DMCC Act 2024 ADR framework is designed to improve how information, advice and guidance relating to ADR providers is made publicly available, prominent, and visible to consumers who may need to access the service. The Commission will provide a link to a list of accredited ADR providers on our website.
It is the government’s intention that the new framework provides a certain amount of flexibility for the creation of new sector-specific ombudsman through the power to exempt ADR provision in regulated sectors and elsewhere where dispute resolution provision in those sectors is underpinned by other statute. This is to prevent dual regulation and give departments and regulators the freedom and flexibility to respond to the needs and requirements of dispute resolution in individual sectors. Therefore, the introduction of the DMCC Act 2024 does not prevent the future creation of a gambling specific ombudsman.
Final wording
Applies to: All licences (including ancillary remote licensees) except gaming machine technical and gambling software licences.
SRCP 6.1.1 - Complaints and disputes
We will amend footnote ‘a’ to:
“a person offering alternative dispute resolution services who has been granted accreditation by the Secretary of State under Chapter 4 of Part 4 of the Digital Markets, Competition and Consumers Act 2024”.
We will delete the following wording from footnote ‘b’:
“Whose name appears on the list of providers that meet the Gambling Commission’s additional standards found in the document ‘Alternative dispute resolution (ADR) in the gambling industry – standards and guidance for ADR providers”.
We will also delete the sentence that sits 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 anticipate that both changes will come into force in Spring 2026. However, these changes depend upon when the DBT 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.
Where appropriate, any references on our website to the ADRR 2015 will be either removed or replaced with the DMCC Act 2024. This process will include removing any material or guidance relating to our responsibilities on gambling ADR arising from those regulations. Our additional standards for ADR providers introduced in 2018 will be withdrawn. The changes to the website will be made at the time the changes to the LCCP come into effect.
Previous sectionProposals 1 and 2: Amendment to LCCP Licence Condition 7.1.1 and amendment to LCCP Social Responsibility Code Provision 5.1.9
Last updated: 18 December 2025
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