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Consultation response

Changes to information requirements in the LCCP, regulatory returns, official statistics, and related matters

Parts I and II of the consultation response that sets out our position in relation to the information the Gambling Commission requires licensees to provide us.


Proposal 3: Changes to licence condition 15.1.1 (reporting suspicion of offences)


We proposed to amend licence condition 15.1.1 to introduce additional text which will enable us to specify the form and manner of the reporting of suspicion of offences etc. The amendment will align the requirement with other conditions relating to information reporting. This will make our information management more efficient and allow us to act in respect of reported offences more quickly and effectively. The changes will also reinforce the principle that responsibility for meeting the licence condition rests with licensees, not third parties.

Consultation question

Question 1.3. Do you agree with the proposed changes to the licence condition?

Respondents' views

Respondents noted the benefits of a standardised reporting approach; although these were tempered by a concern that any prescribed form or manner for reporting should not be overly burdensome. Several respondents noted that the change would make licensees more responsible for their own reporting of known or suspected offences. Two respondents queried whether it would be permissible for one licensee to provide information on behalf of another licensee within a group.

Some respondents requested that we define the required timescales for reporting known or suspected offences. One respondent queried whether fines would be imposed for late reporting or non-compliance.

Our position

While it is acceptable for one licensee to provide information on behalf of another within a group, ultimate responsibility for the timing and content of the submission rests with the licence holder.

We note the request to define timescales for the submission of known or suspected offences. However, we recognise that, in many instances, licensees will want to undertake due diligence to investigate the nature and scale of a potential breach. We do not, for this reason, think it practical to impose a ‘one size fits all’ time limit on reporting issues of known or suspected offences. Breaches will be dealt with in accordance with the principles contained within our Licensing, compliance and enforcement under the Gambling Act 2005: policy statement (opens in new tab). We have developed a standardised template, in consultation with stakeholders, for reporting known or suspected offences under licence condition 15.1.1. The final version and supporting guidance will be available to licensees prior to the updated licence condition coming into effect.

The following changes to licence condition 15.1.1 will take effect from 31 October 2020.

Final wording of amended licence condition 15.1.1

Licence condition 15.1.1
Reporting suspicion of offences etc - non-betting licences
All operating licences except betting, betting intermediary, ancillary remote betting, betting host and remote betting intermediary (trading rooms only) licences

1 Licensees must as soon as reasonably practicable, in such form or manner as the Commission may from time to time specify, provide the Commission with any information that they know relates to or suspect may relate to the commission of an offence under the Gambling Act 2005, including an offence resulting from a breach of a licence condition or a code provision having the effect of a licence condition.

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Proposal 2: Changes to licence condition 13.1.2 (Pool betting – football pools)
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Proposal 4: Changes to licence condition 15.1.2 (reporting suspicion of offences)
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