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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 8: Changes to licence condition 15.2.1 (reporting key events – financial events)


We proposed to remove 15.2.1 (13), (14) and (16) as we have determined that we no longer require this information to be reported to us as key events. We have found different ways of assuring ourselves on the risks that these key events were designed to mitigate against. We also proposed to move 15.2.1 (15) to 'other reportable events' under licence condition 15.2.2 as whilst we still need to be informed of this matter, we no longer consider it to be an event that could have a significant impact on the nature or structure of a licensee’s business.

Consultation question

Question 1.8. Do you agree with the proposed changes to the licence condition?

Respondents' views

These proposals, to remove four key event reporting requirements, were widely supported. Respondents commented that their removal would reduce the regulatory burden for licensees and improve their operational efficiency.

One respondent stated that we need to be aware of any unsettled court judgments as these may indicate wider financial problems with a licensee. Another respondent suggested that all betting licensees (non-remote and remote) should be required to produce independently audited accounts. One respondent queried if removing the key events related to customer funds would place consumers at greater risk.

Our position

Having reviewed historical submissions for licence condition 15.1.1 (13), relating to court judgments, we consider that any significant matters that would be reported under this key event are sufficiently accounted for by other key events, such as 15.2.1 (23) (reporting the commencement of material litigation). Also, where the subject of the court judgment constitutes an offence under the Gambling Act, including a breach of the Licence Conditions and Codes of Practice (LCCP), it would be reported to us under licence condition 15.1.

In relation to the submission of audited accounts (15.2.1 (14)) our focus is on issues of material impact and we now consider these to be sufficiently covered across other reporting requirements.

In the case of licence condition 15.2.1 (15), concerning arrangements for the protection of customer funds, this is to be moved to licence condition 15.2.2 (other reportable events). We will still require this information to be reported to us but have decided to no longer classify it as key event.

For licence condition 15.1.1.(16), reporting of a customer fund account deficit, we have concluded that our key events concerning financial viability (combined with other data sources we use to assess financial risks) are sufficient for us to trigger actions to protect customer funds with a specific licensee, without us continuing to require this key event.

The following changes will take effect from 31 October 2020.

Final wording of amended licence condition 15.2.1 (Financial events)

Financial events

10 [No change]

11 [No change]

12 [No change]

13 [Removed and renumbered]

14 [Removed and renumbered]

15 [Removed and renumbered]

16 [Removed and renumbered]

17 [No change]

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Proposal 7: Changes to licence condition 15.2.1 (reporting key events – relevant persons and positions)
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Proposal 9: Changes to licence condition 15.2.1 (reporting key events - legal or regulatory proceedings or reports)
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