Consultation response
Financial key event reporting: Reporting changes in ownership and interests: Consultation response
The consultation response on reporting changes in ownership and interests as a key event.
Contents
- Executive summary
- Introduction
- Summary of responses
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- Proposal 1: Raising the reporting threshold for ‘operator status’ and ‘relevant persons and positions’ from 3 percent to 5 percent
- Proposal 2: Amendment to paragraph 2 of Licence Condition 15.2.1 to expand the application of ‘relevant persons’ to include shareholders, but also other entities with both direct and indirect interests in the licensee of 5 percent or more
- Proposal 3: Amendment to paragraph 3 of Licence Condition 15.2.1 to include the reporting of entering into financial agreements or arrangements with third parties and/or the receipt of financial assistance from a group company
- Proposal 4: Introduction of a new requirement for licensees to report to the Commission the details of individuals who acquire the equivalent of £50,000 or more worth of new shares in a rolling 12-month period
- Proposal 5: Amendment to the Licensing, Compliance and Enforcement Policy Statement under the Gambling Act 2005 to raise the threshold of shareholders to be listed from 3 percent to 5 percent
- Equalities considerations
- Business impacts and implementation
- Annexes
Business impacts and implementation
In our consultation we invited respondents to comment on any difficulties that they foresaw in complying with each proposed changes and these views have been summarised above. We also asked respondents to provide an estimate of the costs associated with implementing these proposals.
Consultation question
Please provide an estimate, including any evidence, of the direct costs associated with implementing these proposals, identifying to which proposals the estimated costs relate. Please give us your evidence below.
Respondents’ views
None of the respondents provided an estimate of costs involved in implementing the proposals. A few respondents stated that it was not possible to provide an estimate until the changes were finalised as there were too many unknowns.
One respondent stated that raising the reporting threshold from 3 percent to 5 percent for the reporting of direct share capital would appropriately decrease costs. On the other hand, they believed that should additional reporting of voting rights, dividend and/or profit entitlements, and so on, especially of indirect participants, become necessary, the associated costs might increase exponentially.
Our position
We have taken on board all the views expressed on the business impact of implementing the proposed changes in determining how we will proceed in relation to each proposal and are satisfied that our approach is proportionate and will reduce some regulatory burdens.
Equalities considerations
Last updated: 18 December 2025
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