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Consultation response

Licensing, Compliance and Enforcement Policy: Consultation Response

This response sets out our position in relation to the consultation around proposed changes to our Licensing, Compliance and Enforcement Policy.

Proposal 10: Assessment framework


Updated paragraph 4.19

In carrying out this assessment, the Commission will use the following framework:

Serious failings

This indicates that a substantial risk to the licensing objectives; or significant concerns about the licensee’s suitability; or significant non-compliance with the requirements of the Act and the Commission’s LCCP.

Improvement required

This indicates that there is less risk to the licensing objectives; the licensee meets the minimum expectations regarding suitability; the licensee just meets the requirements of the Act and the Commission’s LCCP.


This indicates that the licensee is unlikely to pose a risk to the licensing objectives; the licensee appears to be suitable to carry on the licensed activities in question; the licensee appears to be meeting the requirements of the Act and the Commission’s LCCP.

Consultation question

    Q14. To what extent do you agree with the proposed amendment to the assessment framework?

We proposed changes to the explanations of 'Serious Failings', 'Improvement Required' and 'Compliant'. Most responses supported the proposal but noting some of the feedback, we are implementing the proposal with some amendment.

Respondents’ views

Respondents made the following comments:

  • the categories appear clearer but there should be subcategories in the improvements required section, to separate minor and/or major improvements being required
  • the section entitled 'Improvement Required' should not stipulate that a licensee 'just meets' the Commissions requirements as this would mean they are technically compliant
  • sections of the framework could be more prescriptive.

Our position

We use the summary of our assessment findings, which we send out to licensees after every assessment to clarify where we believe an issue is a breach of a licence condition or where there is an issue of concern, that could be categorised in different terms as a minor non-conformity. We do not consider that additional subcategories are required.

'Improvement required' is used to reflect circumstances where a licensee may be in breach of a licence condition or social responsibility code, or any other requirement attached to a licence. However, we would not use this description where we judge that there is likely to be a significant impact on consumers, the licensing objectives, or the reputation of the industry. We would also expect clear assurances that a licensee will make immediate changes to ensure that there is no future risk. As an outcome focussed regulator we will consider the impact, or potential impact of non- compliance.

Some respondents have requested that the outcome descriptions are more prescriptive. However, our focus in on achieving consistency and so additional categories are not helpful. We are committed to communicating the findings of our assessments in writing with clear details around the actions required.

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Proposal 9: Remote assessments
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Proposal 11: Special Measures
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