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.
Contents
- Executive summary
- Introduction
- Summary of responses - Licensing changes
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- Proposal 1: Policy position in relation to dual regulation products
- Proposal 2: Changes to complete applications
- Proposal 3: Clarification of relevant persons
- Proposal 4: Timescale for using licence
- Proposal 5: Clarification of suitability criteria
- Proposal 6: Clarification of financing arrangements
- Proposal 7: Addition of new examples to update the Commission about
- Proposal 8: Minor updates to reflect minor changes to processes in the policy
- Summary of responses - Compliance changes
- Summary of responses - Enforcement changes
Strengths of the approach
The mixed-methods design of this study is a core strength, allowing findings to be triangulated across 3 distinct phases.
Complementary insights
The phases were designed to build on one another. The digital intelligence phase mapped the online landscape, ensuring the quantitative and qualitative phases were grounded in real-world behaviours and consumer language (such as using terms like ‘giveaway’ and ‘competition’ rather than relying solely on legal definitions).
Balancing breadth and depth
The quantitative survey provides a robust, statistically representative view of the scale and exposure and participation among those who gamble online. The qualitative interviews complement this by explaining the ‘why’, uncovering the emotional and practical drivers behind the data.
Capturing the full consumer journey
By combining the observed online behaviour (digital intelligence) with self-reported actions (quantitative) and lived experiences (qualitative), the research provides a comprehensive view of the entire journey, from passive discovery, through to off-platform payment and post-draw reactions.
Last updated: 13 August 2026
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