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  3. Summer 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response

Consultation response

Summer 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response

This response sets out our position in relation to the consultation on the proposed changes to LCCP and Remote Gambling and Software Technical Standards.

Published
1 May 2024

Last updated
13 June 2024 - Changes

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Contents

Summary - Changes to Personal Management Licence

Gambling licensees must ensure that an employee holds a Personal Management Licence (PML) if responsible for one of the ‘specified management offices’ under licence condition 1.2.1 of the Licence Conditions and Codes of Practice (LCCP). We consulted on changes to this licence condition which would both clarify and extend the roles captured.

PMLs are required to be held by anyone with responsibilities for:

  • overall strategy and delivery of gambling operations
  • financial planning, control and budgeting
  • marketing and commercial development
  • regulatory compliance
  • gambling related IT provision and security
  • management of licensed activity for a particular area in Great Britain where you have 5 or more sets of premises for which you hold a premises licence
  • management of a single set of bingo and/or casino licensed premises.

The provision does not apply to a licensee as long as the licensee is a ‘small-scale operator’ as defined in the Gambling Act 2005 (Definition of small-scale operator) Regulations 2006 (‘the Regulations’) (opens in new tab).

The provision applies to all casino, bingo, general and pool betting, betting intermediary, gaming machine general, gaming machine technical, gambling software and lottery managers licences, except ancillary remote licences (unless exempt as a small-scale operator under the Regulations).

As part of the Gambling Commission’s Summer 2023 consultations, we proposed a change to licence condition 1.2.1 to clarify and increase PML coverage. Specifically, we:

  • reiterated the requirement for the person with responsibility for the overall management and direction of the licensee’s business or affairs to hold a PML by adding wording to state that this is likely to be a CEO, Managing Director or equivalent
  • proposed that for organisations with a Board, the person responsible for chairing the Board to hold a PML (where the licensee has such a body)
  • proposed that the person responsible for the licensee’s anti-money laundering and counter-terrorist financing function as head of that function to hold a PML
  • proposed the person responsible for the submission of reports of known or suspected money laundering or terrorist financing activity under the Proceeds of Crime Act 2002 and Terrorism Act 2000 to hold a PML.

This consultation closed on the 18 October 2023. Following the consultation, the Commission has taken the decision to amend licence condition 1.2.1 on PMLs as consulted, although further clarity on the position of chair has been provided following consideration of the responses.

We have published the revised LCCP provision as part of this response and our website will be updated over the coming weeks. The provisions (in full) will come into force on 29 November 2024.

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