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Frequently Asked Questions for gambling businesses during Covid-19

As the situation with Covid-19 continues to impact daily life in Great Britain, the Commission is following Public Health England guidance and we have told all staff to work from home until further notice.

The devolved governments of England, Scotland, and Wales have issued their own roadmaps for dealing with the current Covid issues. Please familiarise yourself with the arrangements by following these links:

You are also advised to read your respective Trade Association guidance by following these links:

Fees information

Land-based operators

The Gambling Commission recognises the current unprecedented Covid-19 circumstances leaves the affected sectors facing uncertain and unsettling times with the closure of premises.

We received enquiries asking for a reduction in fees or the option to pay by instalments. Unfortunately, due to the way that our fee system is structured we are not able to offer either of these options.

One option for reducing the fee would be for licensees to apply to decrease their fee category given the reduction in gross gambling yield (GGY). Actioning this at the earliest opportunity will reduce the annual fee. You must submit the application as soon as possible and before the annual fee becomes payable.

You can use the fee calculator (opens in new tab) on our website to work out the reduced annual fee.

Operators may also wish to consider applying to make a change to their existing licence for example moving to a remote licence.

Given the uncertain nature of the length of this crisis, some operators may feel they have no option but to surrender their licence. If a licence is surrendered the annual fee will no longer be payable. To surrender a licence, email your Account Manager directly or send your email to licensing@gamblingcommission.gov.uk

Personal Licence holders – maintenance fees

If your maintenance fee is due for payment and you wish to retain your licence, please pay the fee online via the Manage your personal licence service (opens in new tab).

We know that many people have been temporarily or permanently laid off from their jobs because of this unprecedented situation. Should you choose to do so you can surrender your licence online using the link above and the maintenance fee will no longer be payable.

If a business or individual is not able to pay the fee, this will lead to the revocation of the licence.

Can I vary the terms of my licence?

An application to vary your licence can be made on the make changes to your licence (opens in new tab) page on our website.

A reminder for online operators

The social distancing measures that are being put in place will mean that more people will be at home and we would like to remind online operators that they must continue to act responsibly, especially in regards to individual customer affordability and increased social responsibility interactions.

As a reminder, we expect licensees to:

  • assess individual affordability on an ongoing basis – customers may be experiencing disrupted income. (Social Responsibility code 3.4 refers to our guidance - ‘Customer interaction- formal guidance for remote gambling operators’
  • increase social responsibility interactions and intervene where customers are showing signs of gambling-related harm
  • onboard new customers in a socially responsible way and not exploit the current situation for marketing purposes
  • refresh the information they have on customers regularly
  • review the levels which trigger interaction for AML and SR
  • ensure that your gambling products have been tested by a test house before they are released to the market.

You can read a letter sent by Chief Executive Neil McArthur to online operators on 25 March 2020.

Continuing our compliance assessments

We are continuing to undertake our compliance activity and assessments remotely.

Gambling Commission reminder to all licensed casinos: furloughed Nominated Officers

The Gambling Commission recognises the major impact the current unprecedented Covid-19 crisis is having on affected sectors with the closure of premises. We are aware you are facing uncertain and unsettling times and dealing with significant challenges impacting your businesses, your customers and your employees.

Following engagement with the Industry about an emerging risk, we appreciate that part of your management of these challenges may include the furloughing of your staff. The Commission would like to remind casino businesses that during this time, compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations continues to apply, particularly Regulation 21 regarding Nominated Officers. If operators are engaging in the furloughing of staff please ensure you notify the Commission of who will be undertaking Nominated Officer responsibilities within 14 days of any appointment changes through our key events portal.

See our website, specifically the AML hub, for further details.

How do Test Houses continue to meet their audit obligations if locations cannot be visited as normal?

If necessary, audits can be completed in two stages. The first stage can be conducted remotely, with all controls to be assessed. As part of this the auditor should make clear within the audit report the scope of the audit and the methods to be used (such as video conferencing, using tools such as Skype or Zoom) and the measures in place to mitigate any risks.

The second stage, and in addition to the first stage process, the auditor must provide assurances that an onsite visit will be conducted once travel restrictions are lifted. We would expect a report in the usual manner for the Commission to review and store on the account. When the next annual audit is due we will then compare both reports and review onsite inspection areas.

Delaying lottery draws as a result of Covid-19

Societies conducting raffles may feel that they need to delay the draw date – in which case they must take steps to notify the public of the new date. They should publish this fact to players by as many methods as reasonably practicable, such as a letter/email/phone call to supporters, placing information on their website and contact all those who have received tickets in the post or have already purchased tickets.

Can a lottery draw be conducted digitally instead if someone isn’t present physically to conduct the draw?

All societies must be able to demonstrate that the drawing of the lottery is conducted fairly and equally, and if requested, are able to demonstrate to the Commission that the draw was completely random. Society lottery operators should ensure they are familiar with the requirements before making any changes.

If I am running a small local authority-licensed society lottery, am I able to change the draw date due to current restrictions?

For small society lotteries, there is the requirement to have the draw date on the ticket or explanation of how the draw date will be determined. If a small society was to change the draw date, you are only required to ensure players are notified. You could also switch from non-remote to remote ticket sales without needing extra permissions, unlike Gambling Commission-licensed society lotteries where the appropriate licences must be held. A local authority registration permits both remote and non-remote sales.

Customer Interaction – additional guidance during Covid-19

This Covid-19 guidance builds on the Customer interaction - formal guidance for remote gambling operators that we published in July 2019, specifically Social Responsibility Code Provision 3.4.1. The following explains how to use this customer interaction guidance.

How to use the customer interaction guidance

The purpose of this guidance is to share knowledge based on research, current practice and lessons learned in order to support licensees in determining how they can meet the outcomes. It sets out why customer interaction is important and makes our expectations clear. Not all of the content of the guidance will be relevant to all operators, but licensees must take it into account and be able to demonstrate how they have done so.

How the Commission will use this guidance

For compliance and enforcement purposes, we will expect licensees to demonstrate how their policies, procedures and practices meet the required outcomes. This can be through implementing relevant parts of the guidance or demonstrating how and why implementing alternative solutions equally meet the outcomes.

Our understanding of gambling harms and how they manifest is constantly evolving, so for the purposes of raising standards, protecting consumer interests, and preventing harm to consumers, we will update and re-issue guidance where new evidence or risks emerge which may have a meaningful impact on how the outcomes can be met.

Based on our understanding of data relating to the present situation and the likelihood that some customers may be experiencing harms, we judge this additional guidance to be necessary to address the emerging risks.

Can you give further guidance on the expectations of interaction with customers who have been playing for an hour in a single session of play?

As part of their drive to make gambling as safe as possible, operators should be using all the information they know about a customer to determine the most suitable form of interaction. See also section 3 in Customer interaction - formal guidance for remote gambling operators titled ‘Interact’.

Are affordability assessments a new requirement?

The requirement to consider affordability is not new. Considering what a consumer can afford to spend is referenced within the July 2019 Guidance at 2.8 to 2.11.

Reverse withdrawals

If a consumer asks an operator to proceed with a reverse withdrawal, operators may find it beneficial to make it clear to customers that as of 31 May 2020 it is a regulatory requirement to prevent reverse withdrawals.

Does this require amendments to terms and conditions?

We do not require operators to alter their terms and conditions to include the suspension of reverse withdrawal but it may be sensible to consider user-friendly communications to ensure the message is delivered.

Bonuses and promotions

There is a requirement to cease to offer bonuses or promotions to all customers who are displaying indicators of harm. Should this just be applied to stopping the marketing itself or does it also extend to preventing the take up of bonuses by the customers displaying indicators of harm?

This applies to stopping direct marketing and preventing the take up of bonuses by consumers displaying indicators of harm.

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