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Regulatory returns guidance for ELMs

This is to help you prepare some of the key data that you are required to report within the regulatory return for an external lottery manager operating licence.

If you misrepresent or fail to reveal information that you are asked to provide, unless you have a reasonable excuse, you will have committed an offence under section 342 of the Gambling Act 2005. Anyone who provides information of a false or misleading nature risks prosecution.

After receipt of your completed regulatory return, we may still need to contact you for any further information we consider necessary in order to process your regulatory return.

Any information or material that is sent to us and which we record may be subject to the Freedom of Information Act 2000 (FOIA). Our policy on release of information is available on request or on our website.

We will handle confidential information accordingly and will only disclose that information to people outside the Commission where it is necessary to do so in order to carry out our functions or where we are required by law to disclose the information. As a public authority we must comply with the requirements of FOIA and must consider requests for information made under the Act on a case-by-case basis. 

All information provided will be processed in accordance with the Data Protection Act 2018. However, it may be disclosed to government departments or agencies, local authorities and other bodies when it is necessary to do so in order to carry out our functions and where we are legally required to do so. 

Operational information

Workforce information

As part of the Licence conditions and codes of practice (LCCP) operators are required to provide information on the range of gambling activities provided by the licensee and the number of staff employed in connection with them. This means all staff employed by the licensed entity, and therefore employed in the gambling industry.

We recognise that there are operators with only part of their business in the gambling field. Where this is the case we understand that the staff numbers relating to the licensed aspect of the business may need to be estimated for some staff in centralised or support functions.

Staff employed

Employee numbers should be reported at a date as near to the end of the period as possible, for each category listed, on both annual and quarterly regulatory returns. It may be most convenient to calculate this at the date of the last pay run in the reporting period.

Total number of employees    

Record the total number of employees. This is the number of individuals employed at a given time, irrespective of the hours they work. Count each person as one regardless of whether they work full time or part time. 

You must record a figure in this field. Record the total number of employees directly involved with the promotion of your lottery.

An employee is anyone that your organisation directly pays from its payroll(s). If you do not have any employees, eg your lottery is run by agency staff or self-employed workers, then populate this field with ‘zero’.

An employee is anyone that your organisation directly pays from its payroll(s), in return for carrying out a full time or part time job or being on a training scheme. This includes workers who are employed in relation to the licensed activity who are: 

  • paid directly from this business’s payroll
  • temporarily absent but still being paid, for example on maternity leave
  • furloughed on the Coronavirus Job Retention Scheme.

 Do not include: 

  • employees not employed in relation to the licensed activity
  • former employees only receiving a pension
  • self-employed workers
  • working owners who are not paid via PAYE
  • staff who are not directly employed (for example, agency staff) 
  • volunteers.

If employees work across a group, you should record them on the regulatory return for the licensed activity that uses most of their time. 


Complaints logged by the operator

Record the number of complaints that you have logged within the period covered by the regulatory return.

Our codes of practice require operators to log complaints made about any aspect of the conduct of the licensed activities, other than those that are resolved at the first stage of the operator’s complaints resolution procedure. This means that those complaints that are resolved very readily need not be recorded for the Commission. The number of complaints logged within the reporting period needs to be recorded irrespective of the outcome. 

A complaint is an expression of dissatisfaction made to the licensee about any aspect of the conduct of licensed activities. This means that complaints relating purely to commercial issues (such as the provision of non-lottery services) would not need to be logged, as they would not indicate a possible threat to the licensing objectives. Complaints logged may be directly about the outcome of the customer’s gambling or involve wider concerns about the way in which gambling is conducted by the operator. 

Complaints can be expressed orally or in writing and may occur in person, over the telephone, by letter, by email, or via online support. 

Disputes logged by the operator

Record the number of disputes that you have logged within the period covered by the regulatory return. 

Disputes are that subset of complaints which concern the outcome of the customer’s gambling transaction. They do not include wider concerns that may relate to the conduct of the gambling operation. As disputes are a subset of complaints, the number of disputes reported on the regulatory return will also be included in the count of complaints on the regulatory return. 

There is a separate requirement in the code of practice in the LCCP concerning those disputes that were referred to an independent party for resolution. In some sectors these disputes may sometimes be raised directly with the independent party, without the prior knowledge of the operator. The outcome of these ‘third party’ disputes must be notified to the Commission, which is a separate requirement to the regulatory returns. 

This flow chart explains which matters are counted as complaints and disputes and counted for the regulatory returns. 

reg returns flow

Disputes referred to an ADR

Record the number of disputes that you are aware have been referred to an ADR within the reporting period.

Self-exclusions made during this return period

Provide information regarding the number of self-exclusions made during the regulatory return reporting period.

This must not include restrictions made on individual products or timeouts which must be recorded separately below. This return is just in relation to your own self-exclusion scheme. Figures for participation in multi-operator schemes will be collected from the scheme administrator.   

Known breaches of self-exclusion

Record the number of times you know a player has breached their self-exclusion agreement. 

A player breaches their self-exclusion when they attempt to gain access to your facilities, attempt to gamble (for example, attempt to use an internet betting account following self-exclusion), or actually gambles. It is not limited to an attempt to gamble, and includes attempts to enter premises or access online gambling facilities. 

This must not include restrictions made on individual products or timeouts. This should include any breaches of either your own self-exclusion scheme or a multi-operator scheme.

Self-excluded individuals opting to return to gambling

Self-excluded customers can choose to return to gambling following the completion of their chosen length of self-exclusion. For the reporting period of the regulatory return record the number of individuals who have chosen to return to gambling once their self-exclusion period has ended.

We only expect you to report individuals who return to gambling within the time period that you are required to administer a return to gambling process and a 24-hour cooling-off period. So for remote operators we expect you to report any customers that return to gambling within 7 years of the end of their self-exclusion. For non-remote operators we expect you to report customers that return to gambling within 6 months of the end of their self-exclusion.

This must not include restrictions made on individual products or timeouts. This should include the number of players returning to gambling from either your own self-exclusion scheme or a multi-operator scheme.

People who having gambled were unable to verify their age

For the period relating to the regulatory return, you should record the number of people who, having gambled, were unable to prove they were 18 (or 16 for lotteries) when challenged.

For the purposes of the regulatory return, a person has gambled once they have inserted money into (or otherwise credited) a gaming machine, electronic gaming terminal or self-service betting terminal, bought in at a gaming table or completed a transaction over the counter. That transaction can include placing a bet or asking to load money on to a gaming machine. A person is unable to prove they are 18 (or 16 for lotteries) if they either provide identification which shows them to be underage, or do not provide any when challenged.  

You should not include incidents where a customer is challenged before they have been able to gamble, and is refused service because they are unable to prove they are 18 (or 16 for lotteries).

Incidents logged in the customer interaction log

Operators are required to implement policies and procedures for customer interaction where they have concerns that a customer’s behaviour may indicate problem gambling. This includes logging these customer interactions. You should record the total number of incidents on the customer interaction log for the period relating to the regulatory return.

A customer interaction is initiated by the operator, and is prompted by observed behaviour or activity by a customer, which may indicate problem gambling.  

A customer interaction can be carried out by a staff member, or for remote gambling could also be an automated interaction if this has been triggered by a customer’s activity. It may include providing information on responsible gambling, tools to help manage gambling, or signposting to sources of help or support. 

Your customer interaction log should be in a format that works for you. You could include the identity or other identifier of the customer involved, the behaviour or activity that prompted the interaction, the advice or support given, and the outcome of the interaction. 

You should only record here the number of customer interactions related to concerns that a customer’s behaviour may indicate problem gambling. You should not include general customer service communications, marketing, or requests for information for AML purposes.

Individuals included in the customer interaction log

You may carry out more than one customer interaction with each customer. Record the number of different people (customers) included in the customer interaction log for the period relating to the regulatory return. Even if you do not know someone’s full personal details we expect that you will be able to identify them in some way. 


Details of any contributions provided to organisations promoting socially responsible gambling research, education and treatment since submitting the previous return.

Are contributions made?

Select the appropriate option (yes/no). 

Also select yes if you have made a contribution in an earlier regulatory return period that also covers this regulatory return period – eg if you are completing a quarterly return but have previously provided details of an annual contribution. 

Use the 'Details of contribution' section to record the fact you have provided details of your contribution on an earlier regulatory return. Do not record the value of your contribution or the beneficiary again. 

Contribution via trade body 

If you are a trade association/body member and your contribution was made through them please select ‘Contribution via Trade Body’. You should also record the name of the trade association/body. 

Value of contribution (£) 

Record the value of your contribution. If you have apportioned your contribution across a number of sectors you should record the amount relevant to the licensed activity covered by the regulatory return. That is, if your business completes more than one regulatory return, your RET contribution should be divided between the different sectors and recorded in the relevant returns. Do not record the company’s total contribution in full on each regulatory return.  

Indicate the time period to which the contribution relates 

Provide details of the time period to which this contribution relates. For example, you might make a three-year grant in one year, and therefore make no contribution for the following two years. This should be recorded on the regulatory return that covers the period in which the contribution was made. Subsequent regulatory returns should indicate that a contribution was made and that details have previously been submitted. You should use this section of the regulatory return to record those details. 

Details of contribution

Enter details relating to the contribution. 

Lotteries managed 

List the societies you have managed lotteries for during the period applying to this regulatory return. 

Provide the names of the societies you have managed lotteries for.   

Record all societies licensed by the Gambling Commission and all those societies registered with a licensing authority. 

Financial information

Licensed lotteries

For Gambling Commission licensed society lotteries and licensing authority registered society lotteries, please record the total number of non-remote lotteries managed, the total number of remote lotteries managed and the total ticket sales/proceeds for each type of lottery managed.   

Where the ELM makes the arrangements for any part of the lottery they must only record the proportion of the proceeds of the lottery generated by the ELM’s activity. For example, if the ELM is ‘making arrangements’ in respect of one aspect of the lottery campaign such as direct mail, the ELM is only required to report the proceeds generated by that aspect of the lottery.  

ELM percentage 

For Gambling Commission licensed society lotteries and licensing authority registered society lotteries, provide the ELM’s management/service fee expressed as a percentage of the total lottery proceeds managed/generated by the ELM.

For example, if the total lottery proceeds managed/ generated by the ELM for Gambling Commission licensed society lotteries totals £100,000 and the ELM management fee for this amount is £10,000 then the ‘ELM percentage of total proceeds collected’ field would be populated with 10%.  

Lottery proceeds

For Gambling Commission licenced society lotteries and licensing authority societ lotteries, complete the table below showing annual proceeds split by product type.

Certification statement 

The certification statement needs to be signed by one key PML (individuals holding specified management offices). For small-scale operators, the person with control of the business should sign the certification. We would expect the signatories to make reasonable enquiries of the Board and other key staff who play a significant role in ensuring compliance with the operator’s licence conditions and codes of practice. 

The extent of reasonable enquiries may differ between sectors and size of business but the

Commission suggests that these should include:

  • referring to the current trading position and any financial projections that may exist and assessing whether there is a significant likelihood of the business experiencing financial difficulties
  • reviewing the adequacy of resources and arrangements (policies, systems and controls) in place to ensure compliance with licence conditions and codes of practice
  • enquiring of the Board and other PMLs whether they are aware of any factors or pending changes that may threaten the business’s ability to meet the licence conditions and codes of practice.

In signing the statement, we envisage that PMLs of larger entities will be able to draw on a number of sources of assurance, including:

  • Existing trading position
  • Financial projections
  • Results of compliance/internal audit/assurance work
  • Complaints information
  • External auditor’s report
  • Customer feedback surveys
  • Independent reviews/consultants’ reports.

For smaller entities, owners or managers will be more aware of all aspects of the business and will be able to use this knowledge to give the necessary assurances.

We are not seeking to underwrite the financial viability of operators and understand that unforeseen events (financial or otherwise) may arise which cause financial or other difficulties. As indicated above, we expect operators to make reasonable enquiries and to use the information they have to make sound judgements.

If you have any questions or queries relating to the completion of the regulatory return, then please contact us