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Acting as supporting regulator under Primary Authority

Primary authority partnerships on age verification in gambling and the role of the supporting regulator

Preventing underage gambling 

Gambling businesses must have policies to prevent underage gambling and monitor their effectiveness. These policies should include: 

  • checking the age of customers who appear to be, or are suspected of being, underage
  • not deliberately providing facilities for gambling in such a way as to appeal particularly to children and young people, for example by reflecting or being associated with youth culture
  • in premises restricted to adults, refusing service in circumstances where an adult is accompanied by a baby, child or young person.

In keeping with our licensing, enforcement and compliance policy statement, we will continue to provide advice to all operators in relation to age verification. Similarly we will continue to provide age verification advice to licensing authorities through the Guidance to Licensing Authorities.

Primary Authority and underage gambling

Primary Authority offers businesses the opportunity to form a legally recognised partnership with one local authority. The authority can provide advice to that business, or to other local authorities. This advice is often referred to as ‘assured advice’ because, with the back-up of the statutory scheme, local regulators are expected to accept that if the business is following that advice it is meeting its regulatory responsibilities. Businesses might seek this advice if they want reassurance that they will not face local inconsistency.   

Since 2013 Primary Authority has included prevention of underage gambling and age verification. Some gambling businesses have Primary Authority agreements where they receive assured advice. Others have gone a step further and agreed a ‘national inspection strategy’ that sets out arrangements for a minimum number of underage test purchase exercises to be done in the premises of that business during the lifetime of the agreement.     

We have worked with the Primary Authorities that cover gambling and provided informal guidance and advice on the content and consistency of their national inspection strategies. This is because those strategies can provide helpful support to the testing programmes required of businesses under the Licence conditions and codes of practice.  We have not reviewed or approved any of the assured advice produced to date.

We do not ‘endorse’ an operator’s approach to compliance. For this reason, under the Primary Authority scheme we do not provide ‘assured advice’. It is the operator’s responsibility to manage their business in line with legal and regulatory requirements.

Supporting regulator 

The Government has made various changes to the Primary Authority scheme that came into force from 1 October 2017. They enable national regulators to be specified as ‘supporting regulators’, meaning they can have a statutory role in Primary Authority partnerships. Supporting regulators can support Primary Authorities as they develop advice and guidance for businesses. 

As a supporting regulator, we will continue to participate in Primary Authority schemes as we do now, free of charge and can advise on national inspection strategies, in addition to our broader role of providing advice to licensing authorities. 

We will handle any application to be designated as a formal supporting regulator for this area on a case by case basis. This may involve a fee if the application leads to a formalised supporting regulator agreement. 

If you are a Primary Authority or business in a Primary Authority scheme who wishes to discuss our potential involvement as a supporting regulator please contact us at: