Guidance
Guidance to licensing authorities
The Gambling Commission's guidance for licensing authorities.
Contents
- Changes to the Guidance for Licensing Authorities
- Part 1: General guidance on the role and responsibilities of licensing authorities in gambling regulation
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- Introduction
- Partnership working between the Commission and licensing authorities – shared regulation
- Co-ordination and contact
- Primary legislation
- Statutory aim to permit gambling
- The licensing objectives
- Codes of practice
- Licensing authority discretion (s.153 of the Act)
- Local risk assessments
- Licensing authority policy statement
- Limits on licensing authority discretion
- Other powers
- Part 2: The licensing framework
- Part 3: The Gambling Commission
- Part 4: Licensing authorities
- Part 5: Principles to be applied by licensing authorities
- Part 6: Licensing authority policy statement
- Part 7: Premises licences
- Part 8: Responsible authorities and interested parties definitions
- Part 9: Premises licence conditions
- Part 10: Review of premises licence by licensing authority
- Part 11: Provisional statements
- Part 12: Rights of appeal and judicial review
- Part 13: Information exchange
- Part 14: Temporary use notices
- Part 15: Occasional use notices
- Part 16: Gaming machines
- Part 17: Casinos
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- Casino premises
- Casino games
- Protection of children and young persons
- The process for issuing casino premises licences
- Resolutions not to issue casino licences
- Converted casinos (with preserved rights under Schedule 18 of the Act)
- Casino premises licence conditions
- Mandatory conditions – small casino premises licences
- Mandatory conditions – converted casino premises licences
- Default conditions attaching to all casino premises licences
- Self-exclusion
- Part 18: Bingo
- Part 19: Betting premises
- Part 20: Tracks
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- Definition of a track
- Track premises licences – differences from other premises licences
- Betting on tracks
- Licences and other permissions for the provision of betting facilities
- Betting on event and non-event days
- Social responsibility considerations for tracks
- Gaming machines
- Self-service betting terminals (SSBTs)
- Applications
- Licence conditions and requirements
- Part 21: Adult gaming centres
- Part 22: Licensed family entertainment centres
- Part 23: Introduction to permits
- Part 24: Unlicensed family entertainment centres
- Part 25: Clubs
- Part 26: Premises licensed to sell alcohol
- Part 27: Prize gaming and prize gaming permits
- Part 28: Non-commercial and private gaming, betting and lotteries
- Part 29: Poker
- Part 30: Travelling fairs
- Part 31: Crown immunity and excluded premises
- Part 32: Territorial application of the Gambling Act 2005
- Part 33: Door supervision
- Part 34: Small society lotteries
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- Small society lotteries
- The status of lotteries under the Act
- Licensing authority guidance
- Social responsibility
- External lottery managers’ licence status
- Lottery tickets
- Prizes
- Specific offences in relation to lotteries
- Application and registration process for small society lotteries
- Administration and returns
- Part 35: Chain gift schemes
- Part 36: Compliance and enforcement matters
- Appendix A: Summary of machine provisions by premises
- Appendix B: Summary of gaming machine categories and entitlements
- Appendix C: Summary of gaming entitlements for clubs and alcohol-licensed premises
- Appendix D: Summary of offences under the Gambling Act 2005
- Appendix E: Summary of statutory application forms and notices
- Appendix F: Inspection powers
- Appendix G: Licensing authority delegations
- Appendix H: Poker games and prizes
- Appendix I: Glossary of terms
Our position
We will proceed with a ban on the use of credit cards for online gambling. We stated in the consultation (opens in new tab) that we were persuaded there are risks of harm associated with using credit cards for gambling, and the consultation therefore explored what action should be taken to protect consumers and minimise those risks, rather than whether any action should be taken. We have concluded that gambling with credit cards is not reasonably consistent with the licensing objectives of the Gambling Act, and the consultation produced no compelling evidence to dissuade us from intervention.
The data gathered from our call for evidence indicates that:
- Credit cards are disproportionately used for gambling by individuals who are experiencing harm (among online gamblers who participated in our tracker survey, 22% of credit card gamblers were problem gamblers, 25% were experiencing moderate levels of harm and 20% lower levels of harm).
- Credit cards are used for online gambling in a manner that could exacerbate harm. Data indicates that individuals are generally making gambling deposits via credit card over several transactions per month, meaning that cash advance fees will exacerbate their total debt. A number of credit card gamblers advised that the cash advance fees do not deter them from using credit cards for gambling, rather that they will chase larger wins to try to recoup the costs of using such cards.
- Credit cards act as a convenient and relatively frictionless form of using borrowed money to fund online gambling.
- The cumulative debt exposure from multiple credit cards can be much more than the user can afford to repay.
New research undertaken by 2CV during the consultation among 475 credit card gamblers also demonstrates that credit card gambling is disproportionately associated with those who may be at higher risk of harm:
- half of credit card gamblers have a strong potential to encounter harm when gambling
- credit card gamblers tend to demonstrate a lower awareness of the risks of gambling; however, they also tend to be highly engaged gamblers for whom credit card use to fund gambling is often embedded and habitual
- credit card gamblers with a higher potential to experience harm tend to deposit larger sums for gambling, and make more gambling transactions, via credit cards than those with a lower potential
- while most credit card gamblers in the research were not fully aware of the costs of using credit cards to fund gambling (that is, cash advance fees and often higher interest rates), those with a higher potential to experience harm were less likely to be deterred by such fees.
Some operators and financial services challenged that a ban on credit cards would not address the underlying causes of harm. We agree that gambling harm is often multi-faceted as it can manifest as various different types of harm for both the individual gambler and his or her family, and can manifest alongside other harms not directly related to gambling such as financial hardship caused by other circumstances. A ban on credit card gambling does not seek to address those wider complexities.
However, we expect it to be a measure that will reduce the risks of harm to many consumers by preventing them from gambling more than they can afford to repay; or at the very least, it will add levels of friction to the process of gambling with borrowed money such that the rate of financial loss is slowed down and harm is potentially curtailed. Consultation feedback demonstrates that it is not only credit card gamblers who are exposed to these risks but their family members also.
We are not persuaded that the loss of ‘credit card use’ as a variable in operators’ risk detection algorithms is an adequate reason to continue to permit credit cards for online gambling. That is, given the strong association between credit card gambling and harm, it would not be appropriate to continue to permit credit cards simply to enable operators to monitor their use as a basis for possible customer interaction. We note in any case that operators have not typically included ‘credit card use’ as part of their harm prevention models, rather they have tended to use the ‘number of payment methods’ on the customer account as a marker of harm.
Last updated: 14 November 2024
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