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Guidance to licensing authorities

The Gambling Commission's guidance for licensing authorities.


5 - Self-service betting terminals (SSBTs)

19.7. S.235(2)(c) provides that a machine is not a gaming machine if it is designed or adapted for use to bet on future real events. Some betting premises may make available machines that accept bets on live events, such as horse racing, as a substitute for placing a bet over the counter. These SSBTs are not gaming machines and therefore neither count towards the maximum permitted number of gaming machines, nor have to comply with any stake or prize limits. SSBTs merely automate the process that can be conducted in person and the Act exempts them from regulation as a gaming machine.

19.8. However, where a machine is made available to take bets on virtual races (that is, results and/or images generated by computer to resemble races or other events) that machine is a gaming machine and counts towards the maximum permitted number of gaming machines and must meet the relevant category limitations for the premises.

19.9. It is the Commission’s view that the use of SSBTs is a form of remote communication and that a remote licence will be required if SSBTs are used to facilitate the making or accepting of bets by others. The advice note Betting: advice for remote, non-remote and betting intermediaries (this advice note does not form part of the Guidance to licensing authorities) sets out the framework which the Commission applies when deciding whether it considers that a particular operator is offering betting or is acting as a betting intermediary and whether gambling is remote gambling or non-remote gambling.

19.10. S.181 contains an express power for licensing authorities to restrict the number of SSBTs, their nature and the circumstances in which they are made available by attaching a licence condition to a betting premises licence or to a casino premises licence (where betting is permitted in the casino). When considering whether to impose a condition to restrict the number of SSBTs in particular premises, the licensing authority, amongst other things, should take into account the ability of employees to monitor the use of the machines by children and young persons or by vulnerable people.

19.11. Where SSBTs include the functionality to be marketed or presented in foreign languages, licensing authorities may seek to ensure that the operator has considered the ordinary code provision (3.3.2) about making the following information also available in those languages:

  • the information on how to gamble responsibly and access to help referred to in the LCCP
  • the players’ guides to any game, bet or lottery required to be made available to customers under provisions in LCCP
  • the summary of the contractual terms on which gambling is offered, which is required to be provided to customers as a condition of the licensee’s operating licence.
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