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Guidance to licensing authorities

The Gambling Commission's guidance for licensing authorities.


5 - External lottery managers’ licence status

34.15. External lottery managers (ELMs) are required to hold a lottery operator’s licence issued by the Commission to promote a lottery on behalf of a licensed society.

34.16. However, individuals or firms can and do provide services to a society or local authority lottery without assuming the role of an ELM. When determining whether a third party is a ‘service provider’ only, or has assumed the role of an ELM, the degree of management undertaken by both the promoter and the sub-contractor will be crucial factors. Key indicators will include:

  • who decides how the lottery scheme will operate
  • who appoints and manages any sub-contractors
  • the banking arrangements for handling the proceeds of the lottery
  • who sells the tickets and pays the prizes
  • who controls promotional aspects of the lottery.

34.17. Societies employing an unlicensed ELM may be committing an offence and they will need to satisfy themselves that any ELM they employ holds the relevant operator’s licence issued by the Commission. The Commission publishes a register of operating licences.

34.18. Licensing authorities can refer those seeking further information on ELMs to the Commission’s website or its publication Promoting society and local authority lotteries advice note (opens in new tab) (the advice note does not form part of the Guidance to licensing authorities).

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