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Guidance to licensing authorities

The Gambling Commission's guidance for licensing authorities.


3 - Access to premises

7.19. An issue that may arise when division of a premises is being considered is the nature of the unlicensed area from which a customer may access a licensed gambling premises. The precise nature of this public area will depend on the location and nature of the premises. Licensing authorities will need to consider whether the effect of any division is to create a machine shed-type environment with very large banks of machines, which is not the intention of the access conditions, or whether it creates a public environment with gambling facilities being made available.

7.20. The Gambling Act 2005 (Mandatory and Default Conditions) Regulations (SI 2007/1409 for England and Wales (opens in new tab) and SSI2007/266 for Scotland (opens in new tab)) set out the access provisions for each type of premises. The broad principle is that there can be no access from one licensed gambling premises to another, except between premises which allow access to those under the age of 18 and with the further exception that licensed betting premises may be accessed from other licensed betting premises. Under-18s can go into FECs, tracks, pubs and some bingo clubs, so access is allowed between these types of premises.

7.21. These Regulations define street as ‘including any bridge, road, lane, footway, subway, square, court, alley or passage (including passages through enclosed premises such as shopping malls) whether a thoroughfare or not’. This is to allow access through areas which the public might enter for purposes other than gambling, for example, access to casinos from hotel foyers.

7.22. There is no definition of ‘direct access’ in the Act or regulations, but licensing authorities may consider that there should be an area separating the premises concerned, for example a street or cafe, which the public go to for purposes other than gambling, for there to be no direct access.

7.23. The relevant access provisions for each premises type are as follows:

Type of premisesAccess provisions
  • the principal entrance to the premises must be from a ‘street’
  • no entrance to a casino must be from premises that are used wholly or mainly by children and/or young persons
  • no customer must be able to enter a casino directly from any other premises which holds a gambling premises licence
  • no customer must be able to access the premises directly from any other licensed gambling premises.
Betting shops
  • access must be from a ‘street’ or from other premises with a betting premises licence
  • no direct access from a betting shop to another premises used for the retail sale of merchandise or services. In effect there cannot be an entrance to a betting shop from a shop of any kind unless that shop is itself a licensed betting premises.
  • no customer must be able to access the premises directly from a casino or AGC.
Bingo premises
  • no customer must be able to access the premises directly from a casino, an AGC or a betting premises, other than a track.
  • no customer must be able to access the premises directly from a casino, an AGC or a betting premises, other than a track.

Access to gambling by children and young people

7.24. The Act contains the objective of ‘protecting children and other vulnerable persons from being harmed or exploited by gambling’ and sets outs offences at s.46 and s.47 of inviting, causing or permitting a child or young person to gamble, or to enter certain gambling premises. Children are defined in the Act as under-16s and young persons as 16 to 17 year olds. An adult is defined as 18 and over.

7.25. Children and young persons may take part in private and non-commercial betting and gaming, but the Act restricts the circumstances in which they may participate in gambling or be on premises where gambling is taking place as follows:

  • casinos are not permitted to admit anyone under 18
  • betting shops are not permitted to admit anyone under 18
  • bingo clubs may admit those under 18 but must have policies to ensure that they do not play bingo, or play category B or C machines that are restricted to those over 18
  • AGCs are not permitted to admit those under 18
  • FECs and premises with a liquor licence (for example pubs) can admit under- 18s, but they must not play category C machines which are restricted to those over 18
  • clubs with a club premises certificate can admit under-18s, but they must have policies to ensure those under 18 do not play machines other than category D machines
  • all tracks can admit under-18s, but they may only have access to gambling areas on days where races or other sporting events are taking place or are expected to take place. This was extended to other sporting venues under the Gambling Act 2005 (Exclusion of Children from Track Areas) Order 2007 (SI 2007/1410). Tracks will be required to have policies to ensure that under-18s do not participate in gambling other than on category D machines.

7.26. Licensing authorities should take particular care in considering applications for multiple licences for a building and those relating to a discrete part of a building used for other (non-gambling) purposes. In particular, they should be aware that entrances and exits from parts of a building covered by one or more licences should be separate and identifiable so that the separation of different premises is not compromised, and that people do not ‘drift’ into a gambling area. The plan of the premises should clearly denote entrances and exits.

7.27. For bingo and FEC premises, it is a mandatory condition that under-18s should not have access to areas where category B and C gaming machines are located, and this is achieved through default conditions that require the area to be:

  • separated from the rest of the premises by a physical barrier which is effective to prevent access other than by an entrance designed for that purpose
  • supervised at all times to ensure that under-18s do not enter the area, and supervised by either:
  • one or more persons whose responsibilities include ensuring that under- 18s do not enter the areas
  • CCTV monitored by one or more persons whose responsibilities include ensuring that under-18s do not enter the areas
  • arranged in a way that ensures that all parts of the area can be observed.

A notice must be displayed in a prominent place at the entrance to the area stating that no person under the age of 18 is permitted to enter the area.

7.28. Products made available for use in gambling premises will often contain imagery that might be of particular appeal to children or young people. For example, cartoon imagery that is ubiquitous on gaming machine livery. Where any such product is sited on age-restricted premises or in the age-restricted area of premises (and in particular, if sited close to the entrance or threshold and therefore visible to children or young people), licensees should consider whether it might risk inviting under 18s to enter the restricted area.

7.29. The LCCP requires licensees to ensure that their policies and procedures for preventing underage gambling take account of the structure and layout of their gambling premises. This therefore requires licensees not only to be able to supervise their premises but also that they should mitigate the risks of under 18s being attracted to enter premises by the products available within them. Where a licensing authority has concerns that such products are visible, they could for example require the licensee to re-site the products out of view.

7.30. There are a range of other conditions which attach to each type of premises which are set out in Part 9 of this guidance and other parts relating to each type of premises.

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