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Guidance to licensing authorities

The Gambling Commission's guidance for licensing authorities.


4 - Multiple activity premises – layout and access

7.31. With the exception of bingo clubs, tracks on race-days and licensed FECs, children will not be permitted to enter licensed gambling premises. Therefore, businesses will need to consider carefully how they wish to configure their buildings if they are seeking to develop multi-purpose sites.

7.32. Licensing authorities should take particular care in considering applications for multiple premises 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 of the following:

  • the third licensing objective seeks to protect children from being harmed or exploited by gambling and premises should be configured so that children are prohibited from participating in gambling, such that they are not invited to participate in, have accidental access to, or closely observe gambling
  • entrances to and exits from parts of a building covered by one or more premises licences should be separate and identifiable so that the separation of different premises is not compromised, and people do not ‘drift’ into a gambling area. In this context it should normally be possible to access the premises without going through another licensed premises or premises with a permit
  • customers should be able to participate in the activity named on the premises licence.

7.33. In determining whether two or more proposed premises are truly separate, the licensing authority should consider factors which could assist them in making their decision, including:

  • is a separate registration for business rates in place for the premises?
  • is the premises' neighbouring premises owned by the same person or someone else?
  • can each of the premises be accessed from the street or a public passageway?
  • can the premises only be accessed from any other gambling premises?

The Commission has published guidance to assist licensing authority officers when considering applications for, and conducting inspections of, multi-activity premises (this guide does not form part of the Guidance to licensing authorities).

7.34. Where a building consists of a number of areas which hold separate premises licences, each individual licence must not exceed its permitted gaming machine entitlement. The position is different for tracks, as detailed in Part 20 of this guidance.

7.35. The proper application of s.152 means that different premises licences cannot apply in respect of single premises at different times. There is no temporal element to a premises licence. Therefore, premises could not, for example, be licensed as a bingo club on weekdays and a betting shop at weekends.

Single and combined licences

7.36. Only one premises licence may be issued for any particular premises at any time although, in some circumstances, the licence may authorise more than one type of gambling. For example, a bingo licence will also authorise the provision of gaming machines. Details of the gambling permissible under each type of licence are set out in the Act and in the premises specific parts of this guidance.

7.37. The exception to this relates to tracks, that is a horse racing course, dog track or other premises where races or sporting events take place, which may be subject to more than one premises licence, provided each licence relates to a specified area of the track.

7.38. The Act sets out that there will be a main (betting premises) licence for the track, and, in addition, subsidiary premises licences for other gambling activities may be issued. The normal limitations in respect of access by children and young persons will apply, although in relation to a premises licence for a track, children and young persons will be permitted to enter track areas where facilities for betting are provided on days when dog racing and/or horse racing takes place. This is subject to the rule that children and young persons may not enter any area where gaming machines (other than category D machines) are provided.

7.39. In principle there is no reason why multiple types of gambling should not co-exist on a track (with the exception of a casino or AGC, because of the access restrictions placed on tracks by Schedule 6, Part 1 of the Gambling Act 2005 (Mandatory and Default Conditions) Regulations, but licensing authorities will want to think about how the third licensing objective is delivered by the co-location of premises. As with the granting of multiple licences in a single building, licensing authorities will need to ensure that entrances to each type of premises are distinct and that under-18s are excluded from gambling areas where they are not permitted to enter.

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