Guidance
LCCP Information requirements
Guidance for licence holders on the information requirements in the LCCP
5 - Key events (relevant persons and positions)
This section provides guidance to holders of gambling operating licences on how to tell us about key events which relate to relevant persons and positions within, or connected to, a gambling business.
It includes how to tell us:
- if any person or entity holds an interest of 5 percent or more of the licensee or, if applicable, the holding company of the licensee
- if the licensee takes out a loan from any person who is not authorised by the Financial Conduct Authority (opens in new tab) (or a company in the same group of companies as the licensee takes out such a loan and then makes an equivalent loan to the licensee)
- if the licensee appoints a person to a ‘key position’, or a person leaves a key position, or a person leaves a key position to take up another.
Key Event: Relevant persons
Key Event 2: Interests of 5 percent or more
Licence condition 15.2.1 (2)
Reporting key events - Relevant persons and positions
All operating licences
In the case of licensees who are companies, bodies corporate or other legal entities (but excluding society lottery licensees where stated), the name and address of any person or entity who (whether or not already a shareholder):
- becomes a shareholder holding 5 percent or more of the issued share capital of the licensee or its holding company; or
- controls 5 percent or more of the voting rights of the licensee or its holding company, excluding society lottery licensees; or
- is entitled to 5 percent or more of the dividends or profits of the licensee, excluding society lottery licenses
You must submit a key event report to us if any person or entity holds an interest of 5 percent or more in your business or, if applicable, your holding company. We ask for this information so that suitability, and, if applicable, source of funds checks can be carried out on all relevant persons associated with licensees and their holding companies.
An interest may be defined as a shareholding, voting rights or entitlement to profits depending on your business structure or that of your holding company. You should determine which is the most appropriate and complete measure to report to us based on your business structure and the information available in your jurisdiction. In most cases there will be no requirement to report under all measures, just the one that is the most appropriate to your own circumstances. In some cases you may have to report under more than one measure and some examples of this are included in the following Reporting Requirements for Different Business Structures paragraph.
If you have share capital or have a holding company with share capital, you must report the details of any person or entity who (whether or not already a shareholder) becomes a shareholder holding 5 percent or more of the issued share capital. If you are based in a jurisdiction which requires the reporting of beneficial ownership rather than share capital (for example, USA), we accept this as an appropriate alternative measure of interest.
In some companies with share capital, interests measured by share ownership may differ from interests measured by voting rights due to different classes of shares. If this applies to your company or holding company (and you have access to this information) you must also report the details of any additional person or entity who controls 5 percent or more of the voting rights, but does not necessarily hold 5 percent or more of the total share capital. This requirement does not apply to society lottery licensees. “Voting rights” in this context have the same meaning as paragraph 14 of Schedule 1A to the Companies Act 2006 (opens in new tab) .
If you (or your holding company) are a company limited by guarantee you must report the details of any person or entity who is deemed to control 5 percent or more of the voting rights. For example, if you have 20 members with equal voting rights, each member would be deemed to control 5 percent of the voting rights. This requirement does not apply to society lottery licensees.
If you are a partnership you must report the details of any person or entity who is entitled to 5 percent or more of the profits of your partnership. This requirement does not apply to society lottery licensees.
For ease of reference, we have summarised the requirements for different business structures in the following examples.
Company with share capital where each class of share carries the same voting rights such that one share equals one vote
Report details of each shareholder holding more than 5 percent of the share capital.
Company with share capital where shareholdings and voting rights diverge such that one share does not always equal one vote
Report details of each shareholder holding more than 5 percent of the total share capital plus any additional shareholders holding less than 5 percent of the share capital, but more than 5 percent of voting rights.
This information can be included in one key event.
This requirement does not apply to society lottery licensees.
Company Limited by Guarantee (CLG)
Report details of each member deemed to hold more than 5 percent of the voting rights. For example, if each member has one vote and your CLG has 20 members or less we require details for each member.
This requirement does not apply to society lottery licensees.
Ordinary Business Partnership, Limited Partnership or Limited Liability Partnership
Report details of each partner and/or member entitled to more than 5 percent of the profits of the partnership.
This requirement does not apply to society lottery licensees.
Please ensure you seek your own independent legal advice where necessary regarding the structure and reporting requirements.
You must report this within 5 working days of becoming aware of the event. This deadline takes into account that these events may not be in your knowledge at the time they happen (for example, publicly traded companies have to rely on public filings for information about shareholders) and there is no expectation that you undertake additional costly proactive investigations.
For a detailed explanation of the meaning of ‘holding company’ refer to the Companies Act 2006 (Section 1159) (opens in new tab). For ‘bodies corporate’ refer to the Companies Act 2006 (Section 1173(a)) (opens in new tab). For legal entities refer to the Companies Act 2006 (Part 21A Chapter 1 Section 790C) (opens in new tab). This requirement includes companies which are incorporated outside of the United Kingdom.
When reporting this key event, you must include the following information:
- the name of the person or entity
- the address of the person or entity
- the date of birth of the person (if relevant)
- the registration number of the entity
- the percentage interest that the person or entity holds
- whether the interest is in the share capital, voting rights or entitlement to profits
- whether the transaction relates to the purchase of newly issued shares or existing shares
- for newly issued shares, how much was paid for the shares.
All key events are to be reported to us via the key event section of the eServices digital service (opens in new tab) on our website. You must select the following type when entering this key event on eServices:
Key Event: Notification of shareholders or other relevant persons.
This reporting requirement applies to holders of all operating licences except society lottery licences where specified.
Note, you must either surrender your licence or apply for a new licence within 5 weeks of the change occurring if you are subject to a change of corporate control. This is when any person (or other legal entity) holds:
10 percent or more of the issued share capital of the licensee or its parent undertaking
10 percent or more of the voting power in the licensee or its parent undertaking
shares or voting power in the licensee or in a parent undertaking of the licensee as a result of which they are able to exercise significant influence over the management of the licensee or its parent undertaking.
Key Event: Non FCA Loans
Key Event 3: Taking out loans from persons not authorised by the Financial Conduct Authority
Licence condition 15.2.1 (3)
Reporting key events - Relevant persons and positions
All operating licences
The taking of any loan by the licensee, or by a group company who then makes an equivalent loan to the licensee, from any person not authorised by the Financial Conduct Authority: a copy of the loan agreement, if any, must be supplied.
You must submit a key event report to us if it takes out a loan from any person or entity who is not authorised by the Financial Conduct Authority (opens in new tab), or a company within your group of companies takes such a loan and then lends the funds to you, so that we can verify the source of funds and ensure that they are not derived from criminal proceeds.
A loan means the advancement of funds from one party to another for a period of time on the agreement that it will be repaid. Licence Condition 15.2.1 (3) applies whether or not the advancement of funds is formally called a loan and whether or not a written loan agreement exists. If money is given to a licensee, not as equity and not as revenue, and has not been forgiven or written off, it is functionally a loan.
Examples that could fall under the definition of non FCA loans include (but are not limited to):
- informal loans from shareholders and / or company directors
- payment in foreign currencies on behalf of the licensee by group entities
- informal cash transfers from group companies to the licensee for short-term working capital requirements
- drawdowns from an existing loan facility
- convertible notes
- debentures.
We have had a number of queries in recent years regarding the reporting status of transactions in directors’ loan accounts. A director's loan account is an accounting ledger typically used to record all transactions both to and from the director and the licensee. A transaction in the directors' loan account would be reportable if the money is given to you from a director not as equity and not as revenue, rather, to fund your daily operations (such as, due to cashflow difficulties or to fund a specific business project). This is so that we can satisfy ourselves that the source of such funds are not from criminal proceeds.
It should be noted that Licence Condition 15.2.1(3) also applies where funds from directors are credited elsewhere in your accounts, not just to the directors' loan account. Regardless of whether the money is classed in the accounting records as a 'loan', as an 'advance from a director', as a 'credit' to the director or using any other description. If it is functionally a loan, it is reportable.
For the avoidance of doubt the following transactions with directors are not notifiable under this key event:
- withdrawal of funds by the director from the company even if the withdrawal causes the loan account to become overdrawn
- minor day-to-day transactions, for example payment of a personal phone bill by the company on behalf of the director.
As regards intra group loans, the requirement is to report any loans that you receive into your business that originate from a non FCA regulated lender external to the group, irrespective of whether the funds flowed through other group companies first. However, you do not need to report loans received from group entities if the lender is ultimately funding the loan from its own existing cash reserves or from its operating activities, or from a loan from an external lender that is FCA regulated. In addition, there is no requirement to notify us of any borrowing by other entities in your group if the funds do not ultimately flow into your business (in whole or in part).
Under LCCP 15.2.1(3) you should report the “taking” of any loan. The Commission’s view is that this includes monies drawn down from an existing loan facility and therefore each separate drawdown should be reported as a key event. This is so that we can confirm that the source of funds for each drawdown. We often see loans drawdown over several years and the source of the later drawdowns differs from the borrower’s expectations of the source when the loan facility was initially arranged.
You must report within 5 working days of taking a non FCA loan.
A company in your group includes any subsidiary or holding company and any subsidiary of such holding company. For a detailed explanation of these terms, refer to the Companies Act 2006 (Section 1159) (opens in new tab).
Companies whose financial services activities are authorised by the Financial Conduct Authority are listed on the Financial Services Register (opens in new tab).
When reporting this key event, you should include the following information:
- the name of the lender(s)
- total amount of loan
- the amount of the drawdown and the total loan facility, if applicable
- date of receipt of the funds
- the reason(s) for the loan
- the lender’s source of funds for the loan
- what due diligence checks your company has carried out on the lender(s)
- if the loan involves crypto assets.
You must upload a signed copy of the loan agreement or contract, if any, when reporting this event.
All key events are to be reported to us via the key event part of the eServices digital service (opens in new tab) on our website. You must select the following type when entering this key event on eServices:
Key Event: Appointment of persons in key positions
This reporting requirement applies to holders of all operating licences.
Key Event 4: Appointment of persons in key positions
Licence condition 15.2.1 (4)
Reporting key events - Relevant persons and positions
All operating licences
The appointment of a person to, or a person ceasing to occupy, a ‘key position’ (including leaving one position to take up another). A ‘key position’ in relation to a licensee is:
in the case of a small-scale operator, a ‘qualifying position’ as defined in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006
in the case of an operator which is not a small-scale operator, a ‘specified management office’ as set out in (current) LCCP Licence condition 1.2
a position where the holder of which has overall responsibility for the licensee’s anti-money laundering and / or counter terrorist financing compliance and/or the reporting of known or suspected money laundering or terrorist financing activity
any other position for the time being designated by the Commission as a ‘key position’.
General
You must submit a key event report to us if you appoint a person to a ‘key position’, or a person leaves a key position, or a person leaves a key position to take up another.
For small-scale operators, a key position is a person occupying a ‘qualifying position’ as defined in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006 (opens in new tab).
For other gambling operators, a key position is any of the following:
a ‘specified management office’, as described in LCCP Licence condition 1.2.1
a position held by a person who has primary responsibility for making sure you meet requirements relating to preventing money laundering and the funding of terrorism, and for reporting known or suspected money laundering or funding of terrorism
any other position we designate as a ‘key position’ at any time. We will normally do this by attaching an extra condition to a company’s operating licence.
You must do this within 5 working days of you finding out about the event.
Reporting a person who has taken up a key position
If you are reporting a person who has taken up a key position, you should include the following information:
- the person’s name, address and date of birth
- the role the person is appointed to and the date of their appointment
- a summary of their role and primary responsibilities
- if the key position requires a Personal Management Licence
- if the person holds a Personal Management Licence, or has previously sent us an Annex A (opens in new tab)
- if the person does not hold a Personal Management Licence, or has not previously sent us an Annex A (opens in new tab), but requires one for their new position. In which case, tell us when they intend to apply for a licence or submit an Annex A. Include details of who is covering the position until we have processed the application
- if your company will be applying for an amendment to its licence (see following note if you are a small-scale operator).
Reporting a person who has left a key position
If you are reporting a person who has left a key position, you should include the following information:
- the person’s name, address and date of birth
- the role the person has stopped occupying and the date they left it
- if the company intends to replace that person and when. If a replacement is not being made, tell us who will cover that person’s responsibilities
- the arrangements the company has made to cover that person’s position until a replacement is recruited
- if your company needs to apply for an amendment to your licence (see note below if you are a small-scale operator)
- if the person has taken up a new key position (and the name of the new position).
Changes to persons in key anti-money laundering and counter-terrorist financing positions
For changes of persons in key positions relating to anti-money laundering and / or counter terrorist financing, in non-remote casinos, you must also upload documentary evidence of compliance with our guidance on The prevention of money laundering and combating the financing of terrorism (Paragraphs 5.2 and 5.12). For other licensees, evidence of compliance with our advice on Duties and responsibilities under the Proceeds of Crime Act 2002 (Paragraphs 20.7 and 20.15) must be provided.
Changes to persons in other designation key positions
We may have designated any other position as key for a licensee either through a condition attached to the operating licence or by letter to the licensee. If a person is appointed to this position or ceases to occupy this position, provide the same information as set out in the above section on reporting changes to persons in key positions.
All key events are to be reported to us via the key event part of the eServices digital service (opens in new tab) on our website. You must select one of the following types when entering this key event on eServices:
- Key Event: Key position – AML/TF__ (for changes to persons with primary responsibility for anti-money laundering and preventing terrorist financing)
- Key Event:Key position – manage't office__ (for changes to persons in a specified management office)
- Key Event:Key position – GC designated__ (for change to persons in any key position we designate as a ‘key position)
- Key Event:Key position – SSO__ (for changes to a person occupying a qualifying position in a Small-Scale Operator).
This reporting requirement applies to holders of all operating licences.
Note, if you are a small-scale operator reporting any of these events, you must also submit an application to vary your company’s existing operating licence, to update Schedule X of the licence.
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Last updated: 19 March 2026
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