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Annex B: Key characteristics of bingo - Revised, January 2014


Following discussions with the Bingo Association and BACTA, the Gambling Commission published in June 2009 a list of characteristics, which it considered should be present in games, whether or not played by machine, in order for them to be classed as bingo. The Commission has recently reviewed and revised, and now republishes, this list.


The listed characteristics are particularly relevant to bingo machines, also known as video bingo terminals (VBTs). Machines that play bingo are exempt from limits on numbers, and stakes and prizes which apply to gaming machines. If these characteristics are not present it is likely that the Commission will view the machines as gaming machines and regulate them accordingly.


Manufacturers and operators should address these characteristics when developing bingo machines for bingo clubs, adult gaming centres (AGCs) and family entertainment centres (FECs) and should also note that the Commission has concerns about potential access to these machines by children and young people (those under the age of 18). At this stage we do not intend to introduce licence conditions restricting this product to over 18s in those premises that are not age restricted, as the industry has agreed to the following characteristics. However, the options to do so remains open to the Commission should issues arise.


The Commission will continue to monitor the development of bingo machines with a view to a decision, in the longer term, whether it is necessary to incorporate the characteristics in our Technical Standards, Equipment Technical Requirements and/or Licence Conditions and Codes of Practice. In the meantime, we note that both the Bingo Association and BACTA have communicated these characteristics to their members by way of a Code of Practice.


In the following list, any reference to ‘game’ or ‘games’ means a game or games of bingo.

Key characteristics of bingo

  • Players’ payments must be divided between stakes and participation fees, although they may consist entirely of stake or entirely of participation fee.
  • The way that division is made must be transparent to the player and in particular there must be a notice displayed showing participation fees in a way that makes it readily accessible to players. Any stakes must be returned to players, either in the particular game or in a subsequent one.
  • Each game must be played to a single set of numbers, or symbols; drawing a second set starts a new game.
  • Any game formats must clearly be presented as offering the player the opportunity to participate in a game of bingo. This includes numbers (or symbols) being marked off and the game having the appearance of a game of bingo (rather than a gaming machine).
  • Any ‘added prize money’ stated to be available in a game, once offered (and unless the offer is specifically limited in time), must remain available until won in that or subsequent games, that is: by way of rollover; the operator cannot claim them back. Prizes clearly advertised as being offered only for a limited period can be claimed back if they are not won. All prizes offered in each game must be transparent to the player.
  • Games may operate with a single player, provided there is a meaningful opportunity for other players to participate in the same game.
  • The game must comply with the requirements of the Gambling Act 2005 and must be capable of audit, where appropriate, to demonstrate legal compliance. Such audit data will demonstrate for example how players’ payments are split between stakes and participation fees and that all stakes are returned to the players, either in that game or subsequent games.

Characteristics specific to bingo machines

  • The speed of game, including the time taken to join, should be similar to that of an interval game. Games must not have an auto play function.
  • The machines must provide a facility for the player to extend the playing time by a minimum of 100%.
  • The amount that can be staked in a set period should be no greater than on a Category C machine.

Regulations specific to bingo machines in AGCs/FECs

  • the nature or size of the prize offered may not be determined by the number of persons playing; or the amount paid for or raised by the game
  • bingo machines in FECs will not be made available in areas where children and young people (those under the age of 18) are permitted.


1 Gambling Act 2005 section 288 (opens in a new tab) – Meaning of ‘prize gaming’ Gaming is prize gaming for the purposes of this Act if neither the nature nor the size of a prize played for is determined by reference to:
(a) The number of people playing
(b) The amount paid for or raised by the gaming.
2The 2005 Act’s definition of a stake is: ‘an amount paid or risked in connection with gambling and which either
(a) is used in calculating the amount of winnings or value of the prize that the person making the stake receives if successful
(b) is used in calculating the total amount of winnings or value of the prizes in respect of the gambling in which the person making the stake participates.’
3Case law establishes that the fact that a player in bingo may purchase more than one card does not make the chances unequal as between players; such a player will have paid for two or more chances to win and not a chance to win two or more times what another player can win.

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Annex A: Banker’s games and equal chance gaming - January 2014
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