Business to business operators
As is the case with a B2C business, we have an interest in the financial risk of a B2B operator seeking a licence. Both in terms of ability to meet financial obligations and dependency on revenues derived from particular markets and in the probity of that business (including where a material proportion of revenue is likely to be from sources that we deem to be unacceptable).
B2B operators typically provide gambling software to one or more B2C businesses or other B2B operators. B2B operators may also provide facilities for gambling to one or more B2C as in the case of platform or network providers.
Some of the B2B and B2C operators contracting with the B2B operator applying for a licence will themselves provide facilities for gambling and/or gambling software to the British market. We have a strong interest in deterring those we license (either B2B or B2C) from supporting in any way those who compete illegally with licensed B2C operators servicing the British market.
B2B applicant must explain where revenue comes from by setting out approximately what proportion of revenue comes from:
- operators with point of consumption licences in jurisdictions other than Great Britain (such as France and Spain)
- Commission licensed operators
- other operators where the B2B applicant may be uncertain about the players’ locations.
We will ask how you decide with whom to deal (what process do you go through and what contractual constraints you impose on clients, for example, requiring operators to block players located in the US) and whether or not you implement any technological or other protections.
A licensing condition exists for all gambling software licences that the B2B operator undertakes to secure contractually with its B2C operator clients that any British based player accessing the network/platform does so via a Commission licensed B2C operator.
Any gambling software used by a remote operating licensee must be manufactured, supplied, installed or adapted by the holder of a gambling software licence.
We acknowledge that:
- some business models will not provide the B2B operator with the location of a player
- that technology tracking player location is not wholly effective, but the sort of licensing regime that a B2C operator is subject to may enable some inferences to be drawn. In such circumstances, there is also an increased importance placed on the B2B operator understanding the business of the B2C operator it supports.
Detailed information requirements for customer facing businesses
Last updated: 12 March 2021
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