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Principles

This advice is not comprehensive or a binding interpretation of the law and anyone intending to offer cross-gambling activities should refer to the Act and if necessary seek independent legal advice to ensure that they conform to the law before proceeding.

In considering a scenario where an ELM (or society) wishes also to offer gaming or betting activities the Commission considers that there is a risk to the licensing objectives, in particular ensuring that gambling is conducted in a fair and open way and protecting children and vulnerable adults from being harmed or exploited by gambling if players are not clear about the characteristics of the gambling being promoted. The Commission does, however, believe that those risks could be mitigated or removed if the following principles were applied when considering an application.

Licensees wishing to offer betting or casino products alongside lotteries should be advised that the following principles will be applied, which may be attached as conditions to their licence, if an application were to be granted.

The Licensee should only use the word “lottery” in relation to products that fall within the legal definition of a lottery and are being promoted in reliance on a lottery operating licence. Subject to that, the Licensee may offer lottery games and other forms of gambling via a single website, on associated web pages and under a single umbrella brand name, provided:

  • lottery games and other forms of gambling are offered on separate pages of the website
  • each web page makes it clear to players which type of gambling is being offered on that page
  • it is made clear on the home page that the licensed activities authorised by any casino or betting operating licence are only available to and accessible by players aged 18 and over
  • players must only be permitted to participate in gaming or betting (including 'try' or 'play for fun' activities) where they are registered to do so, and only after age verification has taken place.

The Licensee must ensure that any marketing material which expresses, or implies, an association with a lottery or lottery brand relates to lottery products only and not to any other type of facilities for gambling

The previously stated principles describe the Commission’s current position on lottery promoters who intend to offer lottery products alongside betting or gaming remote activities. The Commission’s intention is that these principles will be consulted on in the future with a view to incorporating them as a general condition on all relevant combined licences.

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Last updated: 13 April 2021

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