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Small businesses and sole traders

17 May 2021
9 June 2021

We call businesses with 3 people or less in relevant management positions small scale operators.

Relevant management positions include:

  • overall strategy and delivery of gambling operations
  • financial planning, control and budgeting
  • marketing and commercial development
  • regulatory compliance
  • gambling-related IT provision and security
  • management of licensed activity for a particular area in Great Britain where you have five or more sets of premises for which you hold a premises licence
  • management of a single set of bingo and/or casino licensed premises.
  • nominated officer for anti-money laundering and associated purposes for a casino operator.

A small scale operator may not need to have a personal management licence (PML) holder.

If you qualify as a small-scale operator, you will need to submit an operating licence application with details of anyone in these positions.

The named people in the relevant management positions will each need submit an Annex A personal declaration along with all of the supporting documents for their application, instead of a PML application. This will make them a named person on Schedule X of your operating licence.

Society lotteries

Small scale operators running society lotteries must at all times have a named person with responsibility for promotion of the lottery. This named person needs to be:

  • a member, officer, or employee of the society (not an external lottery manager)
  • approved by the Gambling Commission
  • listed on Schedule X of the lottery operating licence.

Although having just one named person is sufficient to meet the legal requirements, we recommend having more than one named person. This will reduce the risk of having to suspend your lottery should you find yourself without a named person.


We would not normally expect those that are applying for a non-remote or remote casino licences to be small scale operators.

If you think that you qualify for this exemption, you need to be able to demonstrate that those occupying relevant management positions can:

  • uphold the licensing objectives
  • adhere to licence conditions and codes of practice
  • manage the particular risks of casino operation effectively with the reduced numbers of relevant people.

It is our view that it would be difficult for any casino operator to satisfy our requirements with only three people in these positions. We would normally expect these businesses to have more than three people occupying these positions and that those individuals will need to have PMLs.

If you believe you can demonstrate effective management and control with just three people, you must explain this clearly with your application and provide relevant supporting evidence to demonstrate that this is the case.

Next page
Adding or removing a named person from your licence (Schedule X)
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