What you need to send us when you apply for an operating licence
These are the supporting documents you will need for your application for an operating licence for your gambling business. If you are applying for non-remote and remote licences then both columns will apply.
Annual reports
Criteria
Any quarterly, semi-annual or annual reports you have lodged with any government authority or regulator in the past five years.
Annual returns
Criteria
All annual returns you have provided to any regulator for the past five years.
This includes:
- annual returns to any tax authority
- annual returns to Companies House or overseas equivalent
- annual returns to the Charity Commission or overseas equivalent.
Audited accounts
Criteria
If your business is a limited company that has already been trading for a year. Audited accounts should also be provided for any parent and/or holding company.
Bank statements
Criteria
For all businesses
Bank statements for all accounts operated by your business for the last six months. These must be in the name of the applicant and show sort code and International Bank Account Number (IBAN) Business Identifier Code.
For new businesses not yet operating bank accounts. If part of a larger corporate structure, bank statements of the parent company for the last six months.
Bonus and profit sharing schemes
Criteria
Details of any bonus schemes, profit sharing arrangements, pension schemes, retirement schemes, deferred compensation arrangements and similar plans you operate for any employees. You must include:
- the name and specifications of each scheme
- the trustee of each scheme where applicable
- the full terms and conditions of each scheme
- what type of employee and/or individual each scheme is available to
- what criteria an employee and/or individual must meet to qualify for each scheme.
Business Plan
Criteria
For small businesses
We consider that for these purposes a small business is one that satisfies our definition of a Small Scale Operator. A brief document that sets out the reason for the licence application, the activities that will be undertaken, how the business is being funded, where the business will operate, the medium term goals of the business and how success will be measured.
For medium to large businesses
A detailed document that includes:
- organisational background
- details of facilities to be provided
- marketing plan
- financial plan
- risk evaluation and risk management plan
- governance and management framework
- legal framework in which the business is operating
- business objectives for the next 12 months
- success criteria
- any other relevant information.
Certificate of incorporation
Criteria
If your business is a limited company.
Compliance with remote technical standard (RTS)
Remote (Online)Criteria
Written policies and procedures detailing how you will comply with the remote gambling and software technical standards (RTS).
Constitution
Criteria
If they exist for your business, any constitution or constitutional documents. These are documents which define the existence of the entity and regulate the structure and control of the entity and its members.
Credit report
Criteria
If your business is a limited company based outside the United Kingdom
If your business is based outside the United Kingdom you will need to send personal credit reports for all partners or key persons.
Existing licences
Criteria
Copies of existing gambling-related licences if your business is already licensed outside Great Britain. If applications are in progress in jurisdictions outside GB but not yet completed please provide details.
Forecasts
Criteria
For small businesses
We consider that for these purposes a small business is one that satisfies our definition of a Small Scale Operator. A 12 month profit/loss forecast including a commentary on the assumptions that have been made in creating the forecast.
For medium to large businesses
A three year profit and/or loss forecast including a commentary on the assumptions that have been made in creating the forecast.
Gambling software supply details
Remote (Online)Criteria
The name, address and licence number of all of the organisations who provide gambling software to the Applicant. Third party suppliers of software for use in the provision of gambling facilities to customers in Great Britain must be licensed by the Gambling Commission. You may include this in the operational model map so this does not have to be a separate document.
If you are applying for a gambling software licence, you must supply policies and procedures detailing how the business supplies gambling software via remote communication (for example File Transfer Protocol, server downloads). You may include this in the operational model map so this does not have to be a separate document.
Group structure chart
Criteria
If your business is a limited company and is part of a larger corporate structure. The chart should show all the companies within the group structure and demonstrate the nature of the link and the percentage of holdings. With a complicated group structure a commentary should also be provided in the business plan.
Individual identity documents
Criteria
If you are a sole trader, you must provide personal identity documents.
Individual's compensation
Criteria
A list of individuals you have compensated more than USD$250,000 (or GBP £200,000) in the last financial year.
Compensation refers to dividends, bonuses, salaries, employee contract benefits/arrangements or any other remuneration.
The list must include:
- the full name of the individual
- the amount of compensation they received during the last financial year
- what form the compensation took
- the reason the compensation was paid; the date the compensation started
- the date it ended or is due to end
- any terms or conditions of the compensation.
Insolvency, administration and or liquidation reports
Criteria
Any insolvency, administration or liquidation reports relating to the business (or any parent or sister or subsidiary company of the business).
Loan agreements
Criteria
For small businesses
We consider that for these purposes a small business is one that satisfies our definition of a Small Scale Operator. For sole proprietors and partnerships, if a loan has been obtained to fund the business provide a copy of the loan agreement.
For all other businesses, provide copies of all loan agreements linked to the company.
For medium to large businesses
For all limited businesses, provide copies of all loan agreements linked to the business.
Management structure
Criteria
The structure should show all key management positions and who occupies them.
Memorandum of association and articles of association
Criteria
If your business is a limited company.
Operational model map
Remote (Online)Criteria
An operational model map which shows the location and provider and/or operator of all systems and activities used by the business to deliver gambling services and facilities.
The diagram needs to show the location of key equipment, and the relationship between the systems, activities, and third party providers, including how they interact and/or link together.
Ownership structure
Criteria
For all businesses
The chart should show who has a financial interest in the business. Anyone with a 3 percent equity or more in the company must be named and the percentage of their holding shown. Anyone with a 10 percent or more equity is a financial controller and must submit an Annex A or, if responsible for a key management function, a personal licence application.
For medium to large businesses
If the business is part of a larger corporate structure it is acceptable to provide a single chart to show the group structure and the ownership structure. With a complicated ownership structure a commentary should also be provided in the business plan.
Partnership agreement
Criteria
If your business is a partnership.
Policies and procedures
Criteria
Written policies and procedures that explain how the business will meet the following licensing objectives in regard to all the activities applied for:
- keeping crime and disorder out of gambling
- ensuring that gambling is fair and open
- ensuring that children and vulnerable people are protected from being harmed by gambling
- promoting social responsibility in gambling.
The policies must cover all Licence Conditions and Codes of Practice that will apply to the business if a licence is granted and must specifically include a complaints procedure and who will be the ADR for the business, the self-exclusion procedure, how the business will keep up-to-date with any changes to LCCP and legislation and, for premises-based businesses, evidence of a local risk assessment.
Submitting an industry trade body toolkit is not evidence by itself that you have satisfactory policies. You must demonstrate how you will be implementing the procedures in the toolkit specifically for your business.
Businesses providing remote casino, bingo and virtual event betting and/or non-remote casinos must provide an anti-money laundering policy.
For medium to large businesses
The policies should be supported wherever possible by process maps/flow diagrams which show how they will work in practice, where the escalation and decision points are, who is responsible for making those decisions and what their role in the business is. They should highlight any potential risks to the licensing objectives and the business and detail how these risks will be managed and mitigated.
All businesses (except gaming machine technical and gambling software licences) must conduct a money laundering and terrorist financing risk assessment, which should then be used to inform the operator’s associated policies, procedures and controls. Operators must assess and effectively manage the money laundering and terrorist financing risks applicable to their business, and the responsibility for this lies with the licensed operator, who is accountable for any shortcomings.
Public debt and or equity offerings
Criteria
Documents relating to any public debt or equity offerings you have lodged in the past 12 months.
Rules of play
Criteria
Provide copies of the rules of play for the gambling being offered (where applicable).
Source of funds evidence
Criteria
This is a general overview of when and what source of funds evidence is required, but we assess each application on a case-by-case basis according to risk so the type and level of evidence may differ between applications.
We consider there are three main categories of funding:
- from unregulated entities or individuals
- from regulated banks or investment companies
- from regulated banks or investment companies acting as an intermediary for an investor or pool of investors.
Regulated means by the Financial Conduct Authority (FCA) in the United Kingdom (UK) and FCA equivalent in other jurisdictions, for example the United States equivalent would be the Securities and Exchange Commission (SEC).
We would not normally require source of funds evidence in relation to the origin of monies when an operator takes out a loan from a UK regulated bank, but if an investor borrows from a UK regulated bank to invest in an operator, we will normally undertake source of funds checks on the period when the monies were in the investor’s control. If any bank is buying shares in the operator, we will undertake source of funds checks on the bank, as explained on this page.
Funding from unregulated individuals
These are typically private investors who are investing their own money. We require source of funds evidence if the individual has provided £50,000 (or equivalent in foreign currency) or more of the funding for the acquisition or ongoing investment. Evidence of the individual’s source of funds will depend on what the source of funds is but examples include bank statements, investment portfolio statements and P60s.
Funding from unregulated entities
These investors are typically entities that are using their own money to fund the investment. For these investors we need to know when they were created or incorporated, what jurisdiction they are registered in and we require source of funds evidence if they have been:
- created or incorporated for more than 12 months at the date of investment and invest £1,000,000 (or equivalent in foreign currency) or more; or
- created or incorporated for less than 12 months at the date of investment and invested any amount.
Typically for established entities the latest set of filed financial statements can be sufficient evidence. For recently established entities, evidence of how the entity has been funded is required.
Funding from regulated banks or investment companies
These investors are regulated banks or entities investing their own money. When we consider what type of source of funds evidence is required, we group these investors into two categories – FCA regulated and overseas equivalent regulated.
For FCA regulated entities, we require its FCA reference number along with source of funds evidence if it is investing 10 percent or more of the total investment amount (that is, 10 percent of the total borrowed or 10 percent of the monies raised via the issue of new shares). Typically, these investors are established entities and the latest set of filed financial statements can be sufficient evidence.
For overseas equivalent regulated entities, we require its reference number with the regulator, along with source of funds evidence if it is investing 5 percent or more of the total investment amount. Typically, these investors are established entities and the latest set of filed financial statements can be sufficient evidence.
Funding from regulated banks or investment companies acting as an intermediary
These investors are regulated banks or entities acting as an intermediary for an investor or pool of investors (that is, the entity is not investing its own money). When we consider source of funds evidence, we group these investors into two categories – FCA regulated and overseas equivalent regulated.
For FCA regulated entities, we require its FCA reference number and, if it is investing 10 percent or more of the total investment amount, we require a schedule of the underlying investors.
For the underlying investors, we require source of funds evidence for:
- individual private investors investing £50,000 (or equivalent in foreign currency) or more
- non-regulated entities created or incorporated for more than 12 months at the date of investment and investing £1,000,000 (or equivalent in foreign currency) or more
- non-regulated entities created or incorporated for less than 12 months at the date of investment and investing any amount
- regulated entities investing 5 percent or more of the overall total investment amount.
For overseas equivalent regulated entities, we require its reference number with the regulator and, if it is investing 5 percent or more of the total investment amount, we require a schedule of the underlying investors.
For the underlying investors, we require source of funds evidence for:
- individual private investors investing £50,000 (or equivalent in foreign currency) or more
- non-regulated entities created or incorporated for more than 12 months at the date of investment and investing £1,000,000 (or equivalent in foreign currency) or more
- non-regulated entities created or incorporated for less than 12 months at the date of investment and investing any amount
- regulated entities investing 5 percent or more of the overall total investment amount.
System diagram
Remote (Online)Criteria
The system diagram and commentary should provide the names and details of any aspects of the provision that the applicant outsources via third-party providers for example:
- payment services
- age identity providers
- geolocation verification providers
- marketing
- customer service
- fraud detection
- server hosting and data storage
- delivery support
- administration.
System diagram for end to end process
Remote (Online)Criteria
A system diagram details the end-to-end process showing how the gambling activity will work from when a person registers, moves through into the gambling process to the pay-out of winnings providing commentary of the activities that happen at each stage. The system diagram and commentary should also include information on the location of the remote equipment.
Terms and conditions
Criteria
Provide copies of the terms and conditions which customers must agree to prior to gambling (where applicable). If the terms and conditions are not yet finalised please provide a draft copy.
Testing strategy
Remote (Online)Criteria
Procedures that show how you will comply with the testing strategy for compliance with remote gambling and software technical standards. The procedures should include the identity of a third party test house or a declaration of compliance with good practice if testing is to be carried out in-house.
Trust documents (trust deed, letter of wishes, letter of consent from trustees)
Criteria
If your business is a trust or there is a trust involved in the ownership structure, the Commission’s application disclosure requirements for Trusts are the same as those for other entity types and/or individuals that are part of an applicant’s ownership structure.
However, it is important to note that whilst the disclosure requirements set out below are general principles of the information required to support an application, the Commission retains the right to request further information or documents when this is required.
Where the Trust’s ownership equates to 3 percent or above interest in the applicant in your application, you must include:
- a copy of the trust deed
- a copy of the letter of wishes
- a copy of the letter of consent from the trustees (i.e. that they have consented to act as trustees).
Trust beneficiaries
We require an Annex A from those beneficiaries whose interest in the Trust equates to a 10 percent or more controlling interest in the applicant. The Annex A must be submitted online through our Apply for a personal licence service. If any beneficiary is under 18, then we do not require an Annex A from them.
If by virtue of their interest in the Trust, any beneficiary is likely to have an interest in the licensed activities equating to at least 3 percent but less than 10 percent, we require the name, address and date of birth of that beneficiary. This information should be shown in the trust deed – if not, you must provide this information.
Trustees
We require an Annex A from all Trustees where the Trust’s interest in the applicant equates to a 10 percent or more controlling interest in the applicant and/or licensee. The Annex A must be submitted online through our Apply for a personal licence service.
In the case of the Trustee being a company, we require an Annex A from the person or people in that company who have lead responsibility for matters relating to the Trust.
If the Trust’s interest in the applicant equates to equates to less than 10 percent but 3 percent or more, we require the name, address and date of birth of all Trustees which should be shown in the trust deed – if not, you must provide this information.
Settlor
We will not usually require an Annex A from the Settlor. We require the name, address and date of birth of the Settlor which should be shown in the trust deed – if not, you must provide this information.
Protector
We will not usually require an Annex A from the Protector. We require the name, address and date of birth of the Protector which should be shown in the trust deed – if not, you must provide this information.
Last updated: 9 January 2024
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Source of Funds details added Table information updated