Non-remote casino legislative changes
09 September 2025
The Commission would like to draw licensees’ attention to recent legislative changes in relation to non-remote casinos and to the Commission’s guidance: Non-Remote Casino Sector – legislative changes guidance.
The changes allow casinos that were already operating when the Gambling Act 2005 (the Act) came into force, referred to as converted premises, to access new entitlements if certain conditions are met.
Betting activity
The legislative changes allow for betting to be offered as an activity in converted casino premises.
Casino operators are reminded that those wishing to utilise the new extended entitlements will need to inform the Commission under Licence Conditions and Code of Practice (LCCP) Ordinary Code Provision 8.1.1 (Information requirements).
Licence holders should consider whether, as a result of the changes and gambling facilities offered, an operating licence (OL) variation is required with regard to fee category and/or the licensed activities being offered (such as betting). More information on the operating licences required is available in our guidance on the legislative changes. When applying for a licence variation to add betting activity, an updated risk assessment and updated policies, procedures and controls documentation will need to be supplied to the Commission.
Casino licence holders are reminded of their obligation under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the Regulations) to ensure that when new products, business practices or technology are adopted, measures are taken to mitigate any money laundering (ML) or terrorist financing (TF) risks.
The Commission expects casino licence holders who introduce betting activity to update their MLTF risk assessments, considering all relevant risks and taking into account the betting sector risks published in the Commission’s risk assessment. Relevant risks may include (but are not limited to) cross-channel customer activity, payment methods and open loop payment processes.
Policies, procedures and controls will also need to be updated to address the risks identified in the risk assessment and to reflect the mitigations in place. Please note that the Commission expects that all customers in casino premises are treated as casino customers under the Regulations.
Gaming machine changes
The legislative changes also introduced changes to gaming machine entitlements for converted casino premises. Further information on the new entitlements, provisions in place, and the required premise licence variations is available in the guidance on the legislative changes.
Casino licence holders making changes to their gaming machine provision are expected to reflect these changes in their MLTF risk assessment and consider whether their policies, procedures and controls need updating.