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Guidance on changes to non-remote casino licences relating to future amended betting and gambling activities, and gaming machine entitlements.
Published: 12 June 2025
Last updated: 22 July 2025
This version was printed or saved on: 28 July 2025
Online version: https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/non-remote-casino-sector-legislative-changes-guidance
Overview: ## Introduction and background
The Department for Culture, Media and Sport (DCMS) published its gambling White Paper (opens in new tab) in April 2023, which set out the previous government’s plans for modernising the regulation of the gambling sector. A series of key proposals specifically relating to the land-based gambling sector were outlined in Chapter 6 of the White Paper, including measures to adjust outdated regulatory restrictions applying to the sector.
From 26 July to 4 October 2023, DCMS conducted a public consultation (opens in new tab) on these measures.
Based on the responses to the consultation, DCMS introduced changes that would allow casinos that were already operating when the Gambling Act 2005 (the Act) to access a number of new entitlements if certain conditions were met.
In 2024, the new government reviewed the proposals in relation to modernising the rules for casinos and decided to implement the changes as outlined in the previous government’s consultation on this matter.
The following statutory instruments (effective from 22 July 2025) have been introduced to deliver the proposed changes for casino licensed premises:
This implements the following changes:
1 This condition only applies to converted casinos that choose to exercise the extended entitlement. It cannot be enforced against non-extended casinos, but when calculating the number of machines against the maximum of 80, all machines in every connected converted casino will be counted, whether or not they have decided to exercise the extended entitlement.
These regulations make the following changes.
Larger converted casino premises, where the gambling area is no less than 200m² and the extended entitlement for machines is not taken up, will be required to abide by the following rules:
Extended converted casino premises are also a new category of premises which applies to those premises which take up their increased gaming machine allowance. These premises will be required to abide by the following rules:
Other converted casino premises where the gambling area is less than 280m² will be limited to a maximum of 16 separate betting positions.
This instrument also made 2 changes to Small 2005 Act casinos. Firstly, it amends the machine to table ratio from 2:1 to 5:1 for those casinos. Secondly, it reduces the minimum table gaming area requirement from 500m² to 250m² for those casinos.
This enables the holder of a converted casino premises licence who wants to utilise the new entitlements to apply to the relevant licensing authority to vary that licence so the casino plan can show the location and extent of any part of the premises which will be a table gaming area.
These Regulations make amendments to the Gambling Act 2005 (Gaming Tables in Casinos) (Definitions) Regulations 2009 (opens in new tab) (the 2009 Regulations) to alter what constitutes a “gaming table” in a casino for the purposes of section 172(3) to (5) of the Gambling Act 2005.
These Regulations extend to England, Wales and Scotland and apply to all gaming tables in casinos from 22 July 2025.
Subsections (3) to (5) of section 172 of the Act make provision as to the number of gaming machines which may be made available for use in a casino by the holders of a licence issued under the 2005 Act. As well as a fixed numerical maximum, the number of gaming machines must not exceed a specified multiple of the number of gaming tables used in that casino (Regulation 3 of the 2009 Regulations addresses when a gaming table is to be treated as being used in a casino at a particular time)
The effect of the amendments made by Regulation 2 (of the 2025 Regulations) is to make it clear that only gaming tables controlled or operated by casino staff can qualify as a gaming table for the purposes of calculating gaming machine allowances. This change is made to prevent gaming products counting as a gaming table for the purposes of the gaming machine allowance, if a game can be triggered and the outcome established without the direct involvement of casino staff; for example, where the player presses a switch or button, or pulls a plunger or lever to release a set of balls. These types of products do not provide any of the benefits of a casino gaming table in contributing to a balanced mix of products or affording opportunities for social interaction. Further detail on this can be found in the statutory instrument’s Explanatory Memorandum.
The full detail of the entitlements delivered by each of the instruments and any requirements and conditions attached to them are set out in the instruments.
All 4 of these instruments are effective from 22 July 2025. Operators are now able to formally start the process of accessing these new entitlements if they wish to do so. An operator can of course leave their current premises licence unchanged.
Some parts of the regulatory framework for casinos are reserved while other aspects are devolved. Only 2 of the measures from this package apply to Scotland. These are:
While the powers to make changes to gaming machine entitlements are reserved, the protective measures that the government views as necessary accompaniments to any such change are devolved2. The government has indicated that it will not proceed with the other deregulatory changes in Scotland without accompanying protective measures also being in place and is in ongoing discussions with the Scottish Government.
2This condition only applies to converted casinos that choose to exercise the extended entitlement. It cannot be enforced against non-extended casinos, but when calculating the number of machines against the maximum of 80, all machines in every connected converted casino will be counted, whether or not they have decided to exercise the extended entitlement.
This guidance provides information on the overall intent of the statutory instruments, what the changes mean for operators of casino premises that intend to make use of the regulatory changes and how this process should be administered by licensing authorities when applications are received.
Converted casino licensees are advised that those wishing to utilise the new extended entitlements will need to inform the Commission under the Licence Conditions and Code of Practice (LCCP) Ordinary Code Provision 8.1.1 (Information requirements).
Licence holders should also consider whether, as a result of the changes and gambling facilities offered, an operating licence (OL) variation is required with regards to fee category and/or the licensed activities being offered (such as betting).
For non-remote betting facilities, this would be a non-remote general betting (standard) operating licence. To offer self-service betting terminals (SSBTs), casinos would be required to apply for a remote general betting (standard) (real events) licence. It will not be possible for a casino licensee to rely on an ancillary remote betting licence, even where SSBTs are available alongside a non-remote offering, as the ancillary remote betting licence is bound to a betting premises licence.
More information on licence applications is available from the Commission’s webpage Operating Licences.
In addition, Small 2005 Act casinos which take advantage of the new machine to table ratio, and/or the reduced minimum table gaming area, will also need to apply to their local licensing authority to vary their premises licence, given the changes in non-gambling and gambling areas.
An existing licensed 1968 Act casino operator already holds an operating licence for non-remote betting and wishes to make use of the new Regulations to provide non-remote sports betting facilities in its casino (without providing any Self- Service Betting Terminal (SSBT) facilities). The operator can do so without having to make an application to vary its OL (given that betting facilities are permitted by Regulation).
An existing licensed 1968 Act casino operator already holds an operating licence for remote betting and wishes to make use of the new Regulations to provide SSBT facilities in its casino. The operator can do so without having to make an application to vary its OL (given that betting facilities are permitted by Regulation).
An existing licensed 1968 Act casino operator wishes to make use of the new Regulations to provide SSBT facilities in its casino. It does not currently hold a remote betting licence. As SSBTs involve remote communication, the operator will need to apply to the Commission for a remote general betting (standard) (real events) OL. That OL will need to be granted to the operator before it can make SSBTs available on the casino premises.
An existing non-remote 1968 Act casino licence holder does not wish to change their existing operation after the new Regulations come into effect. The licence holder does not have to take any action other than make sure it adjusts its operation to deliver the changes included in the Gambling Act 2005 (Gaming Tables in Casinos) (Definitions) (Amendment) Regulations 2025 (opens in new tab).
Licensing authorities may wish to refer to Part 7: Premises Licences of the Guidance to Licensing Authorities (GLA) issued by the Commission when dealing with applications related to premises licences. To be clear, any premises licence applications made to access entitlements under the new Regulations are the same in nature as any other premises application and should be processed in the same way by licensing authorities.
Operators and licensing authorities should also have regard to Section 187 of the Gambling Act 2005 (opens in new tab) in respect of applications to vary a premises licence.
In relation to Section 187, subsection (1)(a) refers to adding, amending, or removing an authorised activity. A range of gambling activities are already authorised by the Act, by existing Regulations and some are further added by the new Regulations which came into force on 22 July 2025. For example, the new Regulations authorise converted casino premises to offer betting. Where the ability to offer certain gambling activities has been expanded, the provision of these would not fall within the terms of Section 187 and would therefore not require an application to vary the premises licence solely for the addition of an authorised activity. However, other factors (such as a change in the premises layout) may mean that an application to vary the premises licence is required.
Under The Gambling Act 2005 (Premises Licences and Provisional Statements) (Amendment) (England and Wales) Regulations 2025 (opens in new tab), a converted casino premises licence holder who wants to utilise the extended gaming machine entitlements can apply to the relevant licensing authority to vary that licence so the casino plan shows the location and extent of any part of the premises which will be a table gaming area.
For other scenarios, and in deciding whether an application to vary a premises licence is necessary, licence holders and licensing authorities should have regard to the following.
The Gambling Act 2005 (Premises Licences and Provisional Statements) Regulations 2007 (opens in new tab) requires applications for a premises licence to include a scale plan, which shows the gambling and non-gambling areas. If a non-gambling area is to become used for gambling, then that change would require a premises licence variation. Regulation 3 of the Gambling Act 2005 (Mandatory and Default Conditions) (England and Wales) Regulations 2007 (opens in new tab) requires the layout of the premises to be maintained in accordance with the plan.
If a current gambling area in a converted casino is simply to be reassigned for the provision of betting facilities (which is authorised by the new Regulations as of 22 July), without any changes to the gambling and non-gambling areas as shown on the premises plan, then it would not require a premises licence variation. However, where a converted casino premises seeks to utilise the extended gaming machines entitlement, it will need to vary its premises licence to show the table gaming area on the plan, whether or not there are changes to any other part of the premises used for gambling or the non-gambling area.
An application to vary a premises licence will be required where the licence holder wishes to take advantage of the new entitlements under the Regulations but there is already a condition attached to the premises licence by the licensing authority which prohibits the proposed change. A variation application would be required to remove or amend the existing condition.
Where an application to vary a premises licence is required, the licensing authority’s Statement of Principles may include more detailed guidance on what should be covered in the application.
An existing converted casino premises licence holder wishes to utilise the new extended gaming machine entitlements. The licensee can do this by making an application to vary their premises licence to the relevant licensing authority. The Regulations enable the licensee to show (as required) the location and extent of any part of the premises which will be a table gaming area (previous regulations did not require the plan for a converted casino premises licence to include a table gaming area). The plan must also therefore show the gambling and non-gambling areas.
An existing Small 2005 Act casino wishes to utilise the new table to gaming machines ratio alongside a reduction in its minimum required table gaming area. This would require a premises licence variation application to the relevant licensing authority given the changes to the gambling and non-gambling areas.
A 1968 Act casino operating licence holder wishes to take advantage of the new activities and entitlements afforded by the new Regulations. They have the appropriate OL requirements in place and will be providing betting facilities on their converted casino premises. There will be no changes to the existing gambling and non-gambling areas. The licence holder will not be required to apply for a variation of their premises licence. Section 187(1)(a) is not applicable in this case because Regulations entitle them to offer betting on their casino premises.
A licensed casino operator in Scotland wishes to take advantage of the new entitlements. This is not possible because no changes in relation to the new entitlements have been made to the existing Regulations in Scotland. If those changes are made in the future, then operators would be able to access these provisions after they come into effect.
Operators in Scotland do however have to comply with the terms of The Gambling Act 2005 (Gaming Tables in Casinos) (Definitions) (Amendment) Regulations 2025 (opens in new tab), for example, for 2005 Act casinos, only tables for multi-player live gaming, operated by a casino dealer, can count for the purposes of any machine to table ratio calculations.
Under the Licence Conditions and Codes of Practice (LCCP) Social Responsibility Code Provision 10.1.1 – Assessing local risk licence holders are required to conduct, review and update as necessary, a local risk assessment for each of their premises. Under LCCP Ordinary Code Provision 10.1.2 – Sharing local risk assessments licence holders should share their local risk assessments with a relevant licensing authority when applying for a variation of their premises licence, or otherwise on request.
On that basis, licensing authorities can request access to local risk assessments when no application to vary the premises licence has been made.
When granting applications to vary a premises licence, the licensing authority is reminded to ensure that all the appropriate licences and notices are issued with any updated information in respect of changes made by the Regulations, for example in relation to mandatory and default conditions.