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Consultation response

Changes to information requirements in the LCCP, regulatory returns, official statistics, and related matters

Parts I and II of the consultation response that sets out our position in relation to the information the Gambling Commission requires licensees to provide us.


Proposal 4: Changes to licence condition 15.1.2 (reporting suspicion of offences)


We proposed to amend licence condition 15.1.2 (1b) to introduce additional text which will enable us to specify the form and manner of the reporting of suspicion of offences etc. and to reference the relevant section of the Gambling Act 2005 (opens in new tab) which gives us the powers to void a bet. We also proposed to modify licence condition 15.1.2 (2) relating to sport betting integrity reporting to provide additional scope for us to specify the form and manner of the reporting of suspicious offences. The reason for this is to improve the efficiency of our data collection for sports betting integrity reporting. Finally, we proposed changes to 15.1.2 (2) to provide clarification on the reporting of suspected breaches of betting rules to the appropriate sport governing body.

The consultation included a commitment that we will continue to explore alternative technological solutions, such as Application Programme Interfaces (APIs), to improve the effectiveness of suspicious activity reporting.

Consultation question

Question 1.4. Do you agree with the proposed changes to the licence condition?

Respondents' views

Respondents agreed that a standardised approach for reporting of known or suspected offences would provide greater clarity. There were requests for further guidance on the new reporting standards and that the new standards to be proportionate and not create additional burden for licensees. Some respondents commented the proposed development of APIs would enable speedy reporting and constituted a positive step forward, though noted that a low-tech solution may be needed for some licensees. Respondents agreed that the change emphasised the responsibility for known or suspected offences to be reported to us by licensees, rather than any place undue reliance on third parties (for example legal representatives).

Some respondents suggested that the requirement should be for licensees to report known or suspected breaches of the wider 'rules' (that is rather than 'betting rules') applied by sport governing bodies. Also, it was suggested the words 'to enable the sport governing body to carry out its regulatory function' be added to end of licence condition 15.1.2 (2) to reflect the fact that any such information provided may be used for the full range of a sport governing body’s regulatory functions, including both investigation and prosecution of integrity offences. A further suggestion was that licensees should report events that indirectly result in known or suspected breaches of the rules applied by them.

Our position

This change will support our intention to standardise the provision of information related to known or suspected offences and of breaches of betting rules applied by relevant Sports Governing Bodies (SGBs). We think that this will provide enhanced clarity for licensees on our information needs and improve the effectiveness of suspicious activity reporting.

We recognise that SGB regulations may cover a range of rules related to integrity and corruption. However, we consider that broadening the licence condition to include ‘any rules’ may compel licensees to share information with SGBs that may fall outside of our regulatory remit, which would not be appropriate.

Section 30 of the Gambling Act 2005 permits us to share information we receive with those bodies listed on Schedule 6 for use in the exercise of the body's functions. Information that licensees are currently required to provide to SGBs (such as breaches of betting rules), is information that we could ourselves provide to the SGBs under Section 30 of the Act. The Licence Conditions and Codes of Practice (LCCP) requirement therefore shortens the administration and timescales involved in providing the information to SGBs (that is operators can provide an SGB directly with this information rather providing us with the information to forward to the SGB).

SGBs can use existing legal gateways to make specific data requests to betting operators and us, if such requests are lawful and necessary to undertake investigations or prosecutions that fall under their own regulatory remit. These include the Data Protection Act 2018 and additionally the Gambling Act 2005 when making requests to us for information.

We cannot include the term 'to carry out its regulatory function' for the reasons outlined previously. In addition, not all bodies listed on Schedule 6 of the Gambling Act 2005 are regulatory bodies and therefore do not have a regulatory function.

We have reviewed the suggestion for licensees to report to us events that ‘indirectly’ result in known or suspected breaches of the rules applied by SGBs. We do not consider this appropriate at this time as it would be a disproportionate burden for licensees and too open to interpretation.

We have developed a standardised template, in consultation with stakeholders, for reporting known or suspected offences under licence condition 15.1.1. The final version and supporting guidance will be available to licensees prior to the updated licence condition coming into effect. Follow-on development of reporting arrangements for known or suspected offences (for example APIs) will involve further discussion with stakeholders.

We have also removed the wording 'or ensure the Commission is provided with' to make the language consistent with the removal of this phrase from elsewhere in the LCCP. These changes will reinforce the principle that responsibility for meeting the licence condition rests with licensees, not third parties. We will, however, accept submissions by one licensee to provide information on behalf of another within a group.

The following changes will take effect from 31 October 2020.

Final wording of amended licence condition 15.1.2

Licence condition 15.1.2
Reporting suspicion of offences etc - betting licences
All betting operating licences including betting intermediary, ancillary remote betting, betting host and remote betting intermediary (trading rooms only) licences

1 Licensees must as soon as reasonably practicable provide the Commission with any information, in such a form or manner as the Commission may from time to time specify, from whatever source that they:

  • a. know relates to or suspect may relate to the commission of an offence under the Act, including an offence resulting from a breach of a licence condition or a code provision having the effect of a licence condition
  • b. suspect may lead the Commission to consider making an order to void a bet under section 336 of the Gambling Act 2005.

2 Licensees who accept bets, or facilitate the making or acceptance of bets between others, on the outcome of horse races or other sporting events governed by one of the sport governing bodies included in Part 3 of Schedule 6 to the Gambling Act 2005, must as soon as reasonably practicable provide the sport governing body with relevant and necessary information, from whatever source, that they know or suspect may relate to a breach of betting rules applied by that governing body.

3 ‘Betting rules’ includes any rule about bets the making or acceptance of which would be a regulated activity within the meaning of section 22 of the Financial Services and Markets Act 2000 (‘spread betting’).

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Proposal 3: Changes to licence condition 15.1.1 (reporting suspicion of offences)
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Proposal 5: Additional licence condition 15.1.3 (reporting of systematic or organised money lending)
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