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Guidance to operators for age verification test purchasing (non-remote)

This guidance explains what data we need from you about age verification test purchasing when you hold a non-remote operating licence.

  1. Contents
  2. Guidance on conducting age verification test purchasing

Guidance on conducting age verification test purchasing

General guidance on age verification test purchasing is as follows:

  • each licensee is responsible for ensuring they comply with our LCCP requirements. If a licensee chooses to take part in a collective test purchasing programme (for example, one organised by a trade association), they must assure themselves that the collective programme provides reasonable assurance that the licensee has effective policies and procedures to prevent underage gambling
  • the scale and frequency of age verification test purchasing necessary will vary dependent on the size of the business, the sector of the industry they are licensed to operate in, local risk assessments, and other similar factors. As a minimum we expect that all of an operator’s premises are tested at least once a year
  • we expect tests to be conducted at different times of the day (morning, afternoon, and evening) and at different times of the year. If an operator holds different licence types, the scope of test purchasing must be sufficient to assure compliance for each licence type
  • an increased level of testing will be appropriate in some circumstances, for example during the summer for AGCs and FECs in seaside resorts, or in betting shops during high-profile sporting events such as World Cup football
  • age verification test purchase visits to gambling premises should be unannounced
  • licensees, or third parties contracted by them to conduct age verification test purchasing, must not use a child or young person to conduct the tests. This would constitute an offence under the Gambling Act 2005 (opens in a new tab) (Sections 48 and 49) (or Sections 46 and 47). Typically, testing is conducted using “young looking” 18-21 year old adults. As operators should be applying a ‘Think 21’ or ‘Think 25’ policy, individuals younger than these ages should be challenged in any case
  • test purchase results must be recorded and submitted to us at the end of the financial year in which the test took place (see below for Guidance on submission of age verification test purchasing results data). The data submitted is to be broken down per UK financial quarter
  • for reporting purposes, test purchase results should be recorded as ‘challenge before gambling activity’, ‘challenge during gambling activity’, ‘challenge after gambling activity’, or ‘unchallenged’
  • the definition of a ‘challenge before gambling activity’ includes any challenges conducted at the entrance to a premises; noting that it is illegal for a child or young person to enter most types of gambling premises. In an FEC, this could be a challenge before or at the point that the tester attempts to enter the Category C gaming machine area
  • where a premises fails a test purchase visit, we expect the premises staff to be informed of the result and for retesting to be carried out. We expect the retest to be conducted as soon as practicable after remedial action has been taken and no longer than three months after the failed test
  • if test purchasing results reveal weaknesses across several premises, we expect operators to review their age verification policies and procedures and take measures to improve compliance
  • we do not endorse, or ‘passport’, age verification test purchasing standards used in other industries or jurisdictions. Use of these standards by operators, or test purchase organisations contracted by them, does not guarantee our acceptance that test purchasing meets our LCCP requirements. As the national regulator for gambling, we are not resourced to engage with, review or comment on standards that may be developed in different regulatory regimes.
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Summary of non-remote age verification test purchase requirements within the Licence Conditions and Codes of Practice
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Guidance on recording and submitting age verification test purchasing results data
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