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This response sets out our position in relation to the consultation on the proposed amendments to LCCP due to the introduction of the DMCC Act 2024.
Published: 18 December 2025
Last updated: 18 December 2025
This version was printed or saved on: 19 December 2025
Online version: https://www.gamblingcommission.gov.uk/consultation-response/amendments-to-lccp-due-to-the-digital-markets-competition-and-consumers-act
The Digital Markets, Competition and Consumers (DMCC) Act 2024 (opens in new tab) is a new UK law that aims to update and strengthen consumer rights and protections and improve access to alternative dispute resolution for consumer contract disputes. The Act revoked and replaced the Consumer Protection from Unfair Trading Regulations (CPUTR) 2008 and will lead to the revocation of the Alternative Dispute Resolution for Consumer Disputes (Competent Authorities and Information) Regulations (ADRR) 2015, replacing them with new provisions.
Both the CPUTR 2008 and the ADRR 2015 are referenced in our Licence Conditions and Codes of Practice (LCCP). These sections will need to be amended or removed and replaced with references to the new DMCC Act 2024. The LCCP changes required only reflect the changes in legislation and will not extend beyond the legal obligations on licensees. To make these changes, a consultation was required.
On 18 August 2025 we published a consultation which made proposals to amend or remove wording in sections of the LCCP and replace them with references to the DMCC Act 2024. Stakeholders were invited to share their views on these proposals and provide a response to the proposed LCCP amendments.
This response sets out our position now that the consultation has closed and all 14 responses submitted have been considered.
We consulted on 4 proposals to amend the LCCP and to reflect changes in legislation (opens in new tab):
We also stated that we would amend the parts of our website and guidance documents that refer to the CPUTR 2008 and the ADRR 2015. Amendments to our website and guidance documents do not need to be consulted on but we mentioned them for information in the consultation document.
On 18 August 2025 we published our consultation ‘Proposed amendments to Licence Conditions and Codes of Practice (LCCP) due to the Digital Markets, Competition and Consumers Act 2024’.
Stakeholders were invited to share their views on these proposals and provide a response to the proposed LCCP amendments.
The consultation ran until the 29 September 2025.
Responses from stakeholders included:
Annex 1 lists organisations that consented to the publication of their name when responding to the consultation.
Following careful consideration and review of the responses received during the consultation, we have decided to proceed with all 4 proposals:
Proposals 1 and 2 will come into force on the 6 April 2026. We anticipate that the implementation of proposals 3 and 4 will take place in Spring 2026, however, these changes depend upon when the Department for Business and Trade (DBT) can enact the changes in the DMCC Act that will abolish the ADR regulations. That date has not been confirmed. We will update our website with the date when we can.
Following the consultation, we identified a typographical error in SRCP 5.1.9. The word ‘advertisement’ should read ‘advertisements’ and is therefore being amended as part of this consultation. This correction does not change the meaning of the provision.
On 18 August 2025 we published our consultation ‘Proposed amendments to Licence Conditions and Codes of Practice (LCCP) due to the Digital Markets, Competition and Consumers Act 2024’.
Stakeholders were invited to share their views on these proposals and provide a response to the proposed LCCP amendments.
The consultation closed on 29 September 2025.
We received 14 responses to the consultation from the following categories of respondents:
Annex 1 lists organisations that consented to the publication of their name when responding to the consultation.
Proposals 1 and 2 were as follows:
The intention behind these proposals was to ensure that the Licence Conditions and Codes of Practice (LCCP) reflects the new consumer legislation, which provides updated definitions for the relevant terms referenced in LC 7.1.1 and SRCP 5.1.9.
Most respondents were supportive and positive about the proposed changes in proposals 1 and 2. Positive responses included one that strongly agreed with the amendments, stating that the changes would ensure that the LCCP is aligned with new legislation and enhance clarity and transparency.
Two respondents indicated that they neither agreed nor disagreed with the proposals but did not provide any further information to support this view.
Two respondents expressed some concerns around whether the DMCC Act 2024 might carry some new definitions, tests or considerations when compared to the previous legislation and asked that the Gambling Commission provide some guidance if the Act extends the current scope of responsibilities for licensed gambling operators within the LCCP.
One respondent raised concerns about those consumers who are experiencing vulnerability and highlighted that this legislative change alone will not guarantee meaningful protection unless the LCCP explicitly requires gambling operators to implement policies and processes that recognise and respond to vulnerability.
We have considered all comments and acknowledge the concerns raised by stakeholders in the consultation responses.
We maintain the view that we need to amend the wording of both LC 7.1.1 (4) and SRCP 5.1.9 (1) of the LCCP to reflect new legislation, namely the DMCC Act 2024, which has already revoked and replaced the CPUTR 2008.
The DMCC Act 2024 provides updated definitions for key terms, but the concepts themselves are broadly the same. Our assessment was that while there are likely to be aspects in which duties on licensees are enhanced by the DMCC Act 2024, the overall effect is to streamline the requirements rather than hold licensees to a new set of standards. Licensees will be directly bound by the DMCC Act 2024, regardless of whether we make changes to the LCCP.
We note the concerns around consumer vulnerability in one of the responses. However, the aim of this consultation and resulting changes to the LCCP is only to make the necessary consequential changes due to the DMCC Act 2024. Any policy changes regarding licensees recognising and responding to vulnerability fall outside its scope.
This requirement will come into force on 6 April 2026.
Applies to: All operating licenses except gaming machine technical and gambling software licences.
“Licensees must ensure that they do not commit any unfair commercial practices within the meaning of the Digital Markets, Competition and Consumers Act 2024 at any stage of their interactions with consumers”.
Paragraphs 1 to 3 of LC 7.1.1 will be unchanged.
This requirement will come into force on 6 April 2026.
Applies to: All licences.
“Licensees must ensure that their marketing communications, advertisements, and invitations to purchase (within the meaning of the Digital Markets, Competition and Consumers Act 2024) do not amount to or involve misleading actions or misleading omissions within the meaning of this Act”.
Paragraphs 2 and 3 of SRCP 5.1.9 will be unchanged.
Following the consultation, we identified a typographical error in SRCP 5.1.9. The word ‘advertisement’ should read ‘advertisements’ and is therefore being amended as part of this consultation. This correction does not change the meaning of the provision.
Where appropriate, any references on our website to the Consumer Protection from Unfair Trading Regulations 2008 will be replaced with the DMCC Act 2024 at the time these changes come into effect.
Proposals 3 and 4 were as follows:
The ADRR 2015 designates the Commission as a ‘competent authority’ for ADR in the gambling sector. The DMCC Act 2024 will bring in provisions which will fully revoke the ADRR 2015, meaning the Commission will no longer be the competent authority for gambling ADR and will not be able to approve ADR providers, or set additional standards for them. Anyone wishing to carry out ADR in the gambling sector will be required to apply to the Secretary of State for Business and Trade for accreditation.
The intention behind these proposals is to amend and remove wording within the footnote linked to section 6.1.1 of the Licence Conditions and Codes of Practice (LCCP) to reflect the fact that the DMCC Act 2024 will fully revoke the ADRR 2015 and the Commission will no longer be responsible for ADR accreditation.
Ten respondents were supportive and positive about the proposed changes in proposals 3 and 4, with 4 respondents neither agreeing nor disagreeing. One example of a positive response highlighted the need for the LCCP to reflect legislative changes and that these proposals will help licensees maintain compliance. A larger number of concerns were expressed by respondents in this section of the consultation.
Three respondents suggested that consideration ought to be given to the timing of implementation to avoid the potential for operators to be in breach of the updated LCCP provisions. There was a suggestion that amendments to the LCCP should not take effect until all existing ADR providers are approved under the new regime by the Secretary of State. There was also some concern about whether those ADR providers currently approved by the Commission would automatically be accredited under the DMCC Act 2024. If not, would time be allowed for a gambling operator to transition to a new ADR provider in the unlikely event that their current ADR provider did not receive accreditation under the new scheme.
One respondent asked whether the Commission would provide a link or signposting to the new list of accredited gambling ADR providers.
Respondents suggested that removing the Commission as a ‘competent authority’ with extensive experience and industry knowledge may have an adverse impact on the standards for gambling specific dispute resolution or an undue effect on current ADR providers who are well versed on industry specific issues. Respondents hoped that those current ADR providers approved by the Commission would go on to receive accreditation under the new Act.
One respondent queried whether the outcome of this consultation could significantly change the landscape for customer dispute resolution within the gambling industry and might therefore impact on the potential creation of an ombudsman scheme.
We have considered all comments raised by stakeholders in the consultation responses.
We maintain the view that we need to amend and remove wording in the footnotes of Social Responsibility Code Provision 6.1.1 of the LCCP to reflect a change in legislation, namely the introduction of a new accreditation scheme for ADR providers in the gambling sector.
We will continue to work closely with the Department for Business and Trade (DBT) to make sure that any changes it implements, that will have a direct impact on the gambling industry, are clearly communicated to avoid confusion, particularly around the implementation of the new accreditation process.
The DBT plans to put in place transitional arrangements whereby existing ADR providers accredited under the 2015 regulations will be subject to simplified accreditation under the new scheme brought about by the DMCC Act 2024. It envisages that the 2 frameworks will run concurrently for a period of time to provide continuity while the switch to the new system is completed. In doing this, it aims to ensure continuity of ADR provisions for consumer and business users and minimise any additional administrative burden on existing providers.
We will amend LCCP wording, as per the proposals, at the point at which the provisions covering ADR in the DMCC Act 2024 come into effect. We do not envisage licensees finding themselves unintentionally in breach of the LCCP because their ADR provider has not yet been accredited. The DBT intends to operate the ‘fast track’ procedure explained previously including a period where both frameworks operate concurrently.
The DBT has advised the Commission that it will be able to signpost gambling operators to the new list of accredited ADR providers. The DMCC Act 2024 ADR framework is designed to improve how information, advice and guidance relating to ADR providers is made publicly available, prominent, and visible to consumers who may need to access the service. The Commission will provide a link to a list of accredited ADR providers on our website.
It is the government’s intention that the new framework provides a certain amount of flexibility for the creation of new sector-specific ombudsman through the power to exempt ADR provision in regulated sectors and elsewhere where dispute resolution provision in those sectors is underpinned by other statute. This is to prevent dual regulation and give departments and regulators the freedom and flexibility to respond to the needs and requirements of dispute resolution in individual sectors. Therefore, the introduction of the DMCC Act 2024 does not prevent the future creation of a gambling specific ombudsman.
Applies to: All licences (including ancillary remote licensees) except gaming machine technical and gambling software licences.
We will amend footnote ‘a’ to:
“a person offering alternative dispute resolution services who has been granted accreditation by the Secretary of State under Chapter 4 of Part 4 of the Digital Markets, Competition and Consumers Act 2024”.
We will delete the following wording from footnote ‘b’:
“Whose name appears on the list of providers that meet the Gambling Commission’s additional standards found in the document ‘Alternative dispute resolution (ADR) in the gambling industry – standards and guidance for ADR providers”.
We will also delete the sentence that sits under footnote ‘b’ which states, “Both lists are on the Commission’s website and will be updated from time to time” and delete number 3 of the references, which refers to the Commission’s list of approved ADR providers.
We anticipate that both changes will come into force in Spring 2026. However, these changes depend upon when the DBT enact the changes in the DMCC Act that will abolish the ADR regulations. That date has not been confirmed. We will update our website with the date when we can.
Where appropriate, any references on our website to the ADRR 2015 will be either removed or replaced with the DMCC Act 2024. This process will include removing any material or guidance relating to our responsibilities on gambling ADR arising from those regulations. Our additional standards for ADR providers introduced in 2018 will be withdrawn. The changes to the website will be made at the time the changes to the LCCP come into effect.
We are committed to giving consideration to potential equalities impacts, having regard to the need to eliminate discrimination, advance equality of opportunity and foster good relations between those who share a protected characteristic and those who do not.
Our position, as a result of our initial assessment, was set out in the consultation. The Gambling Commission does not currently consider that any of the proposals set out in this response document give rise to any known negative impacts in the context of the policy objectives.
We invited views, evidence or information which might assist the Commission in considering any equalities impacts in the context of the proposals.
We received one response which helped inform our assessment of the equalities impact of the proposals. The respondent expressed concern about those consumers who are experiencing vulnerability and highlighted that this legislative change alone will not guarantee meaningful protection unless the Licence Conditions and Codes of Practice (LCCP) explicitly requires gambling operators to implement policies and processes that recognise and respond to vulnerability. For the purposes of the Equality Act 2010, vulnerability is not itself a protected characteristic, but we acknowledge that a person's vulnerability may arise from or be linked to a protected characteristic.
In line with the Public Sector Equality Duty (PSED) impact assessment guidance, the government’s impact assessment (opens in new tab) for the Digital Markets, Competition and Consumers (DMCC) Bill considered (at pages 41 to 43) whether the DMCC Act 2024 reforms would impact those consumers who share protected characteristics. It was not expected that the reforms would have any direct impact or actively discriminate against those with protected characteristics or other consumer groups. It is anticipated that these reforms will benefit consumers more broadly through enhanced protections and clearer guidance. In relation to Alternative Dispute Resolution (ADR) specifically, the Department for Business and Trade (DBT) is aware of the need for improved provision of signposting, advice and support to enable consumers, particularly those in vulnerable groups, to access and benefit from ADR provision.
Having considered the consultation responses, our position remains the same as our initial assessment, being that the proposals do not present a negative impact on the protected characteristics stated within the Equality Act 2010, and they do not contribute towards unlawful discrimination, harassment or victimisation and/or other conduct prohibited by the Act.
Annex 1 lists organisations that consented to the publication of their name when responding to the consultation: Amendments to Licence Conditions and Codes of Practice (LCCP) due to the Digital Markets, Competition and Consumers Act 2024. All names of organisations have been presented as provided by the respondents that submitted the response.
Organisations that consented to the publication of their name when responding to the consultation: