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LCCP Information requirements

Guidance for licence holders on the information requirements in the LCCP

Published: 30 October 2020

Last updated: 13 January 2021

This version was printed or saved on: 21 September 2021

Online version: https://www.gamblingcommission.gov.uk/guidance/lccp-Information-requirements

Introduction

This provides guidance for licensees on the information requirements contained within the Licence conditions and codes of practice

It covers the information requirements for operating licence and personal licence holders.

Most of the LCCP information requirements are contained within Part 1: Operating licence conditions, Section 15 and Part II: Codes of practice provisions, Section 8. Personal licence information requirements are within Part III: Personal licence conditions. Some extra information requirements are within other parts of the LCCP.

For each requirement, we show the relevant LCCP extract, then explain what it means, what information we need and how it should be submitted to us.

The guidance covers six topics:

General information requests and regulatory returns

Giving us information we may ask for, including the need to submit regulatory returns.

Key events

Telling us about events that could have a significant effect on a gambling business (for example, if your company enters administration or receivership, or you submit a suspicious activity report).

LCCP notifications

Telling us about known or suspected offences under the Gambling Act 2005 (opens in a new tab) , money lending and cheating. Also, other events we need reported to us (for example, money laundering and terrorist financing, matters that could have a material impact on your business, repeated attempts by children or young people to gamble, and any lotteries you intend to promote).

Other information requirements

For specific gambling sectors, telling us about age verification test purchase results, keeping records relating to complaints and disputes, pool betting, and making lottery submissions.

Personal licence events

For personal licence holders, telling us about events about that could have a significant effect on your suitability to hold a licence (for example, if you are subject to a relevant criminal investigation, or have a disciplinary sanction for gross misconduct).

This guidance will be amended periodically to take account of emerging good practice or regulatory changes. Minor amendments will be consulted on informally, for example, through industry trade bodies, with more substantive changes subject to public consultation.

General information requests and regulatory returns

Introduction

This section provides guidance to holders of gambling operating licensees on our requirement for them to give us any information we ask for, in a way that we may specify.

We also explain our requirement for operators to submit regulatory returns and explain how this must be done.

Licence condition 15.3.1

General and regulatory returns

All operating licences

On request, licensees must provide the Commission with such information as the Commission may require, in such form or manner as the Commission may from time to time specify, about the use made of facilities provided in accordance with this licence, and the manner in which gambling authorised by this licence and the licensee’s business in relation to that gambling are carried on.

In particular, within 28 days of the end of each quarterly period or, for those only submitting annual returns, within 42 days of the end of each annual period, licensees must submit an accurate Regulatory Return to the Commission containing such information as the Commission may from time to time specify.

Your company must give us any information we ask for, in the way we specify, about how:

If we request such information, we will explain what we require and how you must provide the information to us.

As part of this requirement, we require operating licence holders to send us a regulatory return on a quarterly or annual basis, depending on their licence type.

Quarterly returns are to be submitted within 28 days of the end of the reporting period, while annual returns are due within 42 days of the end of each annual period.

Regulatory returns need to be submitted via our online regulatory returns system within the eServices digital service (opens in a new tab). Regulatory returns guidance is available throughout the system and on our website.

This reporting requirement applies to holders of all operating licences.

Key events (general)

This section provides guidance to holders of gambling operating licensees on general matters about reporting key events.

A key event is an event that could have a significant effect on a gambling business.

A summary of the key events (opens in a new tab) listed within LCCP Licence condition 15.2.1 is on our website.

Licence condition 15.2.1

Reporting key events - General

All operating licences

A key event is an event that could have a significant impact on the nature or structure of a licensee’s business. Licensees must notify the Commission, in such form or manner as the Commission may from time to time specify, of the occurrence of any … key events as soon as reasonably practicable and in any event within five working days of the licensee becoming aware of the event’s occurrence.

If any key event happens within your business, you must tell us about this, via the key events part of the eServices digital service (opens in a new tab) on our website.

You must do this within five working days of you finding out about the event. If, for any reason, you report the event to us after five working days, you need to explain the reason for the delay in the ‘Detail’ box of the respective key event report.

If you experience technical issues preventing you reporting key events to us via eServices, you should capture evidence of the problems experienced and contact us (opens in a new tab) to discuss the matter.

When submitting a key event report, you must enter a date. This must be the date of the notification. Details about the date of the event are to be recorded in the ‘Detail’ box.

You must also record the key event type. To ensure you do this correctly, refer to the specific guidance for each key event and select the correct key event type.

For each key event report, you are given 1,500 characters in the ‘Detail’ box to provide a summary of the event. If additional space is required, or if you want to provide supporting documentation, you can upload files associated with the key event.

For operators with multiple licences, key events must be submitted within the eServices account of the licence relevant to the event you are telling us about.

This reporting requirement applies to holders of all operating licences.

Key events (operator status)

This section provides guidance to holders of gambling operating licensees on how to tell us about key events which relate to an operator’s status.

Operator status covers matters such as when a company enters administration or receivership, or an individual becomes bankrupt.

Key Event 1: Operator status

Licence condition 15.2.1 (1)

Reporting key events - Operator status

All operating licences

Any of the following applying to a licensee, any person holding a key position for a licensee, a group company, or a shareholder or member (holding 3% of more of the issued share capital of the licensee or its holding company):

  • presenting of a petition for winding up,
  • making of a winding up order,
  • entering into administration or receivership,
  • bankruptcy (applicable to individuals only),
  • sequestration (applicable in Scotland), or
  • an individual voluntary arrangement.

Events about companies

Your company must submit a key event report to us if any of the following events happen to it, or any company in your group of companies:

A company in your group includes any subsidiary or holding company and any subsidiary of such holding company. For a detailed explanation of these terms refer to the Companies Act 2006 (Section 1159) (opens in a new tab) . This requirement includes companies which are incorporated outside of the United Kingdom.

You must do this within five working days of you finding out about the event.

When reporting this key event, you must include the following information:

Upload copies of relevant documents where these are available. For example, the winding up petition or order.

Note, if a company with an operating licence issued by us ceases to exist or goes into liquidation, their operating licence automatically lapses. You must still report this key event to us. Liquidation is defined in the Insolvency Act 1986 (Section 247(2)) (opens in a new tab).

Events about individuals

Your company must also tell us if any of the following events happen to a person in a key position in the company, or any shareholder or person holding more than 3% of issued share capital in your company, or a holding company:

A ‘key position’ is defined in LCCP Licence condition 15.2.1 (4) (Reporting key events - Relevant persons and positions).

You must do this within five working days of you finding out about the event.

When reporting this key event, you must include the following information:

Upload copies of relevant documents where these are available. For example, the bankruptcy petition.

In addition to this requirement, if a personal licence holder is made bankrupt or sequestration of their estate is awarded, the individual must submit a personal event report to us. Also note that, if either of these events occur, a personal licence holder’s licence will lapse.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Winding-up/receivership(to report the presenting of a petition for winding up, making of a winding up order, or receivership)

Key Event: Administration/IVA__ (to report administration or an IVA)

Key Event: Bankruptcy/Sequestration__ (to report bankruptcy or sequestration of a person in a key position or relevant shareholder)

This reporting requirement applies to holders of all operating licences.

Key events (relevant persons and positions)

This section provides guidance to holders of gambling operating licensees on how to tell us about key events which relate to relevant persons and positions within, or connected to, a gambling business.

It includes how to tell us:

Key Event 2: Shareholders or members holding issued share capital

Licence condition 15.2.1 (2)

Reporting key events - Relevant persons and positions

All operating licences

In the case of licensees who are companies or other bodies corporate having a share capital, the name and address of any person who (whether or not already a shareholder or member) becomes a shareholder or member holding 3% or more of the issued share capital of the licensee or its holding company.

Your company must submit a key event report to us if any person holds 3% or more of the company or holding company’s shares, whether or not that person is already a shareholder or member.

You must do this within five working days of you finding out about the event.

For a detailed explanation of the meaning of ‘holding company’ refer to the Companies Act 2006 (Section 1159) (opens in a new tab). For ‘bodies corporate’ refer to the Companies Act 2006 (Section 1173(a)) (opens in a new tab). This requirement includes companies which are incorporated outside of the United Kingdom.

When reporting this key event, you must include the following information:

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Notification of shareholders

This reporting requirement applies to holders of all operating licences.

Note, your company must either surrender its licence or apply for a new licence within five weeks of the change occurring if there is a change of corporate control (opens in a new tab) in your company. This is when any person (or other legal entity), directly or indirectly:

Key Event 3: Taking out loans from persons not authorised by the Financial Conduct Authority

Licence condition 15.2.1 (3)

Reporting key events - Relevant persons and positions

All operating licences

The taking of any loan by the licensee, or by a group company who then makes an equivalent loan to the licensee, from any person not authorised by the Financial Conduct Authority: a copy of the loan agreement must be supplied.

Your company must submit a key event report to us if it takes out a loan from any person who is not authorised by the Financial Conduct Authority (opens in a new tab), or a company in your group of companies takes out such a loan and then makes an equivalent loan to your company.

You must do this within five working days of you finding out about the event.

A company in your group includes any subsidiary or holding company and any subsidiary of such holding company. For a detailed explanation of these terms, refer to the Companies Act 2006 (Section 1159) (opens in a new tab).

Companies whose financial services activities are authorised by the Financial Conduct Authority are listed on the Financial Services Register (opens in a new tab).

When reporting this key event, you should include the following information:

You must upload a signed copy of the loan agreement when reporting this event.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Loans non FCA

This reporting requirement applies to holders of all operating licences.

Key Event 4: Appointment of persons in key positions

Licence condition 15.2.1 (4)

Reporting key events - Relevant persons and positions

All operating licences

The appointment of a person to, or a person ceasing to occupy, a ‘key position’ (including leaving one position to take up another). A ‘key position’ in relation to a licensee is:

  • in the case of a small-scale operator, a ‘qualifying position’ as defined in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006.

  • in the case of an operator which is not a small-scale operator, a ‘specified management office’ as set out in (current) LCCP Licence condition 1.2.

  • a position where the holder of which has overall responsibility for the licensee’s anti-money laundering and / or counter terrorist financing compliance and / or the reporting of known or suspected money laundering or terrorist financing activity.

  • any other position for the time being designated by the Commission as a ‘key position’.

General

Your company must submit a key event report to us if it appoints a person to a ‘key position’, or a person leaves a key position, or a person leaves a key position to take up another.

For small-scale operators (opens in a new tab), a key position is a person occupying a ‘qualifying position’ as defined in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006 (opens in a new tab).

For other gambling operators, a key position is any of the following:

You must do this within five working days of you finding out about the event.

Reporting a person who has taken up a key position

If you are reporting a person who has taken up a key position, you should include the following information:

Reporting a person who has left a key position

If you are reporting a person who has left a key position, you should include the following information:

Changes to persons in key anti-money laundering and counter-terrorist financing positions

For changes of persons in key positions relating to anti-money laundering and / or counter terrorist financing, in non-remote casinos, you must also upload documentary evidence of compliance with our guidance on The prevention of money laundering and combating the financing of terrorism (opens in a new tab) (Paragraphs 5.2 and 5.12). For other licensees, evidence of compliance with our advice on Duties and responsibilities under the Proceeds of Crime Act 2002 (opens in a new tab) (Paragraphs 20.7 and 20.15) must be provided.

Changes to persons in other designation key positions

We may have designated any other position as key for a licensee either through a condition attached to the operating licence or by letter to the licensee. If a person is appointed to this position or ceases to occupy this position, provide the same information as set out in the above section on reporting changes to persons in key positions.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select one of the following types when entering this key event on eServices:

Key Event: Key position – AML/TF__ (for changes to persons with primary responsibility for anti-money laundering and preventing terrorist financing)

Key Event: Key position – manage't office__ (for changes to persons in a specified management office)

Key Event: Key position – GC designated__ (for change to persons in any key position we designate as a ‘key position)

Key Event: Key position – SSO__ (for changes to a person occupying a qualifying position in a Small-Scale Operator)

This reporting requirement applies to holders of all operating licences.

Note, if you are a small-scale operator reporting any of these events, you must also submit an application to vary your company’s existing operating licence, to update Schedule X (opens in a new tab) of the licence.

Key events (financial events)

This section provides guidance to holders of gambling operating licensees on how to tell us about key events which relate to financial matters about your gambling business.

It includes how to tell us:

Key Event 5: Material changes in banking arrangements

Licence condition 15.2.1 (5)

Reporting key events - Financial events

All operating licences

Any material change in the licensee’s banking arrangements, in particular the termination of such arrangements or a particular facility and whether by the licensee or the provider of the arrangements.

Your company must submit a key event report to us if there is a significant change in its banking arrangements. This applies if the change is made by the company, or by the provider of the banking arrangements.

This includes if your company, or a bank or other financial institution, ends any important banking services which were in place.

You must do this within five working days of you finding out about the event.

When reporting this key event, you should include the following information:

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Banking arrangements

This reporting requirement applies to holders of all operating licences.

Key Event 6: Breaches of agreements with lenders

Licence condition 15.2.1 (6)

Reporting key events - Financial events

All operating licences

Any breach of a covenant given to a bank or other lender.

Your company must submit a key event report to us if any agreement it has (or had) with a bank or other lender is broken.

You must do this within five working days of you finding out about the event.

When reporting this key event, you should include the following information:

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Breach of a covenant

This reporting requirement applies to holders of all operating licences.

Key Event 7: Defaults on loan repayments

Licence condition 15.2.1 (7)

Reporting key events - Financial events

All operating licences

Any default by the licensee or, where the licensee is a body corporate, by a group company in making repayment of the whole or any part of a loan on its due date.

Your company must submit a key event report to us if it (or a company in your group) fails to make any loan repayment on its due date.

You must do this within five working days of you finding out about the event.

A company in your group includes any subsidiary or holding company and any subsidiary of such holding company. For a detailed explanation of the meaning of ‘subsidiary’ refer to the Companies Act 2006 (Section 1159) (opens in a new tab). For ‘body corporate’ refer to the Companies Act 2006 (Section 1173(a)) (opens in a new tab). This requirement includes companies which are incorporated outside of the United Kingdom.

When reporting this key event, you should include the following information:

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Default on a loan

This reporting requirement applies to holders of all operating licences.

Key Event 8: Changes to arrangement for accepting payments from customers

Licence condition 15.2.1 (8)

Reporting key events - Financial events

Remote casino, bingo and betting operating licences, except ancillary and remote betting intermediary (trading room only) licences

Any change in the licensee’s arrangements as to the methods by which, and/or the payment processors through which, the licensee accepts payment from customers using their gambling facilities.

Your company must submit a key event report to us if there is any change in the arrangements it has for accepting payments from customers.

This key event is directly related to LCCP Licence condition 5.1.2 (opens in a new tab), which requires that licensees must only accept payment from customers using their gambling facilities in Great Britain by a method involving a payment service provider which is registered with the Financial Conduct Authority (opens in a new tab). The definition of a payment service provider is contained within the Payment Services Regulations 2009 (opens in a new tab).

Payment service providers whose activities are authorised by the Financial Conduct Authority are listed on the Financial Services Register (opens in a new tab).

When reporting this key event, you should include the following information:

You must do this within five working days of you finding out about the event.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Payment processors

This reporting requirements applies to all holders of remote casino, bingo, and betting operating licences, except ancillary and remote betting intermediary (trading room only) licences.

Key events (legal or regulatory proceedings or reports)

This section provides guidance to holders of gambling operating licensees on how to tell us about key events which relate to legal or regulatory proceedings or reports.

It includes how to tell us:

Key Event 9: Grants, withdrawals or refusals of licence applications to other gambling regulators

Licence condition 15.2.1 (9)

Reporting key events - Legal or regulatory proceedings or reports

All operating licences

The grant, withdrawal or refusal of any application for a licence or other permission made by the licensee, or in the case of a licensee which is a body corporate, any group company of theirs, to a gambling regulator in another jurisdiction. In the case of a withdrawal or refusal of the application, the licensee must also notify the reasons for such withdrawal or refusal.

Your company must submit a key event report to us if any application it has made for a licence or other permission, to a gambling regulator in another jurisdiction, is granted, withdrawn or refused.

You must do this within five working days of you finding out about the event.

A company in your group includes any subsidiary or holding company and any subsidiary of such holding company. This requirement includes companies which are incorporated outside of the United Kingdom.

For a detailed explanation of the meaning of ‘subsidiary’ refer to the Companies Act 2006 (Section 1159) (opens in a new tab). For ‘body corporate’ refer to the Companies Act 2006 (Section 1173(a)) (opens in a new tab).

You do not need to tell us about this event if it relates to applications for licences or other permissions to carry out activities which would fall outside the scope of a Gambling Commission operating licence if carried out in Great Britain, or with customers in Great Britain.

When reporting this key event, you should include the following information:

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Licence/permission applications

This reporting requirement applies to holders of all operating licences.

Key Event 10: Investigations by professional, statutory, regulatory or government bodies

Licence condition 15.2.1 (10)

Reporting key events - Legal or regulatory proceedings or reports

All operating licences

Any investigation by a professional, statutory, regulatory or government body (in whatever jurisdiction) into the licensee’s activities, or the activities of a person in a ‘key position’, where such an investigation could result in the imposition of a sanction or penalty which could reasonably be expected to raise doubts about the licensee’s continued suitability to hold a Gambling Commission licence.

Your company must submit a key event report to us if a professional, statutory, regulatory or government body (in any jurisdiction) is investigating its activities, or the activities of a person in a key position, and the investigation could result in a sanction or penalty which could be expected to raise doubts about your company’s suitability to hold a licence from us.

You must do this within five working days of you finding out about the event.

When reporting this key event, you should include the following information:

A ‘key position’ is defined in LCCP Licence condition 15.2.1 (4) (Reporting key events - Relevant persons and positions).

You do not need to report to us investigations that are being conducted by us.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Investigation - suitability

This reporting requirement applies to holders of all operating licences.

Key Event 11: Criminal investigations by a law enforcement agency

Licence condition 15.2.1 (11)

Reporting key events - Legal or regulatory proceedings or reports

All operating licences

Any criminal investigation by a law enforcement agency in any jurisdiction in which the licensee, or a person in a ‘key position’ related to the licensee, is involved and where the Commission might have cause to question whether the licensee's measures to keep crime out of gambling had failed.

Your company must submit a key event report to us if it, or any person in a key position in the company, is the subject of any criminal investigation by a law-enforcement agency in any jurisdiction, and this could give us cause to question if your measures to keep crime out of gambling have failed.

You must do this within five working days of you finding out about the event.

When reporting this key event, you should include the following information:

A ‘key position’ is defined in LCCP Licence condition 15.2.1 (4) (Reporting key events - Relevant persons and positions).

You only need to report criminal investigations that could give us cause to question if your measures to keep crime out of gambling have failed.

If the criminal investigation is abroad (or in another jurisdiction within the United Kingdom), you must still report it to us if your business provides gambling facilities there.

You do not need to report to us criminal investigations that are being conducted by us.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Criminal investigations

This reporting requirement applies to holders of all operating licences.

Key Event 12: Referral to Boards (or audit and risk committees) of material concerns raised by a third party

Licence condition 15.2.1 (12)

Reporting key events - Legal or regulatory proceedings or reports

All operating licences

The referral to the licensee’s Board, or persons performing the function of an audit or risk committee, of material concerns raised by a third party (such as an auditor, a professional, statutory or other regulatory or government body, in whatever jurisdiction) about the provision of facilities for gambling: a summary of the nature of the concerns must be provided.

You must submit a key event report to us if a third party (such as an auditor, a professional, statutory or other regulatory or government body, in any jurisdiction) refers any concerns they have about your company’s gambling facilities to your board or any person performing the role of an audit or risk committee.

You must do this within five working days of you finding out about the event.

Material concerns include those which relate to your company’s ability to comply with the Gambling Act 2005 (opens in a new tab) or the Licence conditions and codes of practice (opens in a new tab). They also include more general concerns relating to the provision of facilities for gambling (such as suitability to hold a licence, consistency of actions relative with the licensing objectives, and risk about products, facilities, or operating environments for gambling) in any jurisdiction.

If you are unsure if a report identifies a matter of material concern, contact us (opens in a new tab) to discuss the matter.

When reporting this key event, you should include the following information:

It is often useful if you upload a copy of the relevant report, or a summary of the report’s findings.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Referral to Board/audit/risk

This reporting requirement applies to holders of all operating licences.

Key Event 13: Disciplinary sanctions against personal licence or qualifying position holders for gross misconduct

Licence condition 15.2.1 (13)

Reporting key events - Legal or regulatory proceedings or reports

All operating licences

The imposition by the licensee of a disciplinary sanction, including dismissal, against the holder of a personal licence or a person occupying a qualifying position for gross misconduct; or the resignation of a personal licence holder or person occupying a qualifying position following commencement of disciplinary proceedings in respect of gross misconduct against that person.

Your company must submit a key event report to us if it starts disciplinary proceedings for gross misconduct against the holder of a personal licence, or a person in a qualifying position, even if that person resigns before any action is taken against them.

You must do this within five working days of you finding out about the event.

There are two types of personal licence holders. These are a personal management licence (opens in a new tab) and a personal functional licence (opens in a new tab) (for people involved in gaming or handling money in a casino).

A ‘qualifying position’ is defined in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006 (opens in a new tab) and applies to small-scale operators.

Gross misconduct can results from actions such as theft, physical violence, gross negligence, or serious insubordination.

When reporting this key event, you should include the following information:

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Disciplinary gross misconduct

This reporting requirement applies to holders of all operating licences.

Note, if any person leaves key position, or leaves a key position to take up another, or you must submit another key event telling us about this change. Refer to the guidance notes for LCCP Licence condition 15.2.1 (4) for further information.

If a personal licence holder receives a disciplinary sanction for gross misconduct, they must also tell us this themselves, by submitting a personal licence event report (opens in a new tab).

Key Event 14: Legal action or court proceedings

Licence condition 15.2.1 (14)

Reporting key events - Legal or regulatory proceedings or reports

All operating licences

The commencement (in whatever jurisdiction) of any material litigation against the licensee or, where the licensee is a body corporate, a group company: the licensee must also notify the outcome of such litigation.

Your company must submit a key event report to us if any legal action or court proceedings are started against it, or a company in your group, in any jurisdiction.

You must do this within five working days of you finding out about the event.

‘Material’ litigation is any significant litigation and any litigation which:

For a detailed explanation of ‘body corporate’ refer to the Companies Act 2006 (Section 1173(a)) (opens in a new tab). A group company includes any subsidiary or holding company and any subsidiary of such holding company. This requirement includes companies which are incorporated outside of the United Kingdom.

When reporting this key event, you should include the following information:

When the legal action is settled, you must also tell us the outcome of the proceedings. This means that you will submit two key events, one at the start of the legal proceedings and one at the end, when the outcome is known.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Material litigation

This reporting requirement applies to holders of all operating licences.

Key Event 15: Suspicious activity reports

Licence condition 15.2.1 (15)

Reporting key events - Legal or regulatory proceedings or reports

All operating licences

The making of a disclosure pursuant to section 330, 331, 332 or 338 of the Proceeds of Crime Act 2002 or section 19, 20, 21, 21ZA, 21ZB or 21A of the Terrorism Act 2000 (a suspicious activity report): the licensee should inform the Commission of the unique reference number issued by the United Kingdom Financial Intelligence Unit of the National Crime Agency in respect of each disclosure and for the purposes of this key event the five working day period referred to above runs from the licensee’s receipt of the unique reference number. The licensee should also indicate whether the customer relationship has been discontinued at the time of the submission.

Your company must submit a key event report to us if it makes a suspicious activity report under section 330, 331, 332 or 338 of the Proceeds of Crime Act 2002 (opens in a new tab) or section 19, 20, 21, 21ZA, 21ZB or 21A of the Terrorism Act 2000 (opens in a new tab), or one is made about its activities.

Suspicious activity reports (SARs) alert law enforcement to potential instances of money laundering or terrorist financing. SARs are a vital source of intelligence not only on economic crime but on a wide range of criminal activity. They provide information and intelligence from the private sector that would otherwise not be visible to law enforcement.

SARs are submitted to the United Kingdom Financial Intelligence Unit (UKFIU) (opens in a new tab) which is part of the National Crime Agency. The easiest way to submit a SAR is with the secure SAR Online system (opens in a new tab). Separate guidance on SARs (opens in a new tab) is available on the UKFIU website.

After submitting a SAR, the UKFIU will send you a unique reference number (URN) for the disclosure you have reported. You must submit this key event to us within five working days of you receiving the URN for the disclosure.

When reporting this key event, you should only provide the following information:

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Suspicious activity report SAR

This reporting requirement applies to holders of all operating licences.

SARs and key events are not crime or fraud reports. If you need to report a crime or a fraud you should contact either your local police service on 101 or Action Fraud (opens in a new tab) on 0300 123 2040.

Known or suspected offences relating to gambling must also be reported to us. Refer to guidance for LCCP Licence condition 15.1 (reporting suspicion of offences) for further information.

Key events (gambling facilities)

This section provides guidance to holders of gambling operating licensees on how to tell us about key events which relate to the gambling facilities they provide.

It includes how to tell us:

Key Event 16: Information security breaches

Licence condition 15.2.1 (16)

Reporting key events - Gambling facilities

All operating licences

Any security breach to the licensee’s environment that adversely affects the confidentiality of customer data; or prevents the licensee’s customers, staff, or legitimate users from accessing accounts for longer than 12 hours.

Your company must submit a key event report to us if any security breach to its environment, has an adverse effect on the confidentiality of customer data; or prevents your customers, staff, or legitimate users from accessing accounts for longer than 12 hours.

You must do this within five working days of you finding out about the event.

For further information on what should be reported, see our guidance on Notification of information security breaches (opens in a new tab).

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Customer data security breach

This reporting requirement applies to holders of all operating licences.

Key Event 17: Gaming system faults resulting in under or over payments to customers

Licence condition 15.2.1 (17)

Reporting key events - Gambling facilities

All operating licences

Where a gaming system fault has resulted in under or overpayments to a player (this includes instances where a fault caused an incorrect prize/win values to be displayed).

Your company must submit a key event report to us if a fault in a gaming system results in underpayments or overpayments to a player (including if a fault causes an incorrect prize or amount to be displayed).

You must do this within five working days of you finding out about the event.

A gaming machine fault is typically where software has malfunctioned and has resulted in the stated return to player (RTP) percentage being incorrectly delivered as prizes (either under or over payment).

Other faults include odds and bonuses being displayed or calculated incorrectly.

For further information on what should be reported, see our guidance on Remote game software/payment faults (opens in a new tab).

You do not need to report gaming system faults which did not result in under or overpayments to players.

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Gaming system fault

This reporting requirement applies to holders of all operating licences.

Key Event 18: Stopping or starting trading on website domains, mobile applications and broadcast media

Licence condition 15.2.1 (18)

Reporting key events - Gambling facilities

All remote licences

In the case of remote gambling, the commencement or cessation of trading on website domains (including mobile sites or mobile device applications) or broadcast media through which the licensee provides gambling facilities (including domains covered by ‘white label’ arrangements).

Your company must submit a key event report to us if, in the case of remote gambling, it starts or stops providing gambling facilities on website domains (including mobile sites or apps) or broadcast media.

This requirement includes reporting of domains covered by ‘white label’ arrangements.

You must do this within five working days of you finding out about the event.

When reporting this key event, you should include the following information:

Starting of trading on website domains or broadcast media

Stopping of trading on website domains or broadcast media

All key events are to be reported to us via the key event part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this key event on eServices:

Key Event: Trading/website domain changes

You must also update the details of any domain names we have recorded against your company’s licence on the ‘Domain names’ part of eServices. This is important, as domain names appear on the record of your operating licence on our Public Register (opens in a new tab).

This reporting requirement applies only to holders of remote licences.

LCCP notifications (general)

This section provides guidance to holders of gambling operating licensees on general matters about reporting LCCP notifications.

An LCCP notification is a report to us about information we have asked for within our Licence conditions and codes of practice (LCCP) (opens in a new tab).

A summary of our LCCP notifications (opens in a new tab) is on our website.

General guidance on reporting LCCP notifications

If any of the LCCP notification matters happen within your business, you must tell us about this, via the LCCP notifications part of the eServices digital service (opens in a new tab) on our website.

You must tell us as about these matters as soon as reasonably possible. If, for any reason, you are delayed in reporting this information, you need to explain the reason for the delay in the ‘Detail’ box of the respective LCCP notification report.

If you experience technical issues preventing you submitting LCCP notifications to us via eServices, you should capture evidence of the problems experienced and contact us (opens in a new tab) to discuss the matter.

When submitting as LCCP notification, you must enter a date. This must be the date of the report. Details about the date of the event are to be recorded in the ‘Detail’ box.

You must also record the LCCP notification type. To ensure you do this correctly, refer to the specific guidance notes for each LCCP notification and select the correct notification type.

For each LCCP notification, you are given 1,500 characters in the ‘Detail’ box to provide a summary of the information we have asked for. If additional space is required, or if you need to provide supporting documentation, you can upload files associated with the notification.

For operators with multiple licences, LCCP notifications must be submitted within the eServices account of the licence relevant to the event you are telling us about.

This reporting requirement applies to holders of all operating licences.

LCCP notifications (reporting suspicion of offences)

This section provides guidance to holders of gambling operating licensees on how to tell us about:

Licence condition 15.1.1

Reporting suspicion of offences etc - non-betting licences

All operating licences except betting, betting intermediary, ancillary remote betting, betting host and remote betting intermediary (trading rooms only) licences

Licensees must as soon as reasonably practicable, in such form or manner as the Commission may from time to time specify, provide the Commission with any information that they know relates to or suspect may relate to the commission of an offence under the Gambling Act 2005, including an offence resulting from a breach of a licence condition or a code provision having the effect of a licence condition.

Your company must give us any information that it knows (or suspects) relates to an offence under the Gambling Act 2005 (opens in a new tab), including any offence arising because of a licence condition being broken.

Licence conditions and code provisions are contained within our Licence conditions and codes of practice (opens in a new tab).

If you have information relating to the above requirements, you must give this to us as soon as reasonably possible.

This information is to be reported to us via the LCCP notifications part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this LCCP notification on eServices:

LCCP Notification: Reporting offences/breaches

We do not prescribe what information should be entered into the LCCP Notification report, but it should include sufficient details of the offence, or suspected offence, for us to assess what action we may need to take. This information could include the details of businesses and / or persons involved, the offence, when it occurred, what has happened and actions by the licensee. Contact details of a person we can approach to ask for further information should also be included.

While it is acceptable for one licensee to provide information on behalf of another within a group, ultimate responsibility for the timing and content of the submission rests with the licence holder.

This reporting requirement applies to all operating licences except betting, betting intermediary, ancillary remote betting, betting host and remote betting intermediary (trading rooms only) licences. If you are a holder of any of these licences and have knowledge of, or suspect, an offence under the Gambling Act 2005 (opens in a new tab), refer to the guidance for LCCP 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

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

  • 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.

  • suspect may lead the Commission to consider making an order to void a bet under section 336 of the Gambling Act 2005.

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.

Your company must give us any information that it knows (or suspects) relates to an offence under the Gambling Act 2005 (opens in a new tab), including any offence arising because of a licence condition being broken.

Licence conditions and ordinary code provisions are contained within our Licence conditions and codes of practice (opens in a new tab).

You must also give us any information that you suspect may lead us to consider making an order to void a bet. Considerations we take into account when deciding when to void a bet are listed in the Gambling Act 2005, Section 336 (opens in a new tab).

The information about a known or suspected offence is to be reported to us via the LCCP notifications part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this LCCP notification on eServices:

LCCP Notification: Reporting offences/breaches

We do not prescribe what information should be entered into the LCCP Notification report, but it should include sufficient details of the offence, or suspected offence, for us to assess what action we may need to take. This information could include the details of businesses and/or persons involved, the offence, when it occurred, what has happened and actions by the licensee. Contact details of a person we can approach to ask for further information should also be included.

To report information that you suspect may lead us to consider making an order to void a bet, you must select the following type when entering this LCCP notification on eServices:

LCCP Notification: Voiding a bet

Provide details of the bet, including when the bet was made, the persons involved and any details about the race, competition or other event or process to which the bet related, or was to be conducted in contravention of industry rules. Explain what information was supplied in connection with the bet that was insufficient, false, or misleading.

Any information which relates to sports betting integrity should be sent directly to the Sports Betting Intelligence Unit (SBIU) (opens in a new tab) either by email to sbiu@gamblingcommission.gov.uk or other secure means as directed by the SBIU. You do not need to copy this information to our Intelligence team. When providing betting data to the SBIU you must use a standard template. To obtain a copy of this template, request a copy from the SBIU (quoting your operating licence or personal licence number).

If your company accepts bets on horse races or sporting events governed by one of the Sport Governing Bodies listed in the Gambling Act 2005, Schedule 6, Part 3 (opens in a new tab), or it provides help with making or accepting bets between others, you must also give the governing body relevant and necessary information, from whatever source, that you know or suspect may relate to a breach of betting rules applied by that governing body.

‘Betting rules’ includes any rule about bets which would be a regulated activity within the meaning of the Financial Services and Markets Act 2000, Section 22 (opens in a new tab). Details of betting rules for many of the Sport Governing Bodies can be found on the Sports Betting Group (opens in a new tab) website.

SBIU, in conjunction with the betting industry, has produced a Framework for Identifying Unusual or Suspicious Betting Patterns. The framework provides guidance to operators on identifying unusual and suspicious activity. It is available on request to licenced operators. Contact the SBIU if you need a copy.

Where it is unclear if information should be reported under this condition, you can email the SBIU or call on 0121 230 6939 to discuss the matter further.

If you have information relating to the above requirements, you must give this to us (and any relevant Sport Governing Bodies) as soon as reasonably possible.

While it is acceptable for one licensee to provide information on behalf of another within a group, ultimate responsibility for the timing and content of the submission rests with the licence holder.

These reporting requirements apply to all holders of betting operating licences including betting intermediary, ancillary remote betting, betting host and remote betting intermediary (trading rooms only) licences. 

Licence condition 15.1.3

Reporting of systematic or organised money lending

All non-remote casino, non-remote bingo, general betting, adult gaming centre, family entertainment centre and remote betting intermediary (trading rooms only) licence

Licensees must as soon as reasonably practicable, in such form or manner as the Commission may from time to time specify, provide the Commission with any information relating to cases where they encounter systematic, organised or substantial money lending between customers on their premises, in accordance with the ordinary code provisions on money lending between customers.

Ordinary code provision 3.8.1

Money-lending – casinos

All non-remote casino licences

There should be appropriate arrangements in place to cover any cases where it appears that the lending may be commercial in nature or may involve money laundering. In the latter case, the requirements in respect of reporting suspicious transactions must be followed. In all cases where the operator encounters systematic or organised money lending, a report should be made to the Commission.

Your company must give us any information that it knows (or suspects) relates to systematic, organised or substantial money lending, and may be commercial in nature or involve money laundering or terrorist financing.

This requirement is concerned with money lending between customers on gambling premises.

This information is to be reported to us via the LCCP notifications part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this LCCP notification on eServices:

LCCP Notification: Organised money lending

We do not prescribe what information should be entered into the LCCP Notification report, but it should include sufficient details of the money lending for us to assess what action we may need to take. This could include the details of businesses and/or persons involved, when it occurred, what has happened, the financial volumes involved, and actions taken by the licensee. Useful information about actions taken by your company would include telling us if the money lending has been reported to law enforcement and if the customers involved were barred by the licensee. Contact details for a person we can approach to ask for further informatio should also be included.

If your company decides that the lending appears to involve money laundering or terrorist financing, it must also reported in accordance with suspicious activity reporting arrangements (opens in a new tab). If you do submit a suspicious activity report (opens in a new tab), the unique reference number of the report must be reported to us as a key event under Licence condition 15.2.1 (15).

You must give us this information as soon as reasonably possible.

This reporting requirement applies to all holders of non-remote casino, non-remote bingo, general betting, adult gaming centre, family entertainment centre and remote betting intermediary (trading rooms only) licences.

Ordinary code provision 3.8.2

Provision of information in respect of cheating

All betting operating licences including betting intermediary, ancillary remote betting and remote betting intermediary (trading room only)

In considering their obligations under licence condition 15.1.2 licensees should in particular keep in mind the scope of the offence of cheating. The Commission would expect to be notified of any information a licensee has which causes them to know or suspect that there has been interference or attempted interference with:

  • an event which has taken or is taking place in Great Britain on which bets have been or are likely to be or to have been placed (whether in Great Britain or elsewhere)

  • an event which has taken or is taking place outside Great Britain on which bets have been or are likely to be or to have been placed in Great Britain.

Cheating is defined in the Gambling Act 2005 (Section 42) (opens in a new tab). Known or suspected offences of cheating must be reported to us under Licence conditions 15.1.1 (reporting suspicion of offences - non-betting licences) and 15.1.2 (reporting suspicion of offences - betting licences). See the guidance for these requirements for details on how to report cheating to us.

Additionally, your company must give us any information it has about known or suspected interference (or attempted interference) with:

Any information which relates to sports betting integrity should be sent directly to the Sports Betting Intelligence Unit (SBIU) (opens in a new tab) either by email to sbiu@gamblingcommission.gov.uk or other secure means as directed by the SBIU. When providing betting data to the SBIU you must use a standard template. To obtain a copy of this template, you must request a copy from the SBIU (quoting your operating licence or personal licence number).

Where it is unclear if information should be reported under this condition, you can call SBIU on 0121 230 6939 to discuss the matter further.

If you have information relating to the above requirements, you must give this to us as soon as reasonably possible.

This reporting requirement applies to all holders of betting operating licences including betting intermediary, ancillary remote betting and remote betting intermediary (trading room only).

LCCP notifications (other reportable events)

This section provides guidance to holders of gambling operating licences on how to tell us about other events which we need reported to us.

It includes how to tell us:

Licence condition 15.2.2

Other reportable events

All operating licences

Licensees must also notify the Commission in such form or manner as the Commission may from time to time specify, as soon as reasonably practicable of the occurrence of any of the following events:

  • any material change in the licensee’s arrangements for the protection of customer funds in accordance with the licence condition 4 (where applicable).

  • any change in the identity of the Alternative Dispute Resolution entity or entities for the handling of customer disputes, as required by the social responsibility code provision on complaints and disputes.

  • their becoming aware that a group company which is not a Commission licensee is advertising remote gambling facilities to those residing in a jurisdiction in, or to which it has not previously advertised or their becoming aware of a sustained or meaningful generation of 3% or 10% of group Gross Gambling Yield being exceeded by the group in that jurisdiction.

  • any actual or potential breaches by the licensee of the requirements imposed by or under Parts 7 or 8 of the Proceeds of Crime Act 2002, or Part III of the Terrorism Act 2000, or any UK law by which those statutes are amended or superseded.

Your company must submit a ‘other reportable event’ report to us if certain events happen. These are listed below.

You must tell us as about these events as soon as reasonably possible.

These reporting requirements apply to holders of all operating licences.

Significant changes to the company’s arrangements for protecting customer funds under LCCP Licence condition 4 (opens in a new tab).

Tell us the date of the change, the level of protection (opens in a new tab) in place and any major issues with the amount of protected funds held. Also tell us about any significant changes to how your company segregates customer funds and protects them in case of insolvency. We also need to know about significant changes to the terms and conditions or other disclosures your company provides to customers relating to the protection of customer funds.

This information is to be reported to us via the LCCP notifications part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this LCCP notification on eServices:

LCCP Notification: Customer funds protection

Changes to the Alternative Dispute Resolution (opens in a new tab) provider the company uses to handle customer disputes

Tell us the name of the new ADR provider, the date you appointed them and why you have changed provider or appointed an additional one. Note that the chosen ADR Provider(s) must be from our approved ADR provider list (opens in a new tab).

This information is to be reported to us via the LCCP notifications part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this LCCP notification on eServices:

LCCP Notification: ADR provider

If a group company which does not have a licence from us, advertises remote gambling to new jurisdiction or exceeds set Gross Gambling yield thresholds

Tell us the name, address and website of the company which does not have a licence from us, which new jurisdiction they are advertising remote gambling to and when this activity started. We also want to know if the group as a whole is advertising in a new jurisdiction.

In addition, you must tell us if the total Gross Gambling Yield (GGY) generated from providing gambling into that new jurisdiction, reaches 3% or more of your group’s total GGY. If your company group generates less than £5 million in GGY per year, you only need to tell us if the total GGY generated from the new jurisdiction is 10% or more of your group’s total GGY.

A company in your group includes any subsidiary or holding company and any subsidiary of such holding company. For a detailed explanation of the meaning of ‘subsidiary’ refer to the Companies Act 2006 (Section 1159) (opens in a new tab).This requirement includes companies which are incorporated outside of the United Kingdom.

Advertising includes having a home page directed towards a jurisdiction and written in, or in one of, that jurisdiction’s official language(s), having arrangements enabling that jurisdiction’s currency to be selected for gambling or the use of payment methods available only in that jurisdiction, and providing a specific customer service facility referable to that jurisdiction.

Guidance on how to calculate Gross Gambling Yield (GGY) (opens in a new tab) is available on our website.

This information is to be reported to us via the LCCP notifications part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this LCCP notification on eServices:

LCCP Notification: New jurisdiction (remote) (when your company is advertising remote gambling to a new jurisdiction)

LCCP Notification: Group GGY exceeds threshold (when a GGY threshold for group company GGY is exceeded)

If the company has broken or may have broken the requirements of the Proceeds of Crime Act 2002 or Terrorism Act 2000

Tell us about any breaches or potential breaches by your company of the requirements of the Proceeds of Crime Act 2002 (Parts 7) (opens in a new tab) or (Part 8) (opens in a new tab), or Terrorism Act 2000 (Part III) (opens in a new tab), or any law that amends or replaces them. These include reporting requirements in relation to known or suspected money laundering or terrorist financing activity, breaches of the tipping-off or prejudicing an investigation requirements, or committing one or more of the principle money laundering or terrorist financing offences. For this event, you do not need to tell us about breaches by your customers.

When reporting this event, you should include the following information:

This information is to be reported to us via the LCCP notifications part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this LCCP notification on eServices:

LCCP Notification: POCA & Terrorism Act breach

LCCP notifications (money laundering, terrorist financing etc))

This section provides guidance to holders of gambling operating licensees on how to tell us:

Licence condition 15.2.3

Other reportable events – money laundering, terrorist financing, etc

All non-remote and remote casino operating licences

Licensees must notify the Commission in such form or manner as the Commission may from time to time specify, as soon as reasonably practicable of any actual or potential breaches by the licensee of the provisions of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on Payer) Regulations 2017, or any UK Statutory Instrument by which those regulations are amended or superseded.

Licensees must, within 14 days of the appointment, notify the Commission of the identity of the individual appointed as:

  • the officer responsible for the licensee’s compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on Payer) Regulations 2017 (regulation 21(1)(a))

  • the nominated officer (regulation 21(3))

and any subsequent appointment to either of those positions.

Licensees must, within 14 days of the departure or removal of any individual appointed to the positions mentioned in 2 above, notify the Commission of such departure or removal.

If the company has broken or may have broken the requirements of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (opens in a new tab).

Your company must submit an LCCP notification report to us if it breaches, or is at risk of breaching, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (opens in a new tab), or any law that amends or replaces them.

You must give us this information as soon as reasonably possible.

When reporting this event, you should include the following information:

We only require you to tell us about actual or potential breaches by your company. This includes breaches of customer due diligence, record keeping and training requirements, and of the requirements for risk assessments and policies, procedures, and controls. For this requirement, you do not need to tell us about breaches by your customers (for example, if a customer has been unable to obtain satisfactory source-of-funds documentation).

This information is to be reported to us via the LCCP notifications part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this LCCP notification on eServices:

LCCP Notification: MF,TF & ToF Regs - breach

This reporting requirement applies to all holders of non-remote and remote casino operating licences.

Note, any actual or potential breaches by your company of the requirements imposed by the Proceeds of Crime Act 2002 (Part 7) (opens in a new tab) or (Part 8) (opens in a new tab), or Terrorism Act 2000 (Part III) (opens in a new tab), or any law that amends or replaces them, should not be reported under this event. Instead, refer to the guidance notes for LCCP Licence condition 15.2.2.

Changes to persons responsible for compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (opens in a new tab), or nominated officers

Your company must also submit an LCCP notification to us if it appoints:

You must do this within 14 days of you making the appointment. If the person appointed to any of the positions mentioned above changes, you must also tell us this within 14 days.

When reporting this matter, you should include the following information:

Additional information on the ‘nominated officer’ is provided in our guidance on The prevention of money laundering and combating the financing of terrorism (opens in a new tab) and advice on Duties and responsibilities under the Proceeds of Crime Act 2002 (opens in a new tab).

This information is to be reported to us via the LCCP notifications part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this LCCP notification on eServices:

LCCP Notification: ML,TF & ToF Regs - persons

This reporting requirement applies to all holders of non-remote and remote casino operating licences.

LCCP notifications (matters that could have a material impact on a business)

This section provides guidance to holders of gambling operating licensees on how to tell us about matters which could have a material impact on its business and its ability to comply with the licensing objectives listed in the Gambling Act 2005 (opens in a new tab).

Matters that could have a material impact on a business

Ordinary code provision 8.1.1

Information requirements – ordinary code

All licences

As stated earlier in this code, the Commission expects licensees to work with the Commission in an open and cooperative way and to inform the Commission of any matters that the Commission would reasonably need to be aware of in exercising its regulatory functions. These include in particular matters that will have a material impact on the licensee’s business or on the licensee’s ability to conduct licensed activities compliantly and consistently with the licensing objectives.

Thus, licensees should notify the Commission, or ensure that the Commission is notified, as soon as reasonably practicable and in such form and manner as the Commission may from time to time specify, of any matters which in their view could have a material impact on their business or affect compliance. The Commission would, in particular, expect to be notified of the occurrence of any of the following events in so far as not already notified in accordance with the conditions attached to the licensee’s licence:

  • any material change in the licensee’s structure or the operation of its business

  • any material change in managerial responsibilities or governance arrangements

  • any report from an internal or external auditor expressing, or giving rise to, concerns about material shortcomings in the management control or oversight of any aspect of the licensee’s business related to the provision of gambling facilities.

Your company must tell us about any matters which could have a material impact on its business and its ability to comply with the licensing objectives listed in the Gambling Act 2005 (opens in a new tab).

The licensing objectives are:

Examples of circumstances that will amount to a material impact are set out as follows (but not limited to):

When reporting these matters, you should include the following information:

If any of these material impacts happen within your business, you must tell us about them, via the LCCP notifications part of the eServices digital service (opens in a new tab) on our website.

You must select the following types when entering these LCCP notifications on eServices:

LCCP Notification: Matters of material impact

You must do this as soon as reasonably possible.

Note that some matters which could have a material impact on your business or affect compliance, are covered by our key event reporting requirements (opens in a new tab). If this is the case, and you have reported a matter to us by submitting a key event report, you do not need to submit a separate LCCP notification.

This reporting requirements applies to holders of all operating licences.

LCCP notifications (repeated attempts by children or young people to gamble)

This section provides guidance to holders of gambling operating licences (non-remote) on how to tell us about repeated attempts by children and young people to gamble on premises restricted to adults.

Ordinary code provision 3.2.2 (6)

Access to gambling by children and young persons – casinos ordinary code All non-remote casino licences

Procedures should be put into effect for dealing with cases where a child or young person repeatedly attempts to gamble on premises restricted to adults, including oral warnings, reporting the offence to the Gambling Commission and the police, and making available information on problem gambling.

Ordinary code provision 3.2.4 (4)

Access to gambling by children and young persons – AGC ordinary code

All adult gaming centre licences

Procedures should be put into effect for dealing with cases where a child or young person repeatedly attempts to gamble on premises restricted to adults, including oral warnings, reporting the offence to the Gambling Commission and the police, and making available information on problem gambling.

Ordinary code provision 3.2.6 (4)

Access to gambling by children and young persons – bingo and FEC ordinary code

All non-remote bingo and family entertainment centre licences

Procedures should be put into effect for dealing with cases where a child or young person repeatedly attempts to gamble on premises restricted to adults, including oral warnings, reporting the offence to the Gambling Commission and the police, and making available information on problem gambling.

Ordinary code provision 3.2.8 (4)

Access to gambling by children and young persons – betting ordinary code

All non-remote betting and remote betting intermediary (trading rooms only) licences

Procedures should be put into effect for dealing with cases where a child or young person repeatedly attempts to gamble on premises restricted to adults, including oral warnings, reporting the offence to the Gambling Commission and the police, and making available information on problem gambling.

Your company must tell us when a child or young person repeatedly attempts to gamble on premises restricted to adults.

A child means an individual who is less than 16 years old. A young person is an individual who is not a child but who is less than 18 years old.

You must give us this information as soon as reasonably possible.

When reporting these matters, you should include the following information:

This information is to be reported to us via the LCCP notifications part of the eServices digital service (opens in a new tab) on our website. You must select one of the following types when entering this LCCP notification on eServices:

LCCP Notification: U18 repeated gambling attempts

This reporting requirements applies to all holders of adult gaming centre licences, non-remote bingo and family entertainment centre licences, non-remote casino licences, and non-remote betting and remote betting intermediary (trading rooms only) licences.

Note, that it is an offence under the Gambling Act 2005 (Sections 48 and 49) (opens in a new tab) for a young person to gamble or to enter premises restricted to adults. It is also an offence for a person to invite or permit a child to gamble or enter a premise Gambling Act 2005 (Sections 46 and 47) (opens in a new tab). You need to report any occurrences of these offences to us separately, in accordance with LCCP Licence conditions 15.1.1 (Reporting suspicion of offences etc – non-betting licences) and 15.1.2 (Reporting suspicion of offences etc – betting licences).

You must also tell us about the total number of ‘People who have gambled were unable to verify their age’ as part of your company’s regulatory return.

LCCP notifications (society and local authority lotteries)

This section provides guidance to holders of lottery operating licences on telling us about the rules of lotteries they promote (and any amendments to these) and on how to submit audited accounts.

Licence condition 11.1.1

Lotteries – societies and local authorities

All lottery operating licences issued to non-commercial societies or local authorities

Para 11: Licensees must lodge with the Commission a description of, and a copy of the rules of, any lottery intended to be promoted in reliance on this licence, and any amendment to the rules of a lottery previously notified to the Commission, at least 28 days before any tickets in such lottery, or amended lottery, are put on sale.

Para 17: For any calendar year in which the cumulative proceeds of lotteries promoted in reliance on this licence exceed £1,000,000 the licensee must provide the Commission with written confirmation from a qualifying auditor confirming that the proceeds of those lotteries have been fully accounted for in their annual audited accounts. Such confirmation must be provided within ten months of the date to which the accounts are made up.

Lottery descriptions, rules and amendments

Before promoting a lottery, your company must send us a description of the lottery it intends to promote. You must also send us a copy of the rules that the lottery will apply.

Usually your company will have submitted this information with its original application for a licence but, if your company did not do this or if you if it has previously told us about a lottery, but changed the rules, you must send us a copy of the revised rules (referencing the lottery to which they apply).

In both cases, you must send us this information at least 28 days before any tickets in the lottery, or the amended lottery, are put on sale.

When reporting this information to us, you must include the following information:

This information is to be reported to us via the LCCP notifications part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this LCCP notification on eServices:

LCCP Notification: Lottery rules and amendments

You must upload a copy of the rules to be used for the lottery which you are telling us about.

Audited accounts

If, in any year, the cumulative proceeds of lotteries promoted by your company are more than £1 million, you must send us written confirmation that the proceeds of those lotteries have been fully accounted for in the company’s annual audited accounts.

This confirmation must be provided by a qualified auditor.

A qualified auditor is a statutory auditor who is approved to carry out the audit of annual financial accounts or consolidated accounts. The Register of Statutory Auditors (opens in a new tab) contains information on Statutory Auditors and Audit Firms in the U.K.

You must do this within 10 months of the date to which the annual accounts are made up.

This information is to be reported to us via the LCCP notifications part of the eServices digital service (opens in a new tab) on our website. You must select the following type when entering this LCCP notification on eServices:

LCCP Notification: Lottery audit confirmation

You must upload a copy of the written confirmation from the qualified auditor.

These reporting requirements apply to all holders of lottery operating licences issued to non-commercial societies or local authorities.

Other information requirements (test purchase results)

This section provides guidance to holders of gambling operating licences (non-remote) on how to tell us about age verification test purchase results.

Social responsibility code provision 3.2.1

Access to gambling by children and young persons – casinos SR code All non-remote casino licences

Licensees must conduct test purchasing or take part in collective test purchasing programmes as a means of providing reasonable assurance that they have effective policies and procedures to prevent underage gambling, and must provide their test purchase results to the Commission, in such form or manner as the Commission may from time to time specify.

Social responsibility code provision 3.2.3 (8)

Access to gambling by children and young persons – AGC SR code

All adult gaming centre licences

Licensees in fee category C or higher must conduct test purchasing or take part in collective test purchasing programmes, as a means of providing reasonable assurance that they have effective policies and procedures to prevent underage gambling, and must provide their test purchase results to the Commission, in such form or manner as the Commission may from time to time specify.

Social responsibility code provision 3.2.5 (7)

Access to gambling by children and young persons – bingo and FEC SR code

All non-remote bingo and family entertainment centre licences

Licensees in fee category C or higher must conduct test purchasing or take part in collective test purchasing programmes, as a means of providing reasonable assurance that they have effective policies and procedures to prevent underage gambling, and must provide their test purchase results to the Commission, in such form or manner as the Commission may from time to time specify.

Social responsibility code provision 3.2.7 (9)

Access to gambling by children and young persons – betting SR code

All non-remote general betting (standard) licences in fee category C or above

Licensees must conduct test purchasing or take part in collective test purchasing programmes, as a means of providing reasonable assurance that they have effective policies and procedures to prevent underage gambling, and must provide their test purchase results to the Commission, in such form or manner as the Commission may from time to time specify.

Your company must carry out test purchasing, or take part in collective test purchasing programmes, to assure itself that you have effective policies and procedures in place to prevent underage gambling.

You must give us the results of the test purchasing.

This reporting requirements applies to all holders of non-remote casino licences, adult gaming centre licences, non-remote bingo and family entertainment centre licences, and non-remote general betting (standard) licences in fee category C or above.

INTERIM guidance on test purchase result reporting (October 2020)

We will engage in due course with interested and most affected bodies to design and agree a format and manner for test purchasing results to be submitted.

In the interim period, test purchase results should be sent in a Microsoft Excel or comma-separated values (.csv) file format, to testpurchaseresults@gamblingcommission.gov.uk.

You must send us the results within 28 days of the end of the financial quarter when the test purchasing activity was conducted.

Other information requirements (complaints and disputes records)

This section provides guidance to holders of gambling operating licences on the records they must keep relevant to complaints and disputes.

Social responsibility code provision 6.1.1

Complaints and disputes

All licences (including ancillary remote licensees) except gaming machine technical and gambling software licences

Licensees should keep records of customer complaints and disputes and make them available to the Commission on request.

Your company should keep records of customer complaints and disputes relating to the provision of gambling facilities. These must be made available to us on request.

We do not specify a format for complaints and disputes records. However, we would expect the following basic data to be captured for all complaints that enter your formal complaints’ procedure:

Records should be retained for inspection for at least three years from the date of the resolution or conclusion of the complaint or dispute to which they relate.

We do not require your company to keep complaints about customer service or other non-gambling related complaints or disputes, although it may wish to do so.

Definitions and further information on complaints and disputes is contained within our Complaints and disputes: procedural, information provision and reporting requirements (opens in a new tab) document.

This reporting requirements applies to holders of all licences (including ancillary remote licensees) except gaming machine technical and gambling software licences.

Note, that you must also tell us about total numbers of complaints and referrals to ADR providers as part of your company’s regulatory return.

Other information requirements (lottery records and submissions)

This section provides guidance to holders of lottery operating licences on:

Licence condition 11.1.1

Lotteries – societies and local authorities

All lottery operating licences issued to non-commercial societies or local authorities

Accurate accounting records must be kept in relation to all lotteries promoted in reliance on this licence showing:

  • the total proceeds of each lottery;

  • the amount allocated to prizes in each lottery;

  • the amount of proceeds allocated to expenses, and details of those expenses, for each lottery;

  • the amount applied directly to the purposes of the society or purposes for which the local authority has power to incur expenditure as the case may be; and

  • the number of sold and unsold tickets in each lottery.

Such records must be made available to the Commission for inspection on request and retained for at least three years from the date of any lottery to which they relate.

In addition, in respect of each lottery promoted in reliance on this licence, a lottery submission must be sent to the Commission within three months of the date of determination of the lottery or, in the case of an ‘instant lottery’, within three months of the last date on which tickets in the lottery were on sale providing the information set out…above. Every such submission must contain or be accompanied by a declaration that the information given in it is correct and must be shown to have been approved before submission by:

  • the holder of a personal management licence,

  • ‘qualified person’ as defined in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006 or,

  • except where the licensee is a local authority, the designated person named on the lottery tickets as having responsibility for the promotion of the lottery.

Accounting records for lotteries

Your company must keep accounting records relevant to each lottery it offers. As a minimum, the record must include the following information:

Records should be retained for inspection for at least three years from the date of any lottery to which they relate.

Lottery submissions

Operators of non-commercial society lotteries and local authority lotteries must also submit information to us about each lottery they have conducted. Guidance notes on lottery submissions (opens in a new tab) are available on our website. These notes explain what details are to be submitted to us and when.

Other useful information on lotteries is contained with our advice for society lotteries, local authority lotteries and external lottery managers about the requirements relating to the distribution of lottery proceeds (opens in a new tab) .

Lottery submissions must be made via our eServices digital service (opens in a new tab). Further guidance notes for completing lottery submission on eServices (opens in a new tab) are also available on our website.

Each submission must be approved by a relevant and authorised person. This is either the holder of a personal management licence employed by the operating licence holder to which the lottery relates, a qualified person (opens in a new tab), or (for a local authority) the person named on the lottery tickets as promoter of the lottery.

These reporting requirements apply to all holders of lottery operating licences issued to non-commercial societies or local authorities. 

Other information requirements (pool betting)

This section provides guidance to holders of pool betting operating licences on the transaction and other records they must keep relevant to each pool they offer.

Licence condition 13.1.1

Pool betting

All pool betting operating licences, except those restricted to football pools

Licensees and any person they so authorise under section 93(2) of the Gambling Act 2005 to offer pool betting on a track in connection with a horserace or dog race in reliance on an occasional use notice, must produce and retain a record of the transactions relevant to each pool that they offer. The record must be capable of identifying individual bets into the pool and relating these to subsequent payment of winnings where applicable. Licensees must make this information available to the Commission on request.

Your company must keep transaction records relevant to each pool it offers. Any person it authorises under the Gambling Act 2005, Section 93(2) (opens in a new tab) must also keep transaction records for each pool they offer.

These records must identify individual bets that are related to the payment of winnings, where applicable. As a minimum, the record of transactions must include, for each bet, the following information:

Your company must only accept bets through equipment capable of communicating bets to a central recording system. Any person it authorises under the Gambling Act 2005, Section 93(2) (opens in a new tab) must also only accept bets through such a system. The central recording system must collect all bets made to each of the operator’s pools and all information required to calculate the winnings of each pool and be capable of storing this information for subsequent retrieval if required by us. See LCCP Social responsibility code provision 4.2.10 for further information.

Your company must also keep records of the persons it authorises under Section 93(2) (opens in a new tab) to offer pool betting on a track in reliance on an occasional use notice. These should include the terms and conditions under which this has been agreed, and contact details of the management and key staff of those that are authorised.

Records should be retained for inspection for at least three years from the date of any transaction to which they relate.

This reporting requirement applies to all pool betting operating licences, except those restricted to football pools.

Licence condition 13.1.2

Pool betting – football pools

All pool betting operating licences which authorise football pools

Licensees and any person they so authorise under Section 93(3) of the Gambling Act 2005 in respect of football pool betting, must produce and retain a record of the transactions relevant to each pool that they offer. The record must be capable of identifying individual bets into the pool and relating these to the subsequent payment of winnings where applicable. Licensees must make this information available to the Commission on request.

Your company must keep transaction records relevant to each pool it offers. Any person it authorises under the Gambling Act 2005, Section 93(3) (opens in a new tab) must also keep transaction records for each pool they offer.

These records must identify individual bets that are related to the payment of winnings, where applicable. As a minimum, the record of transactions must include, for each bet, the following information:

Your company must only accept bets through equipment capable of communicating bets to a central recording system. Any person it authorises under the Gambling Act 2005, Section 93(3) (opens in a new tab) must also only accept bets through such a system. The central recording system must collect all bets made to each of the operator’s pools and all information required to calculate the winnings of each pool and be capable of storing this information for subsequent retrieval if required by us. See LCCP Social responsibility code provision 4.2.10 for further information.

Your company must also keep records of the persons it authorises under Section 93(3) (opens in a new tab) to offer pool betting on a track in reliance on an occasional use notice. These should include the terms and conditions under which this has been agreed, and contact details of the management and key staff of those that are authorised.

Records should be retained for inspection for at least three years from the date of any transaction to which they relate.

This reporting requirement applies to all pool betting operating licences which authorise football pools.

Personal licence key events (general)

This section provides guidance to holders of gambling personal licenses on general matters about reporting personal licence key events.

A personal licence key event is an event that could have a significant effect on the suitability of a person to hold a personal licence. These key events are listed in Part III of the Licence conditions and codes of practice (LCCP).

View a summary of personal licence key events.

General guidance on reporting personal licence key events

Personal licence key events must be reported to us through the Manage and maintain your licence digital service on our website.

You must do this within ten working days of you finding out about the event. If, for any reason, you report the event to us after ten working days, you need to explain the reason for the delay in the ‘Detail’ box of the respective personal licence key event report.

If you experience technical issues preventing you reporting key events to us via the ‘Manage and maintain your licence’ digital service, you should capture evidence of the problems experienced and contact us to discuss the matter.

When submitting a personal licence key event, you will be asked to ‘Select an event’. Choose the event type which matches the event you are reporting.

For each personal licence key event report, you are given 1,500 characters in the ‘Detail’ box to provide a summary of the event. If additional space is required, or if you want to provide supporting documentation, you can upload files associated with the personal event.

When submitting a personal licence key event report, you must enter a date. This must be the date of the notification. Details about the date of the event are to be recorded in the ‘Detail’ box.

For changes to your name or address, use the ‘Manage your details’ option within the Manage and maintain your licence (opens in a new tab) digital service. This will create a personal licence key event report automatically.

This reporting requirement applies to all holders of personal licences.

Personal licence key events (specific)

This section provides guidance to holders of gambling personal licenses on key events they need to report to us.

A personal licence key event is an event that could have a significant effect on the suitability of a person to hold a personal licence.

Specific guidance on reporting personal licence key events

Personal licence conditions

All personal licence holders

Personal licence holders must themselves notify the Commission of the occurrence of any of the following key events within ten working days after the licensee becomes aware of the event’s occurrence:

  • their subjection to any criminal investigation which is listed under Schedule 7 Relevant Offences of the Gambling Act 2005;

  • their conviction of any offence listed under Schedule 7 – Relevant Offences of the Gambling Act 2005;

  • any current or pending investigation by a professional, statutory, regulatory or government body in Great Britain or abroad;

  • the imposition of any sanction or penalty against them following an investigation by any professional, statutory, regulatory or government body in Great Britain or abroad;

  • the imposition of a disciplinary sanction against them, including dismissal, for gross misconduct;

  • their resignation from a position for which a personal licence is required following commencement of disciplinary proceedings in respect of gross misconduct;

  • their disqualification from acting as a company director;

  • the presentation of a petition for their bankruptcy or sequestration or their entering into an individual voluntary agreement;

  • a change in their name or address.

You must submit a personal licence key event report to us if certain events happen. These are listed below.

These reporting requirements apply to all holders of personal licences.

An investigation of an offence under the Gambling Act 2005, Schedule 7 (opens in a new tab)

Tell us what offence you are being investigated for and the position and employer the investigation relates to. If you are being investigated for multiple offences at the same time, tell us about these within the same report. Include a summary of the reasons for the investigation and the date it started.

Conviction of any offence listed under the Gambling Act 2005, Schedule 7 (opens in a new tab)

Tell us what offence you were convicted of and the sentence passed. If you were convicted of multiple offences at the same time, tell us about these within the same report.

Any current or pending investigation by a professional, statutory, regulatory or government body in Great Britain or abroad

Tell us why your actions are being investigated and what position and employer the investigation relates to. Provide the name of the professional, statutory, regulatory or government body. If that body is based overseas, provide the website and address details for that body. Include a summary of the reasons for the investigation and the date it started or will start.

The imposition of any sanction on or penalty against you following an investigation by any professional, statutory, regulatory or government body in Great Britain or abroad

Tell us what the sanction or penalty is, when it was imposed and what position and employer it relates to. Provide the name of the professional, statutory, regulatory or government body. If that body is based overseas, provide the website and address details for that body. Include a summary of the reasons for the sanction or penalty being imposed.

The imposition of a disciplinary sanction imposed against you, including dismissal, for gross misconduct

Tell us what the sanction is, when it was imposed and what position and employer it relates to. Include a summary of the reasons for the gross misconduct. You do not tell us about disciplinary sanctions imposed by your company that were not for gross misconduct.

Your resignation from a position for which a personal licence is required following commencement of disciplinary proceedings in respect of gross misconduct

Tell us what position and employer your resignation relates to. Include a summary of the reasons for the gross misconduct allegations.

Your disqualification from acting as a company director

Tell us when the disqualification begins and will end, the reason you were disqualified, the names of companies relevant to your disqualification, and if you have the court’s permission to continue to act as a director.

The presentation of a petition for your bankruptcy, or sequestration (applies only in Scotland), or your entering into an individual voluntary agreement

Tell us about the circumstances that led to the bankruptcy, sequestration or individual voluntary agreement, including the date the event occurred, what information you have provided to your employer about the matter, and if your employer is taking any disciplinary action as a result. Upload copies of the bankruptcy order, sequestration order or individual voluntary agreement.

In the case of bankruptcy and sequestration, note that your licence will automatically lapse after you inform us of this event, so also tell us if you intend to re-apply for a licence and when you intend to re-apply.

Also note that anyone who has a bankruptcy order (‘undischarged bankrupts’), a debt relief order or bankruptcy restrictions is banned from being the director of a company. If this applies to you, you need to submit a separate personal event report telling us that you have been disqualified from acting as a company director.

Change your name or address

You must tell us your new name or address.

For changes to your name or address, use the ‘Manage your details’ option within the Manage and maintain your licence (opens in a new tab) digital service. This will create a personal licence key event report automatically.