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Report

Annual report and accounts 2024 to 2025

The Gambling Commission's 2024 to 2025 annual report and accounts. For the period 1 April 2024 to 31 March 2025.

Strategic Focus 5 - Regulating a successful National Lottery

The National Lottery remains one of the most recognisable brands in the country. Since its inception in 1994, it has changed lives, both for those who have won prizes and those who benefitted from the funds raised for Good Causes. Since 1994, the Lottery has paid out more than £95 billion in prize money and generated over £50 billion for Good Causes.

The Fourth National Lottery (4NL) Licence started on 1 February 2024 with Allwyn succeeding Camelot UK Lotteries Limited as the licensee.

Our priority, in accordance with our core regulatory objectives, is to uphold the National Lottery duties, which are propriety, protecting participant interests, and subject to both those duties, ensuring the maximisation of returns to Good Causes.

Our Corporate Strategy for 2024 to 2027 recognises that a successful 4NL licence is paramount to achieving these outcomes.

Fully embed Fourth National Lottery controls

The 4NL Programme team have managed the competition and implementation oversight of 4NL within the Gambling Commission. In May 2025, the Commission’s Board approved a further extension of the 4NL Programme to December and then a shift from a programme to a special project alongside the team who manage the ongoing 4NL Regulation. The Commission continues to assess its resource requirements to ensure appropriate oversight of Allwyn’s delivery.

The completion of the 4NL Competition Programme activities is aligned to Allwyn’s delivery of its application. This includes agreed upgrades to the systems, the website and mobile application, to enhance the user experience and ensure the National Lottery is fit for purpose for the duration of the Licence and beyond.

The new licence adopts an outcomes-based model giving the licensee greater responsibility to fulfil its obligations and was designed with a new incentive mechanism that better aligns contributions to Good Causes with the licensee’s profits. We established a new team and introduced processes and procedures that reflect the change in approach to regulation whilst continuing to retain the ability to intervene where appropriate. Our routine regulatory activity includes consideration of a series of reports designed to provide assurance to the Commission that Allwyn is complying with the terms of the Licence and the commitments made in their application, in line with the Commission’s statutory duties.

Allwyn did not deliver full functionality (being all elements of their Application in the competition which they originally committed to deliver by Licence Start Date) by February 2025 as it was contractually required to do and, as a consequence, an enforcement investigation, in line with the Fourth National Lottery Licence Regulatory Handbook, was initiated by the Commission and is ongoing. This process is separate from the day-to-day regulation of the National Lottery and any decision taken will be done so independently.

There is active litigation against the Commission brought by The New Lottery Company (TNLC), one of the unsuccessful bidders for the 4NL licence. There are 2 claims, alleging a breach of the Concession Contracts Regulations 2016, the first in respect of the evaluation of the Fourth National Lottery Competition bids and the second relating to modifications made to the Enabling Agreement and the Licence governing the transition to and operation of the National Lottery. During the legal process to date, there have been additional legal hearings on a variety of issues, including rulings as a result of the inadvertent disclosure of documents by advisors working on behalf of the Commission, where those documents were privileged or partially privileged and were not intended for release as part of the Commission’s disclosure requirements. The Commission is robustly defending the claims and continues to work with its external lawyers to effectively manage the ongoing obligations up to trial, which is set for October 2025. The Commission has assessed this litigation as a contingent liability, see Note 15.

In March 2025, the Commission received a further legal challenge from TNLC, who have submitted a claim to the Competition Appeal Tribunal (CAT) challenging the Commission’s decision to approve a marketing investment proposal in 2023, in relation to the Third National Lottery Licence. TNLC are seeking a review of this decision under a new piece of legislation that came into force in 2023, the Subsidy Control Act. This is a live legal case and at an early stage of proceedings. The Commission’s National Lottery team was also responsible for overseeing the successful closedown of the Third Licence (3NL), ensuring that Camelot complied with all its obligations as outgoing licensee.

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