The publication of the Government’s gambling White Paper, High Stakes: Gambling Reform for the Digital Age in April 2023, marked the most significant reform initiative in gambling regulation since the Gambling Act 2005. Published under the Conservative government, the White Paper aimed to modernise the regulatory framework governing the gambling sector, ensuring a balance between providing consumers with freedom and choice whilst protecting them from harm. The White Paper was structured around six main themes, namely; online protections – players and products, marketing and advertising, the Gambling Commission’s powers and resources, dispute resolution and consumer redress, children and young adults and land-based gambling, each setting proposed changes to be made across all six areas.
Early days of the White Paper
The Government originally aimed to implement the majority of the White Paper proposals by summer 2024, which was a tight deadline – particularly for those that required secondary legislation. However, the Department for Culture and Media and Sport (“DCMS”) was keen to make progress, launching its Summer 2023 consultation in July 2023, which proposed a number of changes to the Licence Conditions and Codes of Practice (“LCCP”) and Remote Gambling and Software Technical Standards (“RTS”).
Towards the end of 2023, implementation efforts gathered pace. In November 2023, the Gambling Commission opened its Autumn 2023 consultation consulting on a number of changes regarding: (a) socially responsible incentives; (b) customer-led tools; (c) improved transparency on customer funds in the event of insolvency; (d) changes to the frequency of regulatory return submissions; and (e) removing obsolete Gambling Commission requirements due to the government’s upcoming statutory levy.
As the first anniversary of the White Paper’s publication passed, momentum continued with the Gambling Commission publishing its response to its Summer 2023 Consultation on 1 May 2024, setting out its planned approach to financial vulnerability checks, remote game design, direct marketing and some land-based changes. The consultation response provided the industry with some certainty and signalled a transition from consultation to implementation.
Concurrently, DCMS published its response to its consultation on measures relating to the land-based gambling sector on 16 May 2024. The response outlined the proposed implementation of measures to relax casino rules for 1968 Act casinos, increase gaming machine entitlement ratios in arcades and bingo halls, accept cashless payments on gaming machines, introduce a legal age limit of 18 for category D slot style machines and increase local authority fees. The majority of these reforms required secondary legislation to be implemented. Despite the Gambling Commission and DCMS’s efforts thus far, the announcement of a General Election on 22 May 2024 abruptly shifted political priorities.
The General Election, which took place on 4 July 2024 (months earlier than expected) had an impact on the pace of reform seen to date. The election resulted in a new Labour government and as the new administration took office, proposals that required secondary legislation and parliamentary time were put on hold and momentum in implementing the White Paper proposals slowed. The Government’s initial target of implementing the key proposals by summer 2024 passed without delivery and for much of the latter half of 2024, the industry awaited confirmation that the reform effort would continue in the same direction under the new government.
White Paper review: The last 12 months
After a quieter period throughout the summer of 2024, the industry experienced a resurgence of reform activity initiated by DCMS publishing its initial response to its consultation on the statutory levy and its approach regarding stake limits for online slots in November 2024 (which were originally anticipated to come into effect in September 2024).
Throughout the first quarter of 2025, activity continued to increase. The Gambling Commission launched its January 2025 consultation regarding Gaming Machine Technical Standards, Testing Strategy and LCCP, published responses to its Autumn 2023 consultation on 4 February 2025 and 26 March 2025 and launched a supplementary consultation regarding updates to the RTS on 6 March 2025.
On 25 February 2025, The Gambling Levy Regulations 2025 and The Gambling Act 2005 (Operating Licence Conditions) (Amendment) Regulations 2025 were both signed into law, cementing further reforms in relation to the statutory levy and online slots stake limits respectively.
By the summer of 2025, the industry’s original feeling of uncertainty around the new Labour government’s approach to the regulatory reforms were a thing of the past, with DCMS and the Gambling Commission proving that their commitment to the White Paper had not dwindled post-election. A series of statutory instruments were signed into law in July 2025, extending entitlements to licensees in the non-remote casino sector, and the Gambling Commission prepared for the first collection of the statutory levy in the Autumn of this year.
Key highlights
At the time of writing, significant progress has been made with a number of key proposals coming into effect addressing the majority of the six main themes originally carved out in the White Paper.
Various measures have been implemented focusing on online player protections. The most significant of which being the introduction of light-touch financial vulnerability checks for gambling customers with a net deposit of more than £150 a month. Arguably the most controversial White Paper proposal, the introduction of such checks is a milestone for the industry. In addition, the Gambling Commission’s three-stage pilot scheme to test how enhanced financial risk assessments will work in practice is still ongoing with the industry awaiting the Gambling Commission’s findings.
The introduction of online slots stake limits at £5 for those aged 25 and over and £2 for those aged 18-24 years old marked a significant measure in the interest of protecting young adults from gambling-related harm.
Reforms to marketing and advertising were introduced through social responsibility code provision (“SRCP”) 5.1.12, requiring licensees to provide customers to opt-in to direct marketing on a per product and per channel basis. On 26 March 2025, the Gambling Commission issued a response to its Autumn 2023 consultation confirming further amendments to SRCP 5.1.1 due to come into effect on 19 January 2026. The changes place a ban on mixed product promotions and limit wagering requirements on bonus funds to a maximum of ten.
On 10 July 2025, the Gambling Commission announced improvements to its approach to enforcement by confirming amendments to its Statement of Principles for Determining Financial Penalties. The changes took effect on 10 October 2025. John Pierce, the Director of Enforcement and Intelligence at the Gambling Commission stated that “the resulting changes will strengthen [the Gambling Commission’s] decision-making and streamline the calculation of penalties – helping to improve the efficiency and effectiveness of [the Gambling Commission’s] enforcement work.”
The introduction of the statutory levy to replace the previous voluntary RET contribution marked another milestone change for the industry. The first statutory levy invoices, which are calculated as a percentage of gross gambling yield as submitted by licensees to the Gambling Commission in their quarterly regulatory returns, were issued on 1 September 2025, with payment due by 1 October 2025.
Long overdue reform to the land-based sector was introduced through the enactment of statutory instruments in July 2025. Holders of converted casino premises licences originally issued under the Gaming Act 1968 are now able to access new entitlements, including an increased gaming machine entitlement of up to 80 machines on a sliding scale (if certain conditions are met) and the offering of sports betting.
One area which has not progressed is the voluntary creation of a non-statutory Gambling Ombudsman, one of the cornerstone proposals of the White Paper. The Gambling Ombudsman is intended to be an independent, free to use, non-statutory body to handle social responsibility complaints from consumers. It was originally proposed that the Gambling Ombudsman would start taking claims from summer 2024.
Timeline of last 12 months
- 27 November 2024 – DCMS published its initial response to a consultation on the structure, distribution and governance of the statutory levy. The response confirmed that the Gambling Commission will collect and administer the levy under the strategic direction of the UK Government, replacing the existing system of voluntary industry contributions.
- 29 November 2024 – New requirements were introduced under licence condition 1.2.1 to clarify and increase personal management licence (“PML”) coverage. CEOs, Managing Director or equivalent, Board Chair and the person responsible for the anti-money laundering and counter terrorist financing function are all required to hold a PML.
- 5 December 2024 – DCMS announced its Gambling Act Review evaluation plan. DCMS expects the evaluation to be reported in 2026.
- 17 January 2025 – Updates to the RTS regarding game design came into effect. The changes introduced a minimum speed of play and requirements to display the amount of time and spend.
- 29 January 2025 – The Gambling Commission launched its January 2025 consultation which set out proposed changes to the Gaming Machine Technical Standards, the Gaming Machine Testing Strategy and the LCCP. The proposals relate to: (a) consolidating and updating the existing 12 gaming machine technical standards into a single standard; and (b) in respect of safe use of gaming machines, introducing five new standards, a licence condition and a social responsibility code provision. The consultation closed on 3 June 2025, and the Gambling Commission is yet to publish a response.
- 30 January 2025 – The Gambling Commission published its guidance on online stake limits.
- 4 February 2025 – The Gambling Commission published its response to the Autumn 2023 consultation. The response confirmed: (a) new requirements for customer led tools to give consumers more effective ways to manage their gambling by making it easier to set and maintain deposit limits on their online accounts; (b) the requirement that operators whose customer funds are ‘not protected’ in the event of insolvency must actively remind customers once every six months that their funds are not protected; and (c) the removal of the requirement to make RET payments to pave the way for the new statutory levy.
- 10 February 2025 – The Gambling Commission published an update on the three-stage financial risk assessment pilot, confirming that the first of the three stages was complete.
- 25 February 2025 – Statutory Instrument, The Gambling Act 2005 (Operating Licence Conditions) (Amendment) Regulations 2025, signed into law, adding a new licence condition to all remote casino operating licences which introduces a maximum stake limit for online slots games in Great Britain. The total amount which an individual may stake in relation to any game cycle may not exceed: (a) £2, where the individual is less than 25 years old; and (b) £5, where the individual is 25 years old or over.
- 25 February 2025 – Statutory Instrument, The Gambling Levy Regulations 2025, signed into law, requiring all operating licence holders in Great Britain to pay a mandated levy to the Gambling Commission.
- 28 February 2025 – The requirement set out in SRCP 3.4.4(7) for financial vulnerability checks at £500 a month reduced to £150 a month, as set out in SRCP 3.4.4(6).
- 6 March 2025 – The Gambling Commission launched its supplementary consultation setting out proposals relating to the definition of financial limits in the RTS. The Gambling Commission consulted on three proposals regarding: (a) revisions to the RTS so as a minimum and default, ‘gross’ deposit limits are offered to customers; (b) ensure the term ‘deposit limit’ is used consistently by operators; and (c) provide increased consumer choice by amending the implementation guidance to allow for ‘net’ limits in addition to other types of financial limits.
- 26 March 2025 – The Gambling Commission published a further response to its Autumn 2023 consultation. The response confirmed: (a) a ban on operators offering mixed product promotional offers; (b) a requirement to cap the wagering requirement on bonus funds to 10; and (c) rewording SRCP 5.1.1 (Rewards and Bonuses) of the LCCP to ensure clarity of the Gambling Commission’s expectations of operators around socially responsible incentives. Requirements are to come into effect on 19 January 2026.
- 31 March 2025 – The removal of SRCP 3.1.1(2) of the LCCP requiring licensees to make annual financial contributions to a list of research, prevention and treatment organisations.
- 6 April 2025 – The Gambling Levy Regulations 2025 came into force. The statutory levy is calculated as a percentage of revenue (0.1% to 1.1%, depending on licensable activities) declared in a licensee’s regulatory returns within the leviable period. The leviable period shall run from 1 April to 31 March each year (except for the first-year levy period which was calculated by the sum of revenue between 1 July 2024 to 31 March 2025 multiplied by one and one third). Statutory levy invoices shall be issued to licensees on 1 September annually, with payment due before 1 October of that year.
- 9 April 2025 – The Gambling Act 2005 (Operating Licence Conditions) (Amendment) Regulations 2025 came into effect, requiring licensees who hold a remote casino operating licence to introduce a maximum stake limit of £5.
- 1 May 2025 – New direct marketing requirements came into force. The introduction of SRCP 5.1.12 requires licensees to provide customers with options to opt-in to direct marketing on a per product, per channel basis.
- 21 May 2025 – The £2 stake limit for 18 to 24 year olds came into effect.
- 21 May 2025 – The Gambling Commission issued an update on its three-stage financial risk assessment pilot. The Gambling Commission confirmed that Stage three of the pilot was now in reporting stage and that Stage three and post-pilot analysis would be used to further explore how the assessments could be targeting where there is most financial risk. The analysis phase was expected to run into the summer of 2025. At the time of writing, there has been no further update on the financial risk assessment pilot.
- 1 July 2025 – A number of statutory instruments were signed into law allowing holders of a converted premises licence, originally issued under the Gaming Act 1968, to access new entitlements including increased gaming machine entitlements of up to 80 machines on a sliding scale (if certain conditions are met) and the offering of sports betting (collectively the “Non-remote Casino Legislative Changes”). Under the Non-remote Casino Legislative Changes, 2005 Act Small casinos also benefit from a reduction of the minimum table gaming area and an increase in gaming table ratio.
- 10 July 2025 – The Gambling Commission published its response to its December 2023 consultation. The response confirmed updates to the Gambling Commission’s Statement of principles for determining financial penalties to bring greater clarity and transparency by: (a) providing a seven-step process that the Gambling Commission will follow when assessing and imposing a financial penalty; (b) transparency on how the level of seriousness of a breach will be determined with five levels of seriousness; (c) the starting point of the penal element of a penalty will be by reference to seriousness and a percentage of Gross Gambling Yield (GGY) or equivalent; and (d) making adjustments to penalties based on aggravating/mitigating factors, deterrence and early resolution.
- 22 July 2025 – The Non-remote Casino Legislative Changes came into effect.
- 22 August 2025 – The Gambling Commission published guidance on the calculation and collection of the statutory gambling levy.
- 1 September 2025 – Invoices for the first statutory levy were issued online through eServices, with full payment of the statutory levy required before 1 October 2025.
- 9 September 2025 – The Gambling Commission published guidance on the Non-remote Casino Legislative Changes.
- 7 October 2025 – The Gambling Commission published its response to its supplementary consultation to the Autumn 2023 consultation. The response confirmed that there will be further changes to RTS 12 (Financial limits) to: (a) require operators to provide customers with the opportunity to set a ‘deposit limit’ which is based solely on the amount a customer pays into their account over a set duration; and (b) amend implementation guidance to allow operators to be able to offer different limits, such as loss limits or limits where withdrawals are also taken into account. The changes to RTS 12 shall come into effect on 30 June 2026.
- 10 October 2025 – Proposed changes to the Statement of principles for determining financial penalties came into effect.
- 15 October 2025 – DCMS launched a consultation on Category D gaming machines and licensing for bingo premises on 15 October 2025. The consultation relates to the categorisation of category D gaming machines and changes to stake/prize limits for certain categories. Additionally, the consultation includes proposals to make it an offence to invite, cause or permit anyone under the age of 18 to use ‘cash out’ slot-style category D machines, and a key proposal relating to the establishment of a ‘bingo area’ in all licensed bingo premises to help create a clearer distinction between adult gaming centres and bingo premises.
- 31 October 2025 – Updates to the RTS, originally consulted on in the Gambling Commission’s Autumn 2023 consultation, requiring operators to prompt their customers to set a financial limit, making it easier for the customer to set and maintain deposit limits on their online accounts, came into force.
- 31 October 2025 – An additional paragraph was added to licence condition 4.2.1 requiring licensees who have selected a ‘not protected’ rating in respect of customer funds, to remind the customer every six months that their funds are not protected in the event of insolvency. The customer must acknowledge receipt of this information before they are able to utilise these funds for gambling.
What’s next for the White Paper
Changes to be implemented include:
- 19 January 2026 – Changes to SRCP 5.1.1 come into effect. Licensees must cap wagering requirements on bonus funds to a maximum of ten and will no longer be able to include more than one type of gambling product within an incentive.
- 30 June 2026 – Changes to RTS 12 (Financial limits) come into effect, providing further consistency and clarity for customers when setting financial limits.
Other areas which are awaited:
- Outcome of the Gambling Commission’s financial risk assessment pilot, which was conducted to test how enhanced financial risk assessments will work in practice.
- Establishment of the Gambling Ombudsman.
- Publication of the Gambling Commission’s remaining response to its December 2023 consultation regarding changes to financial key event reporting. The consultation proposed changes to financial key event reporting to raise the current reporting threshold of a member holding 3% or more of the issued share capital of a licensee or its holding company to 5%, to align with requirements in other global jurisdictions.
- DCMS’s consultation on Gambling Commission fees, as proposed in the White Paper.
Two-and-a-half years on from the publication of the White Paper, the aim of ensuring that “gambling regulation meets the challenges and seizes the opportunities which have come with the changes since the Gambling Act 2005” is gradually being realised. Despite initial delays brought by political change and the challenge of implementing such wide-ranging reform, the pace of progress has notably accelerated throughout 2025. The introduction of the statutory levy, online stake limits, financial vulnerability checks, and strengthened player protection measures represent some of the most tangible outcomes to date. Whilst a handful of proposals remain outstanding, most notably the long-anticipated establishment of the Gambling Ombudsman, both DCMS and the Gambling Commission have demonstrated a sustained commitment to the White Paper’s objectives, ensuring continued momentum into 2026. As the sector moves forward, the focus will increasingly shift from consultation to consolidation, embedding these reforms into practice and ensuring that the UK’s regulatory framework remains fit for the digital age.