Betting and Gaming horizon scanning: UK regulatory roadmap: Winter 2025 edition

Updates to the remote gambling and software technical standards (RTS) came into force on 17 January 2025 regarding online game design. This introduces new rules, for example, autoplay cannot be offered for online gaming and features such as turbo, quick spin and slam stop are not permitted.

The Gambling Commission has launched a new consultation on proposed changes to the Gaming Machine Technical Standards, Gaming Machine Testing Strategy and Licence Conditions and Codes of Practice. The closing date is 20 May 2025. The proposals aim to introduce five new standards, a licence condition, and a social responsibility code to help consumers use gaming machines safely, including features for setting time and monetary limits and providing safer gambling information. Additionally, they propose amending three existing standards to enhance customer enjoyment, consolidating the 12 current gaming machine technical standards into a single clearer standard, and updating the gaming machine technical standards and related testing strategy to remove outdated material.

The Gambling Commission published a response to three topics in the Autumn 2023 consultation on the white paper proposals and has announced various changes. From 31 October 2025, gambling businesses must prompt customers to set financial limits before their first deposit and remind them every six months to review their account and transaction information. In addition from 31 October 2025, operators must remind customers every six months if their funds are not protected in the event of insolvency. The Commission will also introduce changes to the Licence Conditions and Codes of Practice to facilitate the implementation of the Government's upcoming statutory levy, this will replace the current requirement for operators to make annual financial contributions to research, prevention, and treatment organisations. The replacement will be implemented close to the implementation of the statutory levy which is expected to be 6 April 2025. The Commission has also said the consultation revealed that deposit limits were being interpreted by licensees in different ways. It will therefore shortly publish a supplementary consultation on ‘gross deposit limits’.

In August 2024, remote operators began conducting light-tough financial vulnerability checks for customers reaching £500 in net deposits over a 30-day period. To ease the introduction of these light-touch checks, they initially came into force at this higher threshold, however on 28 February 2025 the threshold for these checks will be lowered to £150 in net deposits over the same period, to ensure a more gradual introduction for consumers.

We are expecting new legislation regarding the statutory levy to come into force before 6 April 2025. This will impose a new requirement on licensees in scope to pay the levy, which the Gambling Commission will then be responsible for enforcing. Operators are expected to make their first payments by 1 October in the 2025/2026 financial year.

A new requirement on direct marketing will come into force, whereby customers must be provided with options to opt-in to the product type they are interested in and the channels they prefer to receive direct marketing materials.

We are expecting secondary legislation to be laid before Parliament regarding online stake limits, alongside a regulatory impact assessment. This legislation will introduce new licence conditions on remote gambling operators which the Gambling Commission will then enforce. After the legislation is passed, the new limits will be rolled out in stages. Initially there will be a 6-week period for the £5 stake limit, followed by an additional 6-week period for the £2 stake limit for young adults. If operators find it challenging to enforce age-specific limits, they will be required to implement the £2 stake limit across the board. DCMS has recently highlighted this as a priority, so we expect the legislation to be introduced in 2025.

Six regulations will be laid before Parliament when time allows to implement reform to the land-based gambling sector as follows:

• Measures relating to casinos
• Amending the 80/20 rule for arcades and bingo halls
• Allowing direct use of debit cards on gaming machines
• Introducing an age-limit on certain types of Category D gaming machines
• Increasing the maximum cap that licensing authorities can charge by 15%