SBC News Voice of the Sports Betting Industry
DCMS has published its draft proposals on the regulatory changes needed to enact and implement new rules and entitlements for UK casinos.
The changes and recommendations are presented via two annexes (B and C), which are separate from the Gambling Review’s White Paper, “High Stakes: Gambling Reform for the Digital Age”, published back in 2023.
The annexes outline technical statutory instruments to amend existing requirements under the Gambling Act 2005. Should the proposals be accepted, the government will implement the measures via secondary legislation.
Audiences are reminded that “as these statutory instruments are in draft, they may be subject to change.”
Designing a New Framework
The government recognises that UK casinos require a modern regulatory framework to replace the current provisions of the Gambling Act 2005, particularly those inherited from the legacy Gaming Act 1968.
UK casino operators have submitted demands for a package of reforms to modernise the regulation of land-based venues, enhance operational flexibility, and establish more commercially viable conditions for modern customers. The key changes sought include:
- Increased gaming machine entitlements
- A new machine-to-table games ratio
- Permission to offer sports betting
- Permission to expand electronic table games
- Removal of membership requirements
- Simplified licensing rules
- Greater freedom for venue diversification for entertainment and hospitality
The changes proposed in annexes B and C focus on updating the regulatory provisions for “converted casino premises”, licences originally granted to casinos under the Gaming Act 1968, which were converted to operate under the Gambling Act 2005.
The policy recommendations relate to machine entitlements and licensing requirements. These changes are intended to align legacy casino operations with the broader reforms outlined in the Gambling Review.
Annex B: Entitlements for Converted Casinos
Annex B amends the 2006 transitional order to modernise the machine entitlements of converted casino premises licences in England and Wales. It introduces a new entitlement allowing these casinos to operate up to 80 Category B, C, or D machines, provided specific conditions are met.
As stated in the order: “to make gaming machines available for use on the premises provided that the requirements set out in sub-paragraph (6A) are met.”
These conditions include maintaining a gambling floor area of no less than 280 square metres and ensuring that “the number of gaming machines… is not more than five times the number of gaming tables used in the casino, and is not more than 80.”
The instrument introduces a tiered scale linking floor area to machine numbers — for example: “Minimum gambling area (m²): 500 – Maximum number of gaming machines: 80.”
In cases where multiple casinos are co-located or physically adjacent, a cumulative cap applies: “no more than 80 gaming machines may be made available for use in total across all of those premises (taken together).”
Once a casino adopts these updated entitlements, it relinquishes its previous rights under earlier provisions, as confirmed: “the licence ceases to authorise its holder to make gaming machines available for use.” To ensure oversight, the Secretary of State is required to publish a report on implementation “before the end of the period of five years” and every five years thereafter.
Annex C: Updating Licence Plans for Casino Venues
Annex C supports the practical implementation of the Annex B amendments by updating the regulations governing venues licence variations. It ensures that any converted casino applying to use the new machine entitlements must submit a modified scale plan.
The plan must identify both the “location and extent of any part of the premises which will be the table gaming area” and “any other part of the premises which will be used for providing facilities for gambling.”
These modifications ensure licensing authorities have a clear and consistent visual record of a casino’s gambling layout in line with the operational entitlements being sought. As the explanatory note states: “the plan for a converted casino premises licence must indicate an area as being for ‘table gaming’”, a requirement not previously specified in the 2007 Regulations.
The amended regulation aligns application procedures with the updated operating conditions and references existing legislative definitions. For example, “table gaming” is defined in Regulation 2 of the 2007 Regulations as “casino games played on ordinary, or partially or wholly automated gaming tables…”
An impact assessment was not required, as the proposed changes are expected to have “no, or no significant, impact on the private, voluntary or public sector.”
What Next
The UK government stands by the policy mandate to bring parity to the regulation of land-based gambling venues, with the ongoing changes of the Gambling Review. Despite demands by casino operators, neither the government nor DCMS has committed to a fixed timeline to apply ‘secondary legislative changes’ concerning land-based casino laws by the end of 2025.
