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Eyes Down: The Regulatory Identity Crisis in UK Bingo Licensing

By jili tutorial · September 29, 2026

Eyes Down: The Regulatory Identity Crisis in UK Bingo Licensing

A Sector at a Crossroads

When the UK’s latest gambling statistics recorded yet another sharp increase in gaming machine revenue from licensed bingo premises, critics were quick to identify a troubling trend. One gambling harm campaigner went so far as to suggest that bingo had become a “Trojan horse” for gaming machine operations — a label under which the industry could expand machine gambling under the cover of a socially accepted pastime.

The headline figures behind that accusation are certainly striking. According to the latest data from the Gambling Commission, released in its most recent reporting period, gaming machines generated £461.7 million in gross gambling yield (GGY) for bingo operators in the year to March 2026. Bingo games themselves, by contrast, generated £242.1 million. Together, the sector produced a combined GGY of £703.8 million — and machines accounted for almost two-thirds of that total.

GGY, for the uninitiated, is the amount retained by operators after paying out prizes to players but before deducting operating costs such as staff, rent and utilities. It is the gambling industry’s equivalent of net revenue, and it is the metric most commonly used by regulators and policymakers to measure the size and shape of the market.

On one level, none of this should surprise anyone familiar with the modern bingo industry. Machines have long played a vital financial role in bingo clubs, helping large, labour-intensive venues meet their property costs, staffing bills and energy overheads — particularly as attendances and the number of conventional clubs have steadily declined. A traditional bingo hall is an expensive operation to run: it needs substantial floor space, a full schedule of sessions, and a small army of staff to manage games, sell tickets and run the bar. Machines, by contrast, are relatively cheap to operate and can generate revenue around the clock.

But the aggregate data, as we shall see, conceals a more fundamental change in the composition of the sector. The “bingo premises” category now appears to encompass at least two very different kinds of business — and the gap between them is widening.

Reading the Tea Leaves: What the Latest Data Shows

The long-term trajectory is clear from the Commission’s own figures. In 2019-20, gaming machines in bingo premises generated approximately £293 million in GGY. By 2025-26, that figure had climbed to £462 million — an increase of 57% in just six years.

Category B machines — the higher-stake products available in bingo premises — drove much of that growth. Revenue from this category rose from roughly £197 million to £361 million over the same period. As a result, Category B machines accounted for approximately 78% of all bingo-premises machine GGY in the latest financial year, up from around 67% in 2019-20.

For context, Category B is the broad band of gaming machine categories set out in the Gambling Act 2005 and its regulations. Category B3 machines include some of the most popular products on the high street, while Category B4 machines are commonly found in bingo halls and adult gaming centres. These are higher-stakes, higher-intensity products than the Category C and D machines found in pubs, arcades and family venues — and their growing dominance within bingo premises is one of the key factors driving the regulatory debate.

The divergence between machine revenue and bingo revenue has become increasingly pronounced over the years. In 2019-20, machines already generated more GGY than bingo games. By 2025-26, the gap had widened to a ratio of almost two-to-one in favour of machines. Yet the headline numbers, dramatic as they are, tell only part of the story.

One Licence, Two Business Models

The government itself acknowledged the problem in its October 2025 consultation on bingo licensing. The consultation paper noted that there was a “growing number” of licensed bingo premises that predominantly offered gaming machines and were difficult to distinguish from adult gaming centres (AGCs). In some of these venues, machines occupied most of the floor space. In others, they were presented as the most prominent feature a customer would see when entering the premises.

The Gambling Commission supplied data to the consultation that represented the regulator’s best attempt to separate the economics of different bingo formats. The results were revealing — and, for some in the industry, deeply uncomfortable.

Among operators running mainly or exclusively what the Bingo Association categorises as “high-street bingo premises,” less than 1% of GGY came from bingo games. Gaming machines generated the other 99%. That compares with bingo contributing 51% of GGY for operators focused on traditional bingo clubs, and 55% for operators concentrated in holiday parks.

The comparison suggests that the phrase “bingo premises” now encompasses at least two very different businesses. One is the recognisable destination club — the traditional bingo hall with its scheduled games, its hundreds of customers, its licensed bar and its lively community atmosphere. In these venues, machines are an ancillary but important revenue stream, helping to cross-subsidise the labour-intensive bingo operation. The other is a smaller high-street venue in which machines are the commercial proposition and bingo’s role can be marginal at best.

The Bingo Association, the trade body representing the industry, has long argued that its high-street members are a distinct and important part of the sector. But the data suggests that the “bingo” label is now doing a great deal of work in these venues.

Case Study: Merkur Slots and the New Face of “Bingo”

To understand how far the divergence has gone, one need only look at Merkur Slots. A search of the Gambling Commission’s public licensee register reveals that, of the company’s 340 venues, 227 are classed as bingo venues. Only 106 are registered as AGCs.

A quick look at Google Street View shows what those 227 “bingo” venues actually look like in practice: rows of gaming machines stretching back from the front window, bright LED lighting, and a functional high-street frontage that is indistinguishable, in almost every respect, from a conventional AGC. Some have wording on the windows saying “bingo played here,” but the venue’s appearance and day-to-day operation are those of a machine arcade.

This is not intended to single out Merkur Slots as a bad actor. The company is simply the most prominent example of a broader trend — and one that has emerged from the structure of the licensing regime itself. The Gambling Act 2005 created distinct categories for bingo premises and AGCs, each with its own rules, entitlements and restrictions. Where the economics favour one classification over another, operators will naturally choose the label that best suits their commercial model, even if that label no longer accurately describes what happens inside the venue.

The Rise of the Hybrid Venue

Matters are further complicated by the emergence of a developing hybrid category between the two models. Smaller-format venues are increasingly combining a credible bingo offer — perhaps a handful of sessions per day on a dedicated terminal or at a small counter — with a substantial machine estate. These venues can introduce bingo to different audiences, including younger players and urban professionals, without replicating the traditional club model, which many in the industry see as legitimate and welcome innovation.

But it is precisely this hybrid model that exposes the difficulty at the heart of the regulatory framework. Where exactly should the line be drawn between a genuine bingo venue with machines, and a machine arcade operating under a bingo licence? The question sounds simple; answering it has proven anything but.

The “Substantive” Problem: When Does Bingo Count as Bingo?

The legal framework governing this area rests on a single, heavily loaded word: “substantive.”

Under social responsibility code provision 9.1.2 of the Gambling Commission’s Licence Conditions and Codes of Practice (LCCP), machines may be made available in licensed bingo premises only where “substantive facilities” for non-remote bingo are also available. The internal and external presentation of the premises must also allow a customer to reasonably recognise it as a venue licensed to provide bingo.

What counts as “substantive,” however, is nowhere defined. The Gambling Act 2005 does not specify how much floor space must be used for bingo, how many customers must be able to play it, or what proportion of revenue should come from the game. There is no statutory minimum number of bingo seats.

The Commission has deliberately resisted a universal numerical definition when it has previously considered the issue. In part, this reflects a desire to avoid an inflexible, one-size-fits-all approach that might stifle legitimate formats and innovation. That flexibility has certainly accommodated a wide range of business models, from traditional destination clubs and holiday parks to electronic bingo and newer digital formats.

But that same flexibility has created room for premises in which the bingo provision is technically present yet economically insignificant. A single terminal offering bingo in a corner of a room full of gaming machines is, in a narrow legal sense, a bingo facility. Whether it is a “substantive” one is a question the regulations simply do not answer.

The Electronic Bingo Complication

Electronic bingo terminals add another layer of complexity. The same tablet or terminal can offer both bingo and gaming-machine content, although only one activity can be played at a time. A group of tablets might therefore be used to demonstrate that bingo is available in a venue while also, at other times, contributing to machine play.

The result is a test based on the availability and presentation of bingo rather than on whether bingo is the venue’s principal activity. That may be legally convenient, but it is not necessarily the right test for determining a venue’s risk profile, its impact on the surrounding community, or whether the operator should benefit from the advantages that a bingo licence confers.

Why the Licence Type Matters

One might reasonably ask why any of this matters. If the machines are legal, the gambling is licensed, and the venues are regulated by the Gambling Commission, what difference does the label make?

The answer is that the regulatory identity of a premises affects a great deal more than its name above the door.

First, it is not simply about the number of machines. The incentive for operating under a bingo licence is not necessarily a more generous allowance of Category B machines. Both bingo premises and AGCs can ordinarily make Category B3 and B4 machines available up to a limit of 20% of their total machine estate, with the remaining machines required to be lower-category products. Older premises may have limited grandfathered entitlements, but the underlying machine ratio is broadly similar between the two licence types.

The important differences lie elsewhere. Licensed bingo premises can offer forms of bingo that are unavailable in AGCs, where bingo is restricted to “qualifying prize gaming” — essentially low-stakes, low-prize games played with small stakes and offering modest prizes. Bingo premises may also seek an alcohol licence, whereas customers cannot consume alcohol while gambling in an AGC.

The classification of a premises also affects its customer proposition, its presentation and the multi-operator self-exclusion scheme that applies. It can influence how local licensing authorities assess the venue and the surrounding area’s gambling risk profile. A machine-led premises operating under a bingo licence can therefore occupy a very different regulatory position from an AGC offering an economically similar product.

Perhaps most importantly, in-person bingo and machine gambling do not carry identical risk profiles. The government’s consultation noted that survey evidence associates machine play with higher rates of problem gambling than land-based bingo. A venue primarily offering machines has a different overall risk profile from a club with prominent bingo facilities — regardless of what the label on its licence might say.

The Limits of a Revenue Test

Yet revenue growth alone does not establish increased harm. Nor does a high machine-revenue percentage automatically demonstrate that a traditional club is providing insufficient bingo.

A relatively small number of higher-intensity products can generate substantially more GGY than hundreds of bingo seats. A club might run a full bingo programme, with hundreds of customers playing each session, while still deriving the majority of its revenue from machines — simply because a handful of Category B machines are far more productive per square foot than a bingo seat ever could be.

A crude revenue-based test would therefore risk misclassifying legitimate clubs whose bingo offer remains extensive but whose machines are more commercially productive. This is a key concern for the industry, and one that any new regulatory framework will need to address.

A Sector Transformed

The scale of the change can be measured in two parallel trends.

According to Bingo Association data cited by the government, the number of registered traditional clubs fell from 335 in December 2018 to 248 by August 2024 — a decline of more than a quarter in under six years. Over the same period, however, the total number of licensed bingo premises actually rose. As of March 2026, there were 714 bingo premises, up from 688 the previous year.

That apparent paradox is explained by the growth of smaller high-street locations, which has largely offset the disappearance of traditional venues. The composition of the sector has changed fundamentally, even as the headline number has remained relatively stable.

The revenue mix has shifted in parallel. Machines provided 44% of licensed bingo-sector GGY in the year to March 2014. By March 2024, that share had reached 63%. The latest Commission data puts it at 65.6% for 2025-26.

The debate is therefore not simply about machines taking a larger share within existing bingo clubs. It is also about the expansion of a venue format in which machines were the dominant commercial activity from the outset. The bingo licence has become, for a significant segment of the sector, a route to operating machine-led premises under a regulatory framework designed for something else entirely.

The Government’s Proposed Reforms

The government’s October 2025 consultation set out a series of proposals designed to address the issue head-on.

The central proposal was to establish a clearly defined bingo area in every licensed bingo premises. Options included requiring 30%, 40% or 50% of the premises to form a continuous bingo area. Cabinet and in-fill gaming machines — that is, standalone machines in cabinets and machines designed to be slotted between other machines — would be prohibited from that space. Tablets within the bingo area would have to offer bingo even if they also carried machine content.

The consultation also proposed a minimum number of distinct bingo positions. Options included requirements for 30 or 40 seats, with an alternative formula linking the number of positions to the size of the bingo area.

For operators wishing to retain a predominantly machine-led offering, the consultation presented another route: conversion to an AGC licence. Such a move would mean losing the ability to offer most forms of bingo and potentially the ability to serve alcohol, as well as incurring licensing costs.

The policy challenge, as the consultation itself acknowledged, is to avoid shutting down legitimate businesses while ensuring that the bingo licence is used for what it was intended: providing bingo. Whether the proposed measures achieve that balance — and whether the final rules will be sufficiently flexible to accommodate the sector’s diversity — remains to be seen.

Conclusion: Drawing a Workable Line

What is clear is that the status quo is no longer sustainable. The “bingo premises” category has grown so broad, and the economic role of machines so dominant, that the label has begun to lose its meaning. A licence category designed for a single, recognisable format now covers everything from the traditional seaside club to a machine arcade with a bingo terminal by the door.

The government’s proposals represent a genuine attempt to address the problem. A defined bingo area, a minimum number of positions, and a clear prohibition on machines in the bingo space would all help to restore meaning to the bingo licence. But the details matter, and the industry will be watching closely to see how the final regulations are drafted.

The question now is not whether the line should be redrawn, but where — and how. Draw it too tightly and you risk stifling legitimate innovation and accelerating the decline of a cherished institution. Draw it too loosely and the problems the consultation identifies will simply persist under a different guise.

For a sector that has spent years fighting for its identity, the next few months will be crucial. The outcome will determine not just the shape of the bingo industry, but what the word “bingo” actually means in the United Kingdom.