Gambling Commission’s Call for Proposals to Reduce Regulatory Burdens: A Comprehensive Guide

Gambling Commission’s Call for Proposals to Reduce Regulatory Burdens: A Comprehensive Guide

Overview: A Unique Opportunity for Industry Input

The UK Gambling Commission has launched a formal invitation to the gambling industry to propose ways to simplify, streamline, or eliminate unnecessary regulatory burdens. This initiative, which closes on Friday, 25 September 2026, is not a typical public consultation but a dedicated call for submissions from operators, suppliers, and other industry stakeholders. The Commission opened the call on 26 June 2026 and is now inviting proposals covering any aspect of gambling regulation—from Licence Conditions and Codes of Practice (LCCP) and technical standards, to reporting processes and internal administrative procedures.

This guide provides a deeper look at the background, scope, practical steps for submitting proposals, and what industry players should consider to make their submissions effective.

Context: Why the Commission Is Asking for Input

A Commitment to Proportionality

The call stems directly from a commitment in the Gambling Commission’s Business Plan for 2026–2027. Underpinning this initiative is the principle that the costs of compliance—both in terms of direct rule-following and demonstrating compliance—must remain proportionate to the risks posed to consumers. This principle is enshrined in the Commission’s Statement of Principles for Licensing and Regulation and the three licensing objectives of the Gambling Act 2005:

1. Keeping crime out of gambling.
2. Ensuring gambling is conducted fairly and openly.
3. Protecting children and vulnerable people from harm or exploitation.

The Commission acknowledges that over time, regulations, guidance, and processes can become outdated, duplicated, or overly burdensome. By proactively seeking industry feedback, it aims to identify areas where administrative costs can be reduced without weakening consumer safeguards.

What This Call Is Not

It is important to clarify that this is not a consultation on new policy. Rather, it is an open invitation to submit concrete proposals for reducing or streamlining existing regulatory burdens. The Commission will review all proposals where resources allow and may advise the government on legislative changes if needed. Proposals that touch on legislation outside the Commission’s direct remit will be forwarded to the relevant government bodies.

What Proposals Can Cover

The scope is intentionally broad. Industry stakeholders are encouraged to submit proposals on any of the following areas:

• Licence Conditions and Codes of Practice (LCCP): Specific rules or conditions that create disproportionate administrative work or are no longer fit for purpose.
• Technical Standards: Requirements for gaming machines, software, or online systems that could be simplified or updated.
• Statements of Principles: The Commission’s own guiding documents that set out how it interprets its regulatory objectives.
• Guidance and Communication: How the Commission structures and communicates its requirements, expectations, and updates (e.g., clarity of language, format of guidance notes).
• Reporting Processes: Any administrative reporting obligations that could be automated, consolidated, or eliminated. This includes manual data submissions, duplicate reporting to multiple bodies, or overly frequent returns.
• Outdated Rules: Regulations or guidance that have been superseded by technological changes, market developments, or other legislative reforms.

Example Proposals (for illustration)

• Duplication of reporting: An operator might show that the same financial data is reported separately to the Commission and to HMRC, and suggest a single shared submission.
• Manual processes: A technology supplier could propose that machine certification reports be submitted in a machine-readable format rather than as PDFs, reducing manual data entry.
• Outdated technical standards: A casino operator might argue that a particular LCCP requirement for physical signage in land-based venues is obsolete in a digital era where most customers use mobile apps.

What Is Off the Table

The Commission has clearly stated that certain topics will not be considered in this call:

• Recent policy changes still being evaluated: Any measures implemented through the Gambling Act Review or the 2023 White Paper High Stakes: Gambling Reform for the Digital Age are not open for revision at this stage. The Commission notes that these have not yet been fully implemented and evaluated. Proposals to replace or relax them will only be revisited if there is “strong evidence of adverse consequences being realised.”
• Proposals for new consumer protections: This call is about reducing burdens, not introducing additional requirements. Stakeholders should not use it to propose new or enhanced consumer safeguards—those belong in separate formal consultations.
• Policies recently consulted on: If the Commission has recently run a formal consultation on a policy and the outcome is not yet published, detailed proposals on that policy are unlikely to be considered. Similarly, changes that have just been implemented and are still being monitored will not be revisited without compelling evidence.

Practical Guidance for Industry Stakeholders

How to Craft a Strong Proposal

The Commission has provided an online form for submissions, with one form per proposal. Respondents can fill in as few or as many questions as they wish. To maximise impact, consider the following:

• Be specific and evidence-based: Clearly describe the rule, guidance, or process you want changed. Explain why it is burdensome and provide data on the administrative cost (e.g., hours of staff time, financial outlay).
• Quantify the benefit: Show how streamlining would free up resources for higher-value compliance work. As Michael Clohisy, sports attorney and adviser at Quintel Intelligence, told European Gaming in June, “The goal is to reduce administrative costs and redundancies and tighten the guardrails on a fast-moving digital, AI-enabled gambling ecosystem to free up resources for human compliance teams to focus on high-risk accounts, AML anomalies, integrity/match-fixing, and cybersecurity.”
• Consider alternatives: Suggest a specific alternative—for example, replacing a quarterly manual report with an automated data feed, or merging two existing codes into one.
• Note legislative boundaries: If your proposal requires a change to primary or secondary legislation, acknowledge that and indicate that the Commission may need to refer it to the government.

Evidence and Supporting Materials

Where possible, include:

• Copies of relevant current rules or guidance (with references).
• Internal data on time/cost spent on compliance with that rule.
• Examples of other jurisdictions that handle the same issue more efficiently.
• Industry surveys or third-party analyses that support your argument.

What Not to Submit

• Vague complaints or general frustrations without a clear proposal.
• Proposals that would weaken consumer protections without strong justification.
• Multiple unrelated ideas in a single form (each proposal should be separate).

What Happens Next

After Submission

The Commission has stated that it will not respond to every proposal individually. Instead, it will publish a public summary of its plans and priorities for any actions it decides to take forward. This ensures transparency without creating an administrative burden for the regulator itself.

Implementation Pathway

Any proposal that is accepted may follow one of several routes:

• Internal administrative change: If the proposal involves streamlining a Commission process (e.g., a reporting form), it can be implemented directly without consultation.
• Guidance update: Changes to Commission guidance can be made after internal review.
• Consultation required: Proposals that replace or significantly alter existing Licence Conditions or Codes of Practice may need a formal consultation before being enacted. This is to ensure due process and stakeholder input.
• Legislative change: If a proposal requires amending the Gambling Act or other primary legislation, the Commission will advise the government, which will then decide on next steps.

Timing and Resources

The Commission emphasises that any actions will depend on available resources and business planning. Consumer protection will remain the overriding priority. Even if a proposal is accepted, implementation may not be immediate. Industry players should be prepared for a phased approach.

Key Dates and Deadlines

Conclusion

This call represents a rare, structured opportunity for the gambling industry to help shape a more efficient regulatory environment. By focusing on well-evidenced, practical proposals that reduce duplication and administrative waste—while maintaining robust consumer protections—stakeholders can influence how the Commission allocates its own resources and those of the operators it regulates.

Successful proposals will not only lower compliance costs but also allow compliance teams to concentrate on the highest-risk areas, such as anti-money laundering, problem gambling detection, and sports integrity. As the September 2026 deadline approaches, now is the time to prepare submissions that are clear, data-driven, and aligned with the Commission’s licensing objectives.

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