On 18^th December the Gambling Commission (“Commission”) confirmed that it will introduce some changes to the Licence Conditions and Codes of Practice (“LCCP”) in its responses to consultations on:

• Financial key events; and
• New consumer legislation.

Financial key event reporting

In its consultation response on financial key event reporting, the Commission confirmed specific amendments to LC 15.2.1 and related policy to improve transparency around the ownership and financing of its licensees while aligning reporting with international norms. From 19 March 2026, the following changes will come into effect:

• The Commission will increase the reporting threshold for “operator status” and “relevant persons and positions” under LC 15.2.1(1) and (2) from 3% to 5%. This aligns with common international thresholds and addresses practical limitations for listed groups that often cannot access sub‑5% shareholder data. Importantly, licensees must still report within five working days of becoming aware of a key event.
• The Commission will expand the concept of “relevant persons” under LC 15.2.1(2), beyond shareholders of companies that have a share capital to capture other legal entities with a 5% or greater interest via voting rights or entitlement to profits or dividends, reflecting differing constitutional forms. The final position excludes indirect interests and carves out society lottery licensees for voting/profit entitlements.
• The Commission has decided against the proposed broad reporting of “financial agreements or arrangements” with non‑FCA‑authorised parties. Instead, LC15.2.1(3) will clarify loans must be reported even if not documented in writing, and intra‑group borrowing is only reportable where funds ultimately flow to the licensee.
• A proposed new obligation to report acquisitions of newly issued shares at fixed cash thresholds (£50,000 for individuals and £1 million for entities) and to obtain source‑of‑funds evidence will not be implemented at this time. The Commission will instead gather further information from a sample of licensees over the next eighteen months before deciding whether to revisit this proposal.

The Licensing, Compliance and Enforcement Policy Statement (paragraph 3.25) will also be updated to a 5% listing threshold for shareholders, with additional checks continuing for holders over 10% and a focus on identifying ultimate beneficiaries, including for trusts and nominees. This policy change will also come into force on 19 March 2026.

In response to stakeholder feedback, the Commission will publish improved guidance and worked examples to assist with the application of the revised requirements, and it confirmed that publicly traded companies may rely on public filings and need only report within five days of becoming aware of a reportable event. Updates to the eServices platform are expected to coincide with the LCCP changes.

Overall, the reforms narrow reporting in some areas to reduce the regulatory compliance burden and postponing more onerous proposals pending further evidence. Operators will, however, face a broader scope of “relevant persons” across different legal forms.  Licensees should review ownership monitoring processes, loan reporting procedures, and internal change‑notification workflows ahead of the 19 March 2026 effective date.

Consumer law changes

In the Commission’s response to the consultation on amendments to the LCCP due to the Digital Markets, Competition and Consumers Act 2024 (the “DMCCA”), which closed on 29 September 2025, the Commission confirmed that it will amend the LCCP to align with the DMCCA, replace references to legacy consumer law, and update Alternative Dispute Resolution (“ADR”) provisions. These amendments are, broadly, consequential rather than substantive (though there are nuances that operators should be mindful of and prepare for) and ensure that the LCCP reflects the new legislative framework without extending licensees’ obligations beyond the DMCCA itself.

The changes are as follows:

• From 6 April 2026, references to the Consumer Protection from Unfair Trading Regulations 2008 (“CPUT”) – which were revoked in April 2025 – will be updated to the DMCCA. Specifically, the changes are to:
• • Remove the reference to CPUT from LC 7.1.1(4) (Fair and transparent terms and practices) and replace it with the DMCCA. The reference in question is “Licensees must ensure that they do not commit any unfair commercial practices within the meaning of the CPUT, at any stage of their interactions with consumers”.
  • Remove the reference to CPUT from SRCP 5.1.9(1) (Other marketing requirements) and replace it with the DMCCA. The reference in question is “Licensees must ensure that their marketing communications, advertisement, and invitations to purchase (within the meaning of CPUT) do not amount to or involve misleading actions or misleading omissions within the meaning of those Regulations.

• Subject to the Department for Business and Trade (“DBT”) bringing the new ADR scheme into effect under the DMCC Act, further changes to SRCP 6.1.1 on complaints and disputes are planned for spring 2026. ADR entities will now be accredited by the Secretary of State under the DMCC Act (rather than the Alternative Dispute Resolution for Consumer Disputes (Competent Authorities and Information) Regulations 2015) and the list of Commission-approved ADR providers will be withdrawn. DBT will implement transitional arrangements, including concurrent operation of the old and new frameworks and a simplified “fast track” accreditation for existing providers, to avoid unintended breaches and ensure continuity and the Commission is expected to signpost operators to DBT’s accredited ADR list once this becomes available. The government’s ADR framework is designed to accommodate sector-specific ombudsman models where appropriate, including the possible introduction of a gambling ombudsman.

The Commission has been at pains to stress that, whilst the DMCCA provides updated concepts and definitions for key consumer law terms, the concepts themselves are broadly the same. Its assessment, during consultation, was that while there are “likely to be aspects in which duties on licensees are enhanced by the DMCCA, the overall effect is to streamline the requirements rather than hold licensees to a new set of standards”. It will be reassuring for operators to hear this, though the Commission’s view does somewhat gloss over the more meaningful DMCCA concept/definition updates – in particular, a much greater emphasis on customer vulnerability, as well as a broadening of key concepts such as ‘unfair commercial practices’, ‘misleading omissions’ and ‘misleading actions’ (all relevant under operators LCCP obligations). That said, in response to concerns raised by stakeholders as part of the consultation, the Commission remarked that “… the aim of this consultation and resulting changes to the LCCP is only to make the necessary consequential changes due to the DMCC Act 2024. Any policy changes regarding licensees recognising and responding to vulnerability fall outside its scope”.

What does this mean for operators?

While these changes are stated to be alignment changes rather than reflective of new policy, they nevertheless carry implications for day‑to‑day operations and enforcement risk (noting that the CMA has been granted significantly enhanced enforcement powers under the DMCCA). Some factors operators should think about as a result of these changes are:

• Updates to reflect DMCCA concepts – operators should familiarise themselves with the updated DMCCA concepts relevant to their obligations under LC 7.1.1(4) and SRCP 5.1.9(1), and ensure that their customer terms and conditions, onboarding and checkout journeys, marketing templates, and other commercial practices reflect and comply with the updated DMCCA terminology and concepts. Operators should also refresh staff training and quality assurance scripts accordingly to remain up to date with the legislation.
• Complaints and ADR readiness – operators may continue to use their current ADR provider until the new DBT scheme is implemented. In the event of any changes to their ADR provider, operators should update their procedures and player communications accordingly.
• Affiliate oversight – operators may need to update affiliate terms and monitoring to require compliance with DMCC standards and to capture audit records as missteps by affiliates can be treated as your advertising.

In short, operators should carefully prepare for the legislative crosswalk to the DMCCA in their consumer and marketing practices from 6 April 2026, and monitor for DBT’s commencement of the new ADR accreditation scheme, with transitional safeguards expected and Commission signposting to follow.