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You've accepted all cookies. You can change your cookie settings at any time. The Gambling Commission's guidance for licensing authorities. Published 1 April Last updated 14 September - Changes. Document actions Print or save.

The unsuccessful applicants must be informed of the result of the competition. The Secretary of State has issued a code of practice opens in new tab about the procedure to be followed by licensing authorities in making determinations at both stage one and stage two, and also about the matters authorities are to take into account in making such determinations.

The Act requires licensing authorities to comply with any code of practice issued by the Secretary of State. Where an authority invites applications, those applications may be in the form of an application for a provisional statement as well as in the form of an application for the grant of a full casino premises licence.

Where an application is made in the form of a provisional statement it is to be treated in the same way as an application for a casino premises licence and included in any two-stage determination process that the authority is required to carry out.

If an application for a provisional statement is successful in that process, then it is not necessary for a further two-stage licensing process to be held when a casino premises licence application is eventually made by the operator to whom the statement has been issued.

As a first step in licensing a casino, the licensing authority will have to invite applications for any casino premises licences that it may issue. It is possible that the number of applications that the relevant licensing authorities will receive will exceed the number of licences available.

The Act lays down a framework for a two-stage process for considering applications in these circumstances. As with all deliberations in premises licences, the authority should not confuse planning and building regulation considerations with the matter before it.

Authorities should think carefully before entering into any agreements or arrangements with potential casino operators which might be perceived to affect their ability to exercise their stage two functions objectively and without having prejudged any of the issues. If any such agreements or arrangements are entered into, it will be important that authorities are able to demonstrate for example, through having obtained independent and impartial advice on the competing applications that any decision they reach is objectively based and is not affected by the arrangements.

If more applications are received than the number of available licences, the authority must determine whether each application would be granted a licence if there were no limit on the number of licences that the authority could grant.

Each application must be considered separately, and no reference made to the other applications received. The consideration of representations should be the same as that for normal applications for premises licences, detailed in Part 7 of this guidance.

This process will result in one or more provisional decisions to grant a premises licence, which will be disclosed to the applicant and any party that made representations. The provisional decision of the licensing authority at stage one may be appealed. Until any appeal has been determined, the licensing authority may not proceed to stage two.

The second stage of the process only applies where the number of applications which the licensing authority would provisionally grant under the stage one process exceeds the number of available casino premises licences.

Under the second stage of the process the authority has to decide between the competing applications and grant any available licences to those applications which in their opinion will result in the greatest benefit to its area.

BOB MILLER is Nevada's longest serving governor, holding office from to His son, Ross, who is named after his grandfather, is presently in his second term as Nevada's secretary of state.

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No machine to table ratio currently exists for Act casinos. Small Act casinos are bound by a lower machine to table ratio , meaning that they need to have 40 gaming tables to be able to offer 80 machines, whereas a Large Act casino would only need 16 tables for the same number.

There are currently only three Small Act casinos in operation from the eight licences available. The customer demand for 40 gaming tables does not exist, which can mean that a number of tables are sited but never used. It has also meant that none of these casinos are able in practice to satisfy the current conditions which would allow them to offer the maximum number of gaming machines due to the amount of space they take up.

It was also noted from the call for evidence that where other jurisdictions apply a machine to table ratio, all currently permit a greater proportion of gaming machines in comparison to Great Britain. Relaxing the machine to table ratio for Small Act casinos and applying it to Act casinos that take up their new machine entitlements is also a tested concept as it is already in place in Large Act casinos.

We propose a single machine to table ratio of to be applied to all casinos, with the exception of Act casinos that either have a gambling area smaller than sqm or would prefer to retain their existing entitlements.

This would mean the introduction of a machine-to-table ratio for Act casinos that seek to increase their Category B gaming machine entitlement above 20, and a change to the machine-to-table ratio currently in place for Small Act casinos.

This would ensure that regardless of the size of venue, most casinos will be able to site the same proportion of machines to tables. A single machine-to-table ratio of will apply to all casinos with the exception of Act casinos with a gambling area of less than sqm or those that elect to remain on their existing licensing regime.

Only tables for multi-player live gaming, operated by a casino dealer, will qualify for the purposes of this ratio. Should the government introduce a machine to table ratio for all casinos except those Act casinos that remain on the existing licensing regime?

Please share any evidence or information that is relevant to the proposed amendment to the definition of gaming tables since the government stated its intention to make this change in Depending on the type of licence a casino operator holds, their premises must comply with specific size requirements in relation to gambling area, table gaming area and non-gambling area:.

As gaming machine allowances and machine to table ratios for Act casinos and Small Act casinos converge, more consistent size requirements should apply across the two types of licence to ensure a degree of fairness and consistency.

However, as outlined in our proposals below, there are some difficulties in mirroring the exact restrictions that apply to Small Act casinos for Act casinos. The tables below outline current and proposed space requirements for Act casinos, and Act casinos which seek to increase their gaming machine entitlement above 20 including at least one Category B machine.

In order for a Act casino to be entitled to 80 gaming machines, we propose that it must have a gambling area of at least sqm, the same minimum requirement for Small Act casinos. For Act casinos that have a smaller gambling area, the requirements set out in the sliding scale will apply.

Only casinos that have a gambling area of sqm or more will be eligible to access the enhanced gaming machine entitlement. From data provided by industry, we understand that there are eight Act casinos that have a gambling area of sqm or over, and a similar number that are close to sqm and which could be expanded if they decide to site more gaming machines and tables.

We are unable to easily increase the maximum size of Small Act casinos as the legislation requires that Small and Large casinos are classified distinctly, so an overlap between the two categories would be problematic.

Therefore, we are consulting on three options which could be implemented to address this issue:. Option 1 would provide fairness and consistency across all casinos that are able to site 80 machines. However, it would be disruptive and potentially impose additional costs onto those casinos with a gambling area of 1,sqm or more that are already established.

It could also mean that the same gambling facilities are compressed into a smaller gambling area, with potentially a worse customer experience and no player protection benefits. Option 2 would not require currently operating casinos to reduce their total gambling space.

However, those casinos that would be allowed to keep their current gambling space would have more flexibility in terms of the layout of their venue compared to Small Act casinos, which may be deemed unfair by casinos without this advantage.

Option 3 would not impact any Act casinos and would give these casinos greater flexibility in the layout of their venues. However, it could be seen as unfair by those operators that currently hold Small Act licences who would remain capped at sqm, although such operators will also have greater flexibility in arranging their gambling space as the requirement for a machine to table ratio is removed.

We are also open to any other proposals from respondents on how to approach this issue. We are mindful of ensuring fairness between Act and Act casinos but also to those casinos that are currently operating.

For Act casinos that meet the same size thresholds as Small Act casinos, we have proposed introducing a sqm table gaming area requirement. This restriction, alongside requirements for non-gambling area, will only apply to those Act casinos that decide to exercise the enhanced gaming machine entitlement.

We will also amend the current inconsistency in the regulations which requires Small Act casinos to have a table gaming area of at least sqm identical to their minimum overall gambling area by reducing this requirement to sqm.

We think that this will create greater equity between Act and Small Act casinos and should not have an effect on gambling-related harm as customers will still be offered a mixture of gambling and other non-gambling leisure activities.

In the case of Act casinos that do not meet the minimum size requirements of Small Act casinos, but have a gambling area of at least sqm and decide to take the enhanced gaming machine entitlement, we propose that the table gaming area is commensurate with venue size.

We propose that the table gaming area for casinos that have less than sqm of gambling space must be equal to or greater than half the size of the gambling area. For casinos that are sqm or larger, the table gaming area must be equal to or greater than sqm.

For example, if a casino has sqm of gambling space, it would be required to have at least sqm of table gaming space. However, if a casino has sqm of gambling space, it would only be required to have at least sqm of table gaming space. Further detail is shown in Figure 3.

We are proposing that in order for Act casinos to be entitled to more than 20 gaming machines including one or more Category B gaming machines , then it must also have a non-gambling area that is equal to or greater than half the size of the total gambling area if it has a gambling area of less than sqm.

If its gambling area is sqm or more, its non-gambling area must be equal to or greater than sqm. For example, if a casino had sqm of gambling space, its non-gambling area would need to be at least sqm.

If a casino had sqm of gambling space, it would need to have at least sqm of non-gambling area. This will ensure that casinos continue to offer a variety of gaming and non-gaming activities for customers while at the same time allowing a greater number of machines to be sited on the premises.

The Gambling Act Mandatory and Default Conditions England and Wales Regulations set out that in calculating the table gaming area for Act casinos, any separate area that comprises less than For Act casinos that access the new machine entitlements, we propose that the mandatory licence conditions remain aligned, so that only areas that comprise This will ensure that only distinct and sizeable table gaming areas can count towards the total, giving customers a genuine mix of products that are easily accessible in a casino.

We are also open to any other proposals for how table gaming areas should be calculated for Act casinos which trigger their enhanced gaming machine entitlements. The overarching principle is that specific areas in the casino should be separated for the purposes of table gaming.

We appreciate that for commercial reasons and for a better customer experience, tables are already grouped together in casinos, often in one large area. However, we want to avoid any regulation that would allow table gaming areas to be placed in obscure or less accessible areas for customers so that a genuinely mixed offering of products remains in the casino.

In addition, those Regulations set out the following rules about what areas can be used to calculate the non-gambling area in a Act and Act casino:.

We intend on keeping the same requirements for calculating non-gambling areas for both Act and Act casinos. Industry has raised some concerns about how areas like bars would be categorised if sports betting terminals were placed in them.

However, Act casinos are currently allowed to offer betting and we are not aware of any issues that this has created. Therefore, we would welcome any responses which highlight concerns about this approach and how non-gambling areas could be calculated using a different method. The number of additional machines that a Act casino will be entitled to will be determined by the size of all three different areas that have been outlined above - the total gambling area, the table gaming area and the total non-gambling area.

Failing to meet the size requirement in any of these three areas will result in a lower machine entitlement. For example, a casino could have a gambling area of sqm, a table gaming area of sqm and a non-gambling area of sqm.

While the gambling and table gaming area requirements would be enough for an entitlement of 80 machines, its non-gambling area is too small to qualify for this entitlement. Under the sliding scale proposal Fig 3 , this casino would only be entitled to 70 machines due to the size of its non-gambling area in this instance.

To be allowed 80 machines, its non-gambling area would have to be at least sqm. It is for the Scottish Ministers to consider whether they want to amend the Mandatory and Default Conditions that apply to casinos located in Scotland.

We would not allow additional gaming machines in Scottish Act casinos until Scottish Ministers have had the opportunity to consider what if any restrictions or protections they would like to put in place by way of amendments to the Mandatory and Default Conditions Regulations.

Maximum gambling area for Act casinos will be decided following responses to the consultation. Amending the regulations so that Small Act casinos only need a minimum table gaming area of sqm, reduced from sqm.

This amendment will mean that Act casinos that meet the same size requirements of Small Act casinos subject to our final position on maximum size of gambling space will be entitled to 80 gaming machines. Some of the same size requirements for Small Act casinos will apply for Act casinos, should they increase their entitlement to gaming machines to more than 20 including one or more Category B machines.

Only areas that comprise Do you agree with the proposed i minimum gambling area; ii table gaming area; and iii non-gambling area requirements for Act casinos under the new regime? Should the minimum table gaming area for Small Act casinos be reduced to sqm? Should access to a greater number of gaming machines require compliance with each of the three size requirements outlined above?

Which approach do you think should be taken in relation to the maximum gambling area for Act casinos? Should separate table gaming areas of Please explain your answer, including an alternative solution for how to calculate non-gambling areas where applicable.

Taken together, the three measures will determine the maximum number of gaming machines that casinos will be entitled to. These represent transition costs and are expected to be incurred in the first year of implementation only.

We will use the responses to this consultation as well as wider engagement with the sector to gather data to estimate the likely uptake of additional machines by casinos. This will be used to model the transition costs and will be included in the final impact assessment. There is also a potential societal cost associated with these measures.

According to data from Health Survey England from to , This covers all venues, not just casinos, but it indicates that increasing the number of gaming machines available to play may come with an associated increase in the risk of gambling harm.

Notably, these rates are below the at-risk and problem gambling rates for casino table games Data from the National Gambling Treatment Service shows that a relatively small proportion of patients report participating in gaming machines in casinos.

Taking this evidence together, we conclude that compared to other casino products, gaming machines are likely associated with relatively lower rates of problem gambling.

For those customers who switch from other casino products to gaming machines as a result of this measure, the risk of increased gambling harm as a result of these measures may be limited. We can also analyse average loss and session length data to consider the possible risks of gambling harm for those customers who increase their gambling participation as a result of these measures.

It shows that, from April to September , around , sessions c. Forrest and McHale notes that such levels of expenditure are not dissimilar to those associated with other leisure activities. Additionally, an objective of this measure is to reduce average session duration, which is linked to gambling harm.

Finally player protections are in place in casinos to mitigate increased risks of gambling harms. Gambling operators must ensure that their supervision and monitoring of gaming machines enables them to meet the requirements of the Act and conditions of their licence.

Since , many casinos have adopted a range of measures that enhance machine protections including:. The primary benefit of this measure is increased GGY for casinos that take up additional gaming machines. The Betting and Gaming Council BGC have provided detailed information on each casino, including floor space and the number of existing machines.

Around 20 Act casinos meet the minimum proposed size requirements for gambling area, table gaming area and non-gambling area, and would therefore be able to benefit from the same number of machines as Act Small casinos. We estimate that most of the remaining casinos would also be able to benefit from increased machine allowances, proportionate to their size and non-gambling area.

We do not currently have sufficient data to estimate the likely uptake of additional machines by casinos. Combining this with the number of machines, this yields an average annual GGY of £57, per machine. This will be used to model the estimated total increase in GGY for casinos in the final impact assessment.

This will take into consideration that there is likely to be diminishing returns, such that the more machines you have, the less GGY would be generated per machine.

There are also indirect benefits associated with this policy. A further advantage would be allowing operators to create an experience which competes with international gaming jurisdictions, and elevates the reputation of Britain as a gaming destination for international gaming tourists.

The white paper set out the intention for all casinos to be able to include a sportsbook as part of their product offering. Moreover, this measure would bring greater consistency to the different licensing regimes and bring greater parity between the online and land-based casinos.

The white paper proposed that all casinos should have the ability to offer betting, should they wish to do so. In order to offer this, operators will be required to hold relevant operating licences from the Gambling Commission.

The authorisations required may include a remote betting operating licence required if customers are to be able to bet via Self-Service Betting Terminals , as well as a non-remote betting operating licence.

This entitlement will not be restricted by any space requirements or whether the casino has decided to increase its number of gaming machines under the new regime.

Casinos that are currently permitted to offer betting may site a maximum of 40 Self-Service Betting Terminals SSBTs.

These terminals are not gaming machines if they are designed or adapted for use to bet on future real events. Where a machine is made available to take bets on virtual races, it is classified as a gaming machine and would therefore count towards the maximum permitted number of such machines.

In practice, venues which include sportsbooks as part of their product offering do not utilise a maximum of 40 — the largest casino by gambling area currently sites 12 terminals.

We propose that the number of machines is limited, based on the overall gambling area of the casino. As outlined in the table below, we propose that casinos with a gambling area of sqm or less are allowed 16 machines, increasing by two machines for every additional 20sqm of gambling space, up to 40 machines.

We intend to place some restrictions on the number of SSBTs to avoid a scenario in which the product offering becomes unbalanced and a large number of these machines are sited in a relatively small gambling area.

For example, we do not think that it would be appropriate for a casino that has a gambling area of sqm and a table gaming and non-gambling area of sqm to be able to site 40 SSBTs alongside 25 gaming machines and at least five gaming tables.

While permitting betting in Act casinos is not a reserved matter, as outlined above, we intend to impose a limit on the number of SSBTs that can be made available in a casino. It is likely that this will require an amendment to the Mandatory and Default Conditions.

We would not permit betting in Scottish Act casinos until Scottish Ministers have had the opportunity to consider what if any restrictions or protections they would like to put in place by way of amendments to the Mandatory and Default Conditions Regulations.

There will be some operating and transition costs associated with permitting sports betting in Act casinos, including acquiring the relevant operating licence s for betting from the Gambling Commission and the cost of siting new SSBTs and supervising them.

The policy could also encourage casinos to invest in broadcasting sport, both in broadcast rights and venue enhancement, which will have additional costs. However, at this stage we do not know precisely what these costs will be, as we do not have any evidence on how casinos will respond to this.

There are likely to be indirect costs in the form of displacement from online sports betting as those in casinos who would otherwise have bet on sports using mobile devices may be more inclined to do so using casino services.

However, the online sports sector generated £2. In addition, the current GGY derived from betting in casinos where it is permitted, is very small. The non-remote sports betting sector is a big contributor to the British gambling industry, generating £1.

Therefore, allowing casinos to provide sports betting services will open up a new section of the market to them. Consumers particularly international tourists still bet on sporting events via mobile devices while in casinos, irrespective of whether sports betting is permitted or not.

Therefore, Act casinos are losing out on potential revenue that might otherwise have been generated if they were allowed to offer sports betting services. Anecdotal evidence shows that only three of the Act casinos offer betting, representing about 0.

This is a small proportion because consumers do not tend to associate casinos with sports betting, which is rarely the purpose of their visit. If this proportion was representative across all casinos, then total casino sector GGY could increase by approximately £1.

However, at this stage we do not know precisely what the GGY benefits will be, as we do not have any evidence on how casinos and players will respond to this proposal. Should all Act casinos be permitted to offer sports betting, regardless of size? Do you agree with the proposed entitlements for Self-Service Betting Terminals SSBTs based on the sliding scale?

Please explain your answer, including an alternative proposal for SSBT entitlements where applicable. If you are a casino licence operator, what impact is permitting sports betting expected to have on the Gross Gambling Yield GGY of your casino s?

If your casino already offers sports betting, what is the GGY from this activity? Please provide an estimate if you do not have an exact figure. What impact is permitting sports betting expected to have on revenue from non-gambling activities e. increased income from sports bars which allow customers to place a bet?

What player protections could be adopted in casinos for those customers participating in sports betting? What constitutes a material change will be a matter for local determination, but it is expected that a common sense approach is adopted. Under the new regime, it is quite possible that a casino would make material changes to its layout in order to site additional gaming machines, tables and potential positions for betting.

We would like to make the process for taking up the entitlement of additional machines as simple as possible for both operators and licensing authorities. There must be some notification that casinos are making a change to the number of machines and tables they are offering, even if this will not always trigger the need for a premises licence variation.

Therefore, we are consulting on how best to allow casinos to move onto the new regime. We propose that an operator must notify the licensing authority of their intention to increase their number of gaming machines.

We would expect the operator to provide all the relevant information so that the licensing authority can understand whether all of the requirements have been met in order to site the proposed number of gaming machines e.

size of gambling area, table gaming area and non-gambling area. We do not intend on changing any of the requirements placed on operators for when a variation to a premises licence may be required. This will need to be decided on a case by case basis.

Casino operators will be required to notify licensing authorities and the Gambling Commission if they decide to take-up their entitlement to additional gaming machines under the new regime. Do you agree with the proposal that casino operators will be required to notify licensing authorities and the Gambling Commission if they decide to take-up their entitlement to additional gaming machines under the new regime?

Operator licence fees are different for Act and Act casinos. Fees are intended to cover the costs of regulation, and higher fees in the case of Act casinos are linked to the higher number of gaming machines they are permitted to site relative to Act casinos, as well as the ability of Act casinos to offer sports betting and, in the case of Large Act casinos, bingo.

Premises licence fees are collected by licensing authorities for applications and annual renewals to cover the cost of administration of their gambling duties and gambling enforcement.

Further information about premises licence fees are outlined in Chapter 5. As some of the differences between Act and Small Act casinos are brought in line, operating and premises licence fees and mandatory licence conditions should be harmonised accordingly.

If Act casinos wish to increase their machine allowances, it is the intention that operating and premises licence fees for Act casinos will be aligned with fees for Act casinos, and the mandatory premises licence conditions for Small Act casinos will also be applied to those Act casinos.

These changes would only come into effect if Act casinos elect to make more than 20 gaming machines including at least one Category B machine available to the customer.

As above, Act casinos will retain the option of continuing to operate under the existing regime should they not wish to increase their machine allocations.

Operating and premises licence fees for Act casinos that increase their gaming machine entitlement should match the operating and premises licence fees charged for Act casinos.

Should the operating and premises licence fees that apply to Act casinos also apply to Act casinos that increase their gaming machine entitlements? Please upload any further evidence or any other information that should be considered as part of this consultation relating to casino measures.

Optional response [File upload]. Arcades adult gaming centres and bingo premises are licensed to offer a range of gaming machines ranging from Category B3 and B4 machines maximum stake £2 and maximum prize £ and £ respectively , Category C machines maximum stake £1 and maximum prize £ to Category D machines e.

slots-style, money prize machines having a maximum stake 10p and maximum prize £5. This rule mandates that at least 80 percent of all gaming machines in Adult Gaming Centres AGCs and bingo halls must be Category C and D. Up to 20 percent of total gaming machines can be Category B.

This rule was instituted to ensure a balance of machines are made available for customer use, limiting the number of machines with higher stakes and prizes available for high street gambling, and allowing larger operators to make commercial decisions on machine availability, rather than relying on fixed numerical limits as had been the case before.

The Order also included provisions known as grandfather or legacy rights. A number of premises, particularly those located in motorway service stations, chose to retain their existing entitlements.

As a result, these venues will be entitled to choose between adopting any revised entitlement set down in legislation following this consultation or retaining the four Category B machine allowance for AGC premises and eight Category B machine allowance for bingo premises.

Extensive consultation was undertaken with a wide range of stakeholders. The main theme that emerged from industry was that the current rule does not allow operators to meet consumer demand. We welcome further evidence on the unmet consumer demand in the consultation response.

In addition, we noted that some player safety improvements have been made to modern Category B3 machines which cannot easily be replicated on older machines, and that customers can and do play at lower stakes than the maximum on Category B3 machines.

As outlined in the white paper, we strongly encourage operators to continue to improve player safety controls on Category B3 machines. The Gambling Commission will also consult on appropriate player protections that should be required on these machines.

The Gambling Commission raised concerns that arcade and bingo venues have sought to maximise their number of Category B machines under the current rules by providing Category C and D gaming on tablets and in-fill machines. The white paper indicated that we would expect industry to strictly adhere to this ratio and we would set out detailed requirements in further consultation.

We are consulting on three different options and seeking further evidence to understand which should be taken forward, on the basis of our overarching objectives of allowing operators greater commercial flexibility and avoiding the situation where machines which customers do not want must be provided, maintained and kept switched on, and providing customers with a genuine choice of higher and lower stake machines.

The significant increase in energy bills for businesses has seriously impacted the sector, with the Bingo Association highlighting that 20 bingo halls have already announced closures this year, many of which cite energy costs as the primary driver.

While the intensiveness of energy expenditure will vary by machine device type and energy efficiency, the costs to industry of maintaining these machines can be significant.

Challenges caused by rising energy costs are in addition to the longer-term commercial challenges faced by industry, particularly following the COVID pandemic. For example, numbers provided by the Bingo Association show that the number of bingo premises that offer mainstage bingo declined from at the end of to in March The objective of commercial flexibility should therefore be understood as providing operators with scope to respond to energy prices for example, by removing unused energy intensive machines and also providing a degree of flexibility to increase the number of Category B machines to promote increased GGY and address long-term commercial challenges within the sector.

The objective of providing customers with a genuine choice of higher and lower stake machines is understood in terms of providing a safeguard against increased gambling harm. For instance, evidence provided by Bacta shows that the average stake placed on a Category B3 game is between £1.

Gambling Commission data, from April to September , indicates that across all land-based sectors, 1. To meet our objectives of allowing operators greater commercial flexibility, avoiding the provision and maintenance of machines which do not appeal to customers, and providing customers with a genuine choice of higher and lower stake machines, we are consulting on the following options.

The impact of each option will vary in how these objectives are balanced. For example, some options may place further emphasis on achieving commercial flexibility than achieving customer choice of higher and lower staking machines, and vice versa.

To ensure a proportionate and evidence-based balance is satisfied, we are seeking views from a range of interested stakeholders to inform the strengths and risks of each option. Also, Category C and D gaming machine device types made available for use must be of similar size and scale to Category B.

As evidenced in the rationale for change, offering customers a genuine choice between higher and lower stake machines is important because Category B machines are associated with higher session losses and increased likelihood of gambling harm.

The Gambling Commission has expressed concern that operators currently seek to maximise Category B machine numbers by providing Category C and D games on inaccessible small tablets or via in-fill machines. For bingo halls, based on a sample of approximately 60 percent of the market, it is estimated that the number of Category C and D cabinets in these venues will decrease by over 1, In addition, there will likely be an increase of approximately Category B cabinets.

This would result in an overall decrease of over cabinet machines across these venues, predominantly consisting of legacy Category C cabinets. The removal of energy intensive legacy Category C cabinets will likely reduce the overall energy consumption of these operators.

The increase in Category B machines will enable bingo halls to better meet customer demand and will likely result in greater GGY. Projections on the impact of this proposal for the AGC sector suggest there will be a 10 percent reduction in the number of Category C machines and a 20 percent reduction in the number of Category D games, in-fills, and tablets.

This is in addition to a 9 percent increase in the overall number of B3 machines, representing approximately machines across the total AGC estate. Similarly to bingo halls, this would likely result in both energy savings and increased GGY for operators. Under the scenario outlined in Option 1, it is expected that there will be a significant increase in commercial flexibility for operators across both bingo halls and AGCs.

The increased flexibility will provide operators with more scope to make commercial decisions relating to energy consumption and customer demand. It is possible that operators could use inaccessible tablets and in-fill machines to increase the overall number of Category B3 machines in their venues, undermining the principle of a balanced offer of higher and lower stake machines giving genuine choice to the customer.

This proposal outlined in Option 2 would require any such premises to have one Category C or D cabinet for each Category B cabinet it sites.

The same rule would apply to all other gaming machine device types. For example, a Category B tablet could only be made available for use if there is one other Category C or D tablet that customers can play on in the venue.

Under this option, for every device with higher maximum staking there would be a lower maximum staking machine of equivalent size and nature available to customers. Consequently, it would deter operators from offering tablets and in-fill devices as a way to increase the number of Category B cabinets on their premises.

This proposal would likely reduce the potential risks of gambling harm associated with an increased number of Category B machines. Data provided by industry indicates that this option would achieve to a limited extent the objective of ensuring commercial flexibility.

When combining the number of cabinets across the AGC and bingo hall sectors there is a surplus of Category C and D cabinets by comparison to Category B cabinets. However, the extent to which this would be significant is questionable.

There would be a reduction of approximately 2, tablets but given the low energy intensiveness of these devices it would not produce comparable energy saving to those outlined under Option 1.

In addition, there would be limited opportunities for operators to meet customer demand for Category B machines and increase GGY.

In AGCs, the number of Category C cabinets across a large part of the sector is significantly higher than the number of Category B cabinets. It would also provide greater flexibility in determining the make-up of their machines and potentially lead to the removal of machines, such as tablets and in-fills, that are infrequently played.

Bacta have argued, however, that the benefits to operators would not be as substantial as those outlined in Option 1.

In addition, we are aware that across both AGCs and bingo halls that the impacts of this measure will vary significantly, from club to club and operator to operator. Indeed, we reviewed data that showed some operators, particularly in the bingo sector where tablets are in widespread use for playing bingo games, have significantly greater numbers of Category B cabinets than Category C and D cabinets.

The equalising of these machine types may come at significant costs for some businesses. This may further contribute to the existing financial challenges across the sector — as indicated by the large number of business closures outlined in the rationale for change. Under the scenario outlined in Option 2, it is anticipated that a genuine balance and choice of higher and lower stake machines would be achieved across venues.

Unlike Option 1, it would be much more difficult for an operator to increase the number of B3 cabinets on their premises by increasing the number of Category C or D in-fills and tablets that they site. Therefore, it could further reduce the risk of gambling-related harm that is associated with higher category machines.

The rationale for considering this option is that even a Category B machine could be argued to have a relatively low maximum stake, that no equivalent ratio of products is mandated online or in other commercial sectors, and that it would give operators maximum flexibility to respond to customer demand, while reducing the burden on the Commission and licensing authorities of enforcing a ratio.

For example, in bingo halls where tablets are essential to play mainstage bingo, it is unlikely there will be a significant reduction. The short-to-medium term impacts of Option 3 would therefore likely be similar to those outlined in Option 1.

However, over the longer term, some industry representatives have suggested that operators would likely further reduce their number of Category C and D cabinets in favour of multi-staking Category B cabinets. Multi-staking category B cabinets provide customers with the choice of staking at different levels and therefore below the maximum stake permitted.

For example, a customer could stake 50p on these machines which is also below the maximum stake permitted on Category C machines. These machines can also offer customers Category C or D content on the same device.

Without any requirement in law for a balanced offer, it is possible that this option would result in Category B machines becoming the only product on offer. Under such circumstances, and given the relatively higher stakes and losses set out in the rationale for change, there is the potential for gambling-related harm to increase.

In addition, while customers could stake lower than the maximum on a multi-stake Category B machine, evidence suggests that on average players tend to stake more on Category B machines than Category C and D machines.

For example, as previously highlighted, evidence provided by Bacta shows that the average stake placed on a Category B3 game is between £1. Therefore, this option would need to be accompanied by a requirement that Category B3 machines in these venues would have certain player safety controls, such as staff alerts where a player meets spend or time limits.

We would like to understand whether these types of protections are already available on these machines, or whether it would require investment in new machines or software. These represent transition costs which are expected to be incurred in the first few years of implementation, with exact timescales depending on the option taken forward.

We will use the responses to this consultation as well as wider engagement with the sector to gather data to estimate the likely uptake of additional machines and removal of existing machines under each option. This covers all venues, not just bingo and arcade venues, but it indicates that increasing the number of gaming machines available to play may come with an associated increase in the risk of gambling harm.

For comparison, these rates are above the at-risk and problem gambling rates for bingo games While we have no direct evidence on the rate of gambling harm for those participating on gaming machines in bingo and arcade venues specifically, we can use net expenditure and session length data to consider the possible risks of gambling harm.

The data used in this section reflects activity from April to September and relates to a single session on a particular machine. This is possible on the single terminals that offer multiple games across a range of Categories. For example, a player may start a session on the Cat B game, before switching, within a session, to a Cat C game.

Data on session duration shows that, in general, players spend a similar amount of time on Category B machines as Category C and D machines. This suggests a relatively similar level of binge gambling across both machine categories. Data on net expenditure per session shows that from April to September , the vast majority of sessions across all machine categories ended in the player either winning money or losing up to £ On the other hand, the data shows that a substantially higher proportion of sessions on Category B machines ended in a loss over £, compared to Category C, Category D and mixed machines.

This suggests a higher risk of unaffordable spending on Category B machines. Although the data on mixed sessions creates some uncertainty, we conclude that overall, Category B machines lead to higher losses than Category C or D machines.

This difference is particularly stark for bingo venues. Any measure that increases the availability of Category B machines risks leading to increased gambling harm for those playing on the machines.

All options set out in this section are expected to lead to an increase in the total number of Category B machines across bingo and arcade venues. This increase is expected to be higher under Option 1 than Option 2, as operators will not be restricted by device constraints.

The increase in Category B machines is expected to be even higher for Option 3, where no restrictions would be applied. Therefore, the risk of increased gambling harm is assumed to be higher for Options 1 and 3 than Option 2.

A more detailed estimate of the impact for each option will be presented in the final stage impact assessment, once further data has been collected.

Player protections can be used to mitigate increases in the risk of gambling harm. The Gambling Commission will conduct a future review of the gaming machine technical standards. This will include assessing the role of sessions limits across Category B and C machines alongside safer gambling tools.

The primary benefit of this measure is a reduction in energy and maintenance costs from unused machines. The proposed measure will allow venues to remove unused Category C and D machines and save on the costs of maintaining and powering them. Energy costs per machine will be estimated in the final stage impact assessment using an energy calculator.

We do not currently have sufficient data to estimate the likely reduction of Category C and D machines under each option. We welcome further evidence on this in the consultation response.

Another key benefit is the increased GGY from Category B machines in bingo and arcade venues. Category B machines are significantly more profitable for operators earning considerably higher GGY than Category C and D alternatives.

In the financial year to , the average GGY per Category B machine across all licenced land-based venues was £30,, compared to £2, per Category C machine and £1, per Category D machine.

As such, any change in the composition of gaming machines which results in a higher share of Category B machines will represent an uplift in GGY for operators. We do not currently have sufficient data to estimate the likely uptake of additional Category B machines under each option, nor on how the average GGY per machine will change as a result.

Therefore, we cannot currently estimate the total increase in GGY for each option. We will use the responses to this consultation as well as wider engagement with the sector to gather data to estimate the likely change in machine configuration in bingo and arcade venues. This will be used to model the estimated increase in GGY for each option in the final impact assessment.

Indirect benefits are also expected to accrue as a result of this measure. A healthier land-based gambling sector, able to compete on a more even basis with similar online gambling opportunities, is likely to support local employment opportunities, regeneration effects and contribute to business rates.

We have been unable to estimate the scale of these benefits at this time. Finally, we anticipate there may be some wellbeing benefits resulting from the continued existence of bingo halls, supported by revision of the rule.

Anecdotal evidence suggests that for some individuals the option of attending physical bingo premises delivers substantial social benefits which would be lost if the sector is not supported.

It has not been possible to model these benefits at this stage in the analysis. How, if at all, would the approaches taken in Options 1, 2 and 3 impact the ability of business to meet customer demand for gaming machines?

What impact would options 1, 2 and 3 have on Gross Gambling Yield GGY for businesses? If available, please provide evidence of the potential impact of Options 1, 2 and 3 on the GGY of operators and on the wider gambling sector. Mandatory response What impact would Options 1, 2 and 3 have on the overall number of Category B machines?

What impact would Options 1, 2 and 3 have on the overall number of Category C machines? What impact would Options 1, 2 and 3 have on the overall number of Category D machines?

If available, please provide estimates of the potential impact of Options 1, 2 and 3 on the overall number of machines. What impact would Options 1, 2 and 3 have on the product mix of Category B, C and D machines? For example, cabinets and terminal devices. Please provide any evidence you have on the potential harm of implementing Options 1, 2 and 3 on customers.

What impact would Options 1, 2 and 3 have on the overall number of Category B, C and D gaming machines? Please rank these options in order of preference, with 1 being your preferred option. Optional response.

Please explain why this is your preferred option. Please outline any other proposals relating to machine allowances in arcades and bingo halls that you think that we should consider. What benefit would this proposal s offer in comparison to Options 1, 2 and 3?

Please upload any further evidence or any other information that should be considered in this consultation relating to bingo and arcade gaming machine measures.

The Gaming Machine Circumstances of Use Regulations prohibit the use of debit cards for direct payments to gaming machines, and prohibit any use of credit cards.

As they are an extension of card payment, the direct use of contactless mobile systems such as Google Pay or Apple Pay on gaming machines is also prohibited. The original purpose of the debit card rules was to protect players. Cash-only gambling was assumed to give players more control by providing natural interruptions in play to obtain more cash, helping players play within budget limits.

The legislation also requires ATMs in gambling-licensed premises to be positioned so that any customer who wishes to use them must stop gambling in order to do so, while in pubs and clubs the rule comes from the Code of Practice.

Since these rules were put in place, the use of card payments has increased greatly across society and in many settings cash is a rarity. However, it is still the primary way to pay for machines in land-based venues. For example, some machines accept indirect payment from a debit card via mobile apps.

Some venues also operate a ticketing system, which allows customers to purchase a ticket with a debit card for use on a gaming machine.

When casinos reopened following COVID-related closures in , casino operators introduced an approach, agreed by the Gambling Commission, whereby customers could stand up and turn away from gaming tables to complete a debit card transaction with a staff member via a mobile card terminal.

The approach was seen as being consistent with the intention of the Gambling Act Mandatory and Default Conditions England and Wales Regulations and their equivalent in Scotland in ensuring players have a break in play before being able to access additional funds.

So while debit cards can be used at casino tables, they still cannot be directly used as a form of payment on gaming machines in casinos.

Gaming machines are currently permitted in a variety of locations and divided into various categories based on factors such as maximum stake and prize available, as well as the premises where they may be used. Land-based gambling has a significantly larger workforce than online gambling.

In addition to this, research commissioned by Bacta showed that in , seaside arcades alone contributed £m in UK GVA, and were responsible for employing around 19, people.

Across society, cash has been declining as a form of payment method. While the existing framework has allowed for some innovation in cashless payments, gambling has largely remained cash-based.

The lack of direct cashless payment methods on gaming machines contrasts with the cashless options that consumers have within the wider retail economy. There has also been a decline in gaming machine usage in alcohol licensed premises.

Evidence submitted by the British Beer and Pub Association shows a post-COVID decline in both the percentage of pubs with machines and machine weekly income. Anecdotal industry evidence suggests that payment methods are a factor in this decline in machine usage, as pub goers now pay for food and drink by card but might have previously played a machine using spare change.

This indicates that unless customers actively plan to bring cash to a pub for use on a gaming machine, they are unlikely to be able to use one.

Bacta highlighted that pubs no longer give cashback and ATMs have all but disappeared from pubs, making it more difficult for customers to access cash to use on machines. They also noted the cost of refloating machines, which has become more challenging for pubs where cash payments are not taken over the bar.

The societal shift towards cashless payments threatens the future of gaming machine GGY. not including alcohol-licensed and other such premises was £1. This would likely affect the future viability of land-based venues, which support jobs and have been adversely affected by the pandemic.

The introduction of direct forms of cashless payments on gaming machines, subject to suitable safeguards, therefore represents an opportunity to future-proof the land-based gambling industry.

As mentioned above, the existing regulations prohibit the use of debit cards for direct payments to gaming machines, and prohibit any use of credit cards. Lifting the prohibition will require us to amend secondary legislation, but we do not intend any relaxation of the prohibition to extend to credit card payments.

This is because allowing people to gamble with money that they may not have exposes players to a higher risk of harm. While it is important to future-proof gaming machine payment methods, there must be a balance between this and any elevated risk of harm that could emerge from allowing direct cashless payment methods to be used for gambling.

There is evidence that cashless payment methods are associated with increased expenditure in comparison to the use of cash , which can lead to unintended consequences for consumers including overspending and a higher willingness to pay.

Consumer preferences therefore indicate that cashless would need to complement, rather than replace, cash as a gambling payment method.

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