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UK LEGAL


industry. This is ringfenced for enforcement activity against unlicensed operators who illegally target the British market. The Commission will no doubt use part of these funds to increase its monitoring activity and continue to engage with search engines such as Google to take down illegal sites, but a significant part of its spend is likely to relate to prosecuting those unlicensed operators with the biggest impact in the British market. Whist there will be challenges associated with prosecuting operators based overseas, the threat of such proceedings may serve as a deterrent.


EVALUATION OF WHITE PAPER MEASURES?


The Gambling Commission and DCMS have jointly commissioned the National Centre for Social Research (NatCen) to evaluate the impact of the various reforms arising from the White Paper. NatCen’s report is expected to be published at some point in 2026 and will use various methods to gather data, including obtaining data from licensed operators and carrying out surveys with consumers and other stakeholders.


Given the number of new measures introduced in a relatively short timeframe, it is difficult to see how NatCen will be able to accurately measure the impact of each individual reform. It is also probably too much to hope that the outcome of this process will lead to any refinement of the rules already implemented, given that NatCen’s evaluation of the credit card ban did not lead to any reconsideration of that measure, despite appearing to find that use of credit cards for gambling actually increased amongst those most vulnerable to harm. However, evaluation of the impact of the reforms is crucial not just to understand the impact (including any unintended impact) of them, but also to ensure accountability and transparency in the regulatory process.


there will be fewer licence reviews overall than we saw in previous years, however we can expect that when the Commission does take formal action against a licensee, the penalties will be sharper. The recent £10m fine for Platinum Gaming and suspension of licences held by Deadheat Racing, VGC Leeds and Spribe are indicative of this approach.


£26m in additional funding has been promised by the Government to be delivered over the next three years, derived from the increased taxes to be paid by the gambling


24 JANUARY 2026


Melanie is a gambling regulatory lawyer with 13 years’ experience in the sector. Melanie advises on all aspects of gambling law including licence applications, compliance, advertising, licence reviews and changes of control. She has acted for a wide range of gambling operators including major online and land-based bookmakers and casinos, B2B game and software suppliers and start-ups. She also frequently advises operators of raffles, prize competitions, free draws and social gaming products. Melanie has a particular interest in the use of new technology for gambling products and novel product ideas.


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