UK LEGAL
EXTENDED CONVERTED CASINOS An extended converted casino is a larger converted casino that chooses to take up the new entitlements. They can do this by making an application to the local authority to vary their licence to add a table gaming area to the plan of the premises. If granted, this will effectively give the casino machine entitlements up to those allowed for a 2005 Act small casino (depending on gambling area), but also the same additional rules on table gaming and non-gambling areas. An extended converted casino will be permitted to offer category B to D gaming machines in the ratio of 5 machines per live gaming table, up to a total of 80 machines on a sliding scale based on gambling area. A gambling area of 280m2 would permit 25 gaming machines, with increments of 5 additional machines per 20m2 of gambling area, going up to 80 machines allowed for a casino with a gambling area of at least 500m2 (all subject to the 5:1 ratio).
As with larger converted casinos, betting machines will also be permitted on the same sliding scale.
premises under the new entitlements may need to apply to the local authority to vary the plan attached to their premises licence, for example if they plan to reduce the table gaming area and increase the area allocated to machines.
As well as making existing small casinos more commercially viable, these changes are presumably intended, at least in part, to increase the likelihood that the unused small casino licences will become operational.
LARGE CASINOS
The main change that will affect large casinos is the amendment to the definition of a gaming table, for the purpose of calculating machine to table ratios. Otherwise, the provisions for large casinos remain the same, with the total gaming machine allowance remaining at 150, with a 5:1 machine to table ratio.
OTHER CONVERTED CASINOS The “other” category covers existing converted casino premises where the gaming area is less than 200m2. There will be no change to the gaming machine entitlement for these premises, it will remain at 20 category B to D machines (or any number of C or D machines).
For the new betting allowance, these casinos will be permitted to offer up to 16 self-service betting positions.
If this type of casino plans to increase its gaming area to greater than 200 m2, it will then need to choose between becoming a “larger converted casino” (by taking no further action) or an “extended converted casino” (by applying to the local authority).
28 JULY 2025
LARGER CONVERTED CASINOS A “larger converted casino” will be any casino holding a converted casino premises licence and having a gambling area of at least 200 m2.
The gambling area in these casinos must remain below 1500m2, unless on 12 May 2025 they already had a larger gambling area. Those with a 1500m2+ gambling area on 12 May 2025 may not further increase their gambling area, nor may they move the licence to different premises unless as part of the move they also reduce the gambling area to less than 1500m2.
Larger converted casinos will retain their existing entitlement to 20 category B to D machines (or any number of C or D machines). They will be able to offer self-service betting positions on a sliding scale, from 16 if their gambling area is less than 280m2, adding 2 positions per additional 20m2, up to 40 if their gambling area is over 500m2.
The following additional rules will apply to an extended converted casino: • The premises must contain a table gaming area which is at least half the size of the total floor area of the gambling area, or 250m2 (whichever is smaller);
• The premises must contain a non-gambling area, which again is at least half the size of the gambling area, or 250m2 (whichever is smaller);
• The provisions regarding the total gambling area remaining below 1500m2 (as per larger converted casinos) will still apply;
• Where two casino premises are at the same location or immediately adjacent (this is where a customer can move between the premises without passing through an area that is not controlled by one of the casino operators), the maximum number of machines across both premises may not exceed 80.
Once a converted casino has chosen to take up this new entitlement, it may not revert back to its previous entitlements.
Melanie has been providing UK legal and regulatory advice to betting and gaming clients since the advent of the Gambling Act 2005. She advises on all aspects of gambling law including licence applications, compliance, advertising, licence reviews and changes of control and is described in the legal directories as “a very impressive lawyer” who “demonstrates commercial pragmatism supported with a great deal of technical and operational knowledge and experience”.
Melanie 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. She is a regular contributor to industry publications and often speaks at industry events. Melanie is listed as a ‘Leading Partner’ in the Legal 500 guide and is also ranked in Chambers.
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