The 2025 Gambling Act Overhaul: All Bets are Off for UK Gaming and Licensing Law

To pull from my own research gained from speaking with legal practitioners in the gaming sector, the impact of these changes on licensing frameworks and operational compliance is already very real. With the rising popularity of online gambling platforms, which (excluding lotteries) now contribute to more than half of the UK’s total gambling revenue, the British Government has turned its attention to modernising laws originally drafted before the explosion of digital technology. The newly passed Gambling Regulation Reform Bill, building on the 2023 White Paper, introduces a new roster of obligations that will likely reshape business models across the sector.

The most headline-grabbing change is the introduction of mandatory financial risk checks for online gamblers. From this point on, operators are required to conduct tiered affordability assessments, especially when a customer’s losses cross certain thresholds. This shift reflects growing political pressure to mitigate gambling addiction and protect vulnerable users. However, it also presents significant operational challenges: Legal practitioners are already having to navigate the fine line between compliance and data privacy, as operators seek to verify players’ financial health without breaching GDPR rules or alienating their customer base. This echoes the broader tension seen in other industries, where the need for consumer protection must be balanced against commercial realities.

Equally transformative is the formalisation of a statutory levy on operators to fund research, education and treatment (RET) for gambling harms. For years, contributions were made on a voluntary basis, leading to accusations of inconsistency and insufficient funding. With a mandatory levy set as a condition of licensing, operators must now factor these costs into their financial planning. From a legal perspective, this change is prompting a wave of advisory work around structuring contributions, auditing compliance and general managing disputes over the allocation of levy funds.

One might ask why, despite these new powers, the Gambling Commission has not already taken a harder line on enforcement. The answer stems from the complexity of the industry and the Commission’s historically limited resources. However, the reform package grants the regulator enhanced investigative powers, including the ability to compel data sharing and impose tougher license conditions. This newfound authority acts as both a carrot and a stick – while it raises the stakes for non-compliance, it also offers operators the opportunity to collaborate with regulators in shaping best practices.

The legal community has also turned its attention to the new restrictions on online slot machine stakes and game design. Under the new system, stake limits are capped between £2 and £5 (depending on the player’s age group) and features like autoplay and rapid spin cycles have become more restricted. This marks a direct intervention in product development, forcing operators to revisit their portfolios and rethink their user engagement strategies. For law firms, this has sparked closer collaboration between regulatory teams and commercial/IP practices, as clients seek to ensure that their game designs comply with the new codes of conduct.

Perhaps less visible but equally consequential are the tightened rules around gambling advertising and sports sponsorships. The reforms aim to reduce the exposure of those under 25 years of age to gambling promotions, which has led to a cascade of renegotiated contracts in various sports including football and rugby. Legal practitioners in media and advertising law are seeing an increased demand for advice on sponsorship agreements and advertising standards compliance.

With these sweeping changes, another question arises: Why has the overhaul not upended the UK gambling market? The answer, much like the legal sector’s hesitant embrace of AI technology, can be considered a result of trust and risk aversion. Gambling remains a highly regulated but socially accepted form of entertainment in the UK. The British Government, wary of driving consumers to unlicensed offshore sites, has opted for incremental reform over an outright clampdown.

However, it would be a mistake to assume that the current reforms mark the endpoint of regulatory scrutiny. As with the legal profession’s cautious adoption of AI, which has not been helped by high-profile errors like the infamous ChatGPT-generated fake cases, the gambling industry’s future hinges on its ability to rebuild public trust. Each regulatory breach or instance of gambling damage fuels calls for even tougher measures, including potential bans on certain forms of online betting and gaming.

From a legal practice standpoint, the reforms have transformed gambling law from a niche specialty into a multidisciplinary field encompassing regulatory compliance, data protection, corporate transactions and public law. Firms with established gaming practices are expanding their teams, while boutique firms are finding new opportunities in representing smaller operators grappling with the complexities of the updated regime.

One area of particular interest is the surge in demand for pre-transaction regulatory due diligence. With the Gambling Commission's enhanced authority, acquirers and investors are scrutinising targets for historical compliance issues that could result in hefty fines or license revocation post-acquisition. Cross-border considerations, especially for operators that are based in Gibraltar and Malta but serve the UK market, add another layer of legal complexity.

Looking ahead, the industry is bracing for a second wave of changes as the Gambling Commission rolls out further technical guidance and secondary legislation. Legal experts anticipate a rise in judicial review challenges, as operators test the boundaries of the new framework and push back against what they perceive as regulatory overreach.

While the recent overhaul of the Gambling Act 2005 does not spell the end for UK gaming and licensing as we know it, it unquestionably signals a new era of heightened scrutiny and operational discipline. The challenge for operators and their legal advisers will be to navigate this shifting landscape with agility, ensuring compliance while preserving the commercial viability of their businesses.

Until a new equilibrium is reached, most likely through a combination of regulatory refinement and technological innovation, the effect of these reforms will continue to ripple through the UK gambling market. For legal practitioners, this represents both a challenge and a generational opportunity to shape the future of gaming law in the UK.