Seven-step model aims to clarify enforcement process and strengthen industry accountability
The UK Gambling Commission (UKGC) has announced a major update to its Statement of Principles for Determining Financial Penalties (SoPfDFP), which governs how fines are calculated and imposed on gambling operators. The revised guidelines, a product of extensive industry consultation, will come into effect on 10 October 2025, with the objective of enhancing transparency, proportionality, and enforcement efficiency.
A Structured Seven-Step Approach to Penalty Imposition
The new framework introduces a seven-step process that will guide the Commission’s decisions when issuing financial penalties. This process is designed to remove ambiguity by clearly setting out:
Initial breach assessment
Determination of severity based on a new five-tier metric
Calculation of the starting penalty amount as a percentage of Gross Gambling Yield (GGY)
Consideration of aggravating and mitigating factors
Adjustment of penalties accordingly
Consideration of operator cooperation and early resolution
Final determination and publication of the penalty
The model aims to standardise enforcement actions, ensuring they are fair, proportionate and consistent across the sector.
Industry Consultation Drives Policy Shift
The decision follows a lengthy consultation that concluded in March 2024. According to the UKGC, 29 stakeholders provided responses, though only 21 chose to be named in the final report. This feedback significantly shaped the final guidelines, especially around improving procedural clarity and ensuring flexibility for diverse operator types.
One major exemption includes society lotteries and external lottery managers, whose penalties will not be based on GGY, recognising their not-for-profit nature and different regulatory objectives.
Severity and Proportionality at the Core
One of the key innovations of the new policy is the five-tiered severity scale, which classifies breaches from minor to very serious. This scale will guide the baseline penalty amount and reflect the actual harm caused to consumers or the market.
Moreover, the Commission has defined what constitutes aggravating circumstances—such as repeat offences, deliberate concealment, or harm to vulnerable players—as well as mitigating factors like voluntary disclosure, rapid corrective action, and robust internal compliance systems.
A Tool for Consumer Protection and Operator Responsibility
John Pierce, Director of Enforcement and Intelligence at the Gambling Commission, underscored the wider benefits of the changes:
“The resulting changes will strengthen our decision-making and streamline the calculation of penalties – helping to improve the efficiency and effectiveness of our enforcement work… [and] support the protection of consumers alongside fair and proportionate outcomes for operators.”
The UKGC views these changes not merely as a punitive tool, but as a means to encourage early compliance, boost public trust, and support a safer gambling environment.
What Comes Next?
With the new guidelines scheduled to take effect in October 2025, the Commission is expected to publish detailed technical documentation and training materials in the coming months. Operators will need to review internal compliance protocols, evaluate potential financial exposure under the updated rules, and prepare for a more predictable but rigorous enforcement environment.
As the UK continues to modernise its gambling regulatory framework, this latest move reflects a growing emphasis on accountability, consumer protection, and operational transparency in the face of evolving industry dynamics.
