- Date
- 9 October 2026
- Details
-
We have received guidance from the Gambling Commission which we have been asked to share with all casinos within the borough.
Please take the time to read the information provided below. If you have any questions regarding the guidance, please do not hesitate to contact us at licensing.unit@bolton.gov.uk
Reminder of casino regulations
In summer 2025, government introduced a number of measures via secondary legislation with a view to modernising land-based casinos in England and Wales. The amendments give converted casinos the option of exercising an extended gaming machine entitlement provided certain requirements are met. In support of implementation of these legislative changes, the Commission published guidance to assist the premises licence variation process for those licensees wishing to take advantage of the new entitlements and for licensing authorities in considering variation applications.
The Commission has received intelligence that suggests that the changes made to the regulatory framework may not have been fully understood by all stakeholders and that, in some instances, premises licence variations appear to have been granted contrary to the regulations. We therefore want to take this opportunity to signpost licensees to our guidance. We request that casino premises licence variations granted after 22 July 2025 are reviewed to ensure compliance with the regulatory framework, and that appropriate steps are taken by licensing authorities to regularise the position in cases where issues of non-compliance are evident.
Specifically, we would like to draw attention to 3 elements of our guidance.
Non-gambling areas
The policy intention behind non-gambling areas in casinos is well established and recorded in documents such as, for example, the Explanatory Memorandum to the 2007 Mandatory and Default Conditions Regulations (opens in a new tab), the 2024 government consultation response (opens in a new tab) and the Explanatory Memorandum to 2025 Gaming Machines and Mandatory Conditions Regulations (opens in a new tab). Respectively, these documents outline that: ‘providing a non-gambling area in casinos is an important way of ensuring that customers can take a break from gambling in an area where they are not exposed to any gambling facilities’; there should be ‘clear delineation between gambling areas and non-gambling areas’; and ‘...this instrument in particular ensures that a number of strict rules are in place to ensure customers are offered a balanced variety of gambling and non-gambling opportunities in these venues’.
The Gaming Machines and Mandatory Conditions Regulations (opens in a new tab) require that ‘extended converted casino premises’ (those 1968 Act casinos which decide to take up the extended gaming machine entitlement) must have a non-gambling area no less than half the size of the gambling area or 250m², whichever is smaller. The non-gambling area:
- may consist of one or more areas within the premises
- must not provide facilities for gambling
- may consider lobby areas and toilet facilities in calculating the non-gambling area; but the non-gambling area must not consist exclusively of lobby areas and toilet facilities, and
- at any time during which facilities for gambling are being provided on the premises, each separate area comprising the non-gambling area, other than the lobby areas and toilet facilities, must contain recreational facilities that are available for use by customers on the premises.
In some instances, variations have included staircases, corridors and lifts within non-gambling area calculations. Such areas, by any common definition, serve different purposes to lobby areas or toilet facilities and therefore should not be considered as such. Furthermore, given the purposes of staircases, corridors and lifts it is difficult to envisage that relevant recreational facilities can be provided safely in those areas as required. Whilst all applications need considering on a case-by-case basis, licensing authorities should assure themselves that, in the non-gambling area calculations received, all ‘other’ areas contain the safe provision of relevant recreational facilities.
Additionally, examples have been highlighted whereby it appears there is no clear delineation between the gambling area and non-gambling area (for example, plans with a narrow strip of non-gambling area located between a bar and a gambling area).
Maximum gambling area of all converted casino premises
The Gaming Machines and Mandatory Conditions Regulations (opens in a new tab) introduced a new requirement that all 1968 Act casinos should have a gambling area of less than 1,500m² (as is currently the case for small 2005 Act casinos). Those Regulations included temporary relief from this new requirement for the very small number of 1968 Act casinos where the gambling area was 1,500m² or greater on 12 May 2025. No casino in that group is bound by the maximum gambling area requirement until it purports to increase the size of its gambling area or varies the converted casino premises licence so as to relate to new premises.
The Commission is aware of an instance whereby the evidence suggests that a 1968 Act casino with a gambling area of less than 1,500m² as of 12 May 2025 was able to vary its licence to increase its gambling area to more than 1,500m². Such a variation would be contrary to the regulatory framework.
Additionally, where casino premises are connected (when two or more premises licences are utilised at the same location or immediately adjacent to each other), the mandatory conditions regarding the maximum gambling area apply separately and distinctly to each individual premises. As such, any licensee that seeks to make physical changes to connected premises that result in an extended gambling area in one casino (of 1,500m² or greater) and a reduction the gambling area in another casino, is unable to justify this by stating there is no change to the overall gambling area of both casinos.
Premises plans
Variations to become an ‘extended converted casino premises’ (those 1968 Act casinos which elect to take up the extended gaming machine entitlement) must be accompanied by a scale plan. That plan must show:
- the location and extent of any part of the premises which will be a table gaming area
- the location and extent of any other part of the premises which will be used for providing facilities for gambling in reliance on the licence. This may include gaming machines, wholly automated gaming tables, electronic terminals used in connection with real games of chance, a betting counter and betting positions (self-service betting terminals)
- the location and extent of any part of the premises which will be a non-gambling area.
Plans should also clearly show the:
- floor area of the table gaming area
- floor area of the gambling area
- floor area of the non-gambling area
- number of gaming tables for the purposes of calculating the tables: machine ratios
- number of gaming machines
- number of betting positions.
We have seen examples of plans that, in our view, do not satisfy the requirements set out in legislation and/or provide insufficient information to allow licensing authorities to reasonably assess compliance with the requirements.