Industry Forum minutes for 15 January 2026

Minutes of the meeting of the Industry Forum, 6 August 2025.

[Remote] Industry Forum Meeting

Members:

• Kirsty Caldwell (Interim Chair)
• Tony Boulton
• Charles Cohen
• Ashley Padgett
• Mark Pearson
• Nigel Roddis
• Leo Walker
• Helen Walton
• David Williams.

In attendance:

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Apologies: Tony Boulton.

Observing: Gambling Commission (GC) Commissioners - David Rossington and Helen Dodds.

1. Welcome, apologies and declarations of interest

Apologies for the meeting were noted, no new declarations of interest.

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2. Approval of minutes

Approved subject to slight amendments.

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3. Welcome to Interim Chair

The Interim Chair (IC) was congratulated on her appointment. Members were positive about this appointment and praised the Interim Chair’s engagement in the Forum so far.

The IC introduced some topics to cover in the next couple of months.

There may be some misunderstanding across industry about what the Industry Forum (IF) is and what they do. The IC wants to address this by being more open and/or public about the work the IF does and reset industry’s understanding of the purpose of the Forum.

The IC wants to be proactive about having input from members into meeting agendas. It can be frustrating for members when topics presented don’t feel the most important, but members can help to make this a two-way street by being proactive about topics of interest.

The IC will be meeting with the Gambling Commission Interim Chair and CEO which will help to steer items for future meetings. The Expert Group team will look to arrange a ‘1 in 4’ meeting whereby a team from the GC attends a meeting, introduces themselves and presents their role and remit in the GC, in a bit more detail. The IC expressed an interest in the Licensing team featuring in this.

The IC reminded members that the GC have invited IF to attend the Spring Conference and have also been offered the opportunity to participate by presenting on the day.

An IF member has volunteered to present on the Illegal Market at the Spring Conference, covering the topics of what attracts players to the illegal market, onboarding and withdrawals.

The IC recommended that she present on the IF itself; what they do and what they’re here for. A member suggested that in principle this is a good idea, but it is important to ensure the Forum are not justifying their existence. Instead, ensure it is scoping out how to get more engagement from the wider industry and requesting for industry to feedback on topics to take back to the Forum.

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The IC wants to expand how the IF are working with the Commission; for example, by members providing direct input to projects in the GC instead of keeping engagement strictly to meetings.

The IC asked members what they would like to see from her and received some comments.

The value of the Forum derives as and when there is the correct level of engagement at a senior level. At times it feels like there isn’t the correct level or seniority presenting and/or attending. Members want to be engaging at a high enough level so as to feel they are having an impact. This will help to raise enthusiasm in members.

Members welcome more early intervention in the Research and Policy Team so as to have a bigger impact. The customer tools led item is an example of good interaction with GC.

GC Commissioners David Rossington and Helen Dodds introduced themselves in the meeting. They expressed their enthusiasm to be observing the meeting to learn more about the Forum.

4. LCCP Key event guidance update

REDACTED introduced themselves and their item. They have been involved with the public consultation on changes to financial key event reporting in respect of ownership of, and interests, in operators under LCCP 15.2.1.   Key event reporting requirements help operators understand what to notify the GC about. All notifications from operators are taken seriously and high-risk issues are followed up. Previously, the forensic accounting team have found examples of events that should have been reported but were not, such as changes in key personnel. Events of this nature that are not reported can, in some instances, cause AML risks.

It took a while to publish our response to the consultation due to the complexity of the responses from stakeholders. There were some interesting and helpful points that came out of the consultation. The outcome is that some proposals are being taken forward and some may be revisited in the future. The 2 main changes involve:

• increasing the reporting threshold for ownership and interests from 3 percent to 5 percent
• expanding reportable interests to include voting rights and rights to profits.

Today’s agenda item is related to an update to guidance notes which will be published on the GC website before the implementation date for these changes. At this stage the team have looked at improving the guidance notes related to the reporting of ownership and interests only. There are plans to update the whole of the guidance notes further in future. The team would also like to improve the signposting of these notes on the Commission’s website, so they are easier for operators to find.

GC officials are asking Industry Forum members for feedback on the suggested improvements to the guidance notes, particularly; is it clear what the GC are asking industry to do, or do they need more information and/or clarification?

One member asked if these changes would mean that the Commission’s own processes will be simplified to the extent that change of corporate control (CoCC) applications would not take so long (the member cited an example of an 18 month wait for a CoCC application to be processed).

The GC Official stated that the Commission cannot always control the flow of key evets due to resource, however this has improved recently, so the processing time should be quicker now. However, these changes only relate to key events rather than applications, so it is not expected for them to impact processing time of applications.

The IC commented that a number of clients were struggling to understand the reporting requirements around directors’ loan accounts. For example, do dividends taken through a loan account need to be reported?

The GC official clarified that this would not be reportable as the director would be taking money out of the business through dividends. The key event relates to funds being paid into a business by a director, as it could be considered to be a loan, subsequently triggering the notification requirement.

The GC is only concerned with loans that have a significant impact on the nature or structure of an operator’s business. This will be based on the operator’s subjective assessment of their own business.

The IC suggested that examples could be included in the guidance notes to help directors of smaller companies. This was noted by GC colleagues as a good suggestion.

The GC Officials explained that whereas previously operators only had to report shareholdings, the definition of interests is to be expanded to include voting rights and rights to profit and talked through the draft changes to the guidance in this area including giving examples of the different types of business structures and what each would need to report.

Members agreed that the objective of the changes is clear, although some of the wording could be improved in the guidance. For example, one member stated that the use of the word “partner” needs to be revisited because Limited Liability Partnerships (LLPs) have members rather than partners.

Members agreed that a flowchart might be an easier way of digesting this information.

The IC noted there should be more consistency with wording (name and address vs name/address/DOB).

The REDACTED provided clarification that the obligation is for operators to report within 5 working days of becoming aware of an event, not within 5 working days of an event occurring. This takes into consideration that events may not be in the operator’s knowledge at the time they happen, depending on the scale and complexity of the organisation. For example, publicly traded companies have to rely on public filings for information about shareholders.

The REDACTED explained that in respect of the requirement to report non-Financial Conduct Authority (FCA) loans, only one small change has been made to add the words “if any” after the reference to loan agreement. However, following feedback in the consultation responses the guidance notes have been expanded.

A member asked what would happen if it transpired that operators reviewed this improved guidance and realised that they should have reported events but did not, due to the previous lack of clarity. The REDACTED stated this will be assessed on a case-to-case basis but that the overall objective was to improve and achieve more compliance in the industry, not to fine operators.

The GC are adding in a definition of ‘loan’ and what might be included within it. These changes are based on casework and experience that has been collated along with queries that have been sent into the GC. Regarding notifications about FCA loans, the GC want to eliminate the need for unnecessary reporting of loans and create focus on the loans that should be reported e.g., where non FCA loan monies end up in the licenced operator (rather than remaining in another group company). The GC understands it is difficult to track loans that are historic.

A member expressed that some of the detail in this item is too high-level for some IF members but that they would be happy to share the information internally with their relevant teams and feedback.

Another member suggested that it would be useful to include a preamble on what the GC is trying to achieve with each reporting requirement. The REDACTED agreed.

The REDACTED also agreed with the IC that the guidance around directors’ loans could be expanded and developed.

Members were thanked for their feedback and were reminded that any specific queries about the reporting requirements for key events could be directed to Licensing colleagues through the usual channels.

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5. Policy: Gambling Act Review (GAR) Evaluation

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6. Recap of 2025

The REDACTED reflected on some of the successes of the Industry Forum in 2025, expressing how the GC’s Interim Chair is engaged with Expert Groups and keen for their support to continue in 2026.

One GC official also reflected on some of the topics that have been brought to the Forum such as Illegal Gambling. This large topic is being worked on in different areas across the GC and feedback from GC colleagues is that input from the IF has been very helpful so far. The REDACTED intend to arrange further collaboration between the GC and IF on this topic.

One GC official also recapped on areas of work from IF members that were outside of meetings for example attendance at GC board to discuss the HMT tax consultation and attendance at various events such as KnowNow and Smart Betting Club.

IF meetings will be developed to allow space for ‘hot topics’ suggested by IF members. One member suggested that the HMT consultation is a hot topic to be addressed as a priority.

7. AOB

Members would like to see increased senior-level attendance at Industry Forum meetings so that they feel their input is being heard by decision makers.

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