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Interview with a representative of the UK Gambling Commission
The UK is one of iGaming's most rigorous and predictable markets. The UK Gambling Commission (UKGC) license gives access to the largest regulated audience, but requires mature compliance: from responsible play and financial monitoring to technical standards and transparent advertising. We have spoken to a representative of the UKGC about the regulator's key expectations and practical steps for claimants and current licensees.
Short reference
UKGC regulates operators and key suppliers in the UK market. Basic responsibilities are enshrined in LCCP (License Conditions and Codes of Practice) and Remote Technical Standards (RTS), plus requirements for AML/CFT, data protection, advertising and work with vulnerable groups apply. The approach is risk-based, focusing on consumer safety, product integrity and business transparency.
Interview (Q&A)
1) Who and when does it make sense to go for a UKGC license?
Q. For which company profile is the UK license relevant?
Answer (UKGC): For brands ready for full-scale compliance and work in a mature ecosystem: strict Responsible Gambling standards, game affordability checks, strict advertising rules and close supervision of technical components. If strategy is a long-term brand in a regulated market, then it is the right choice.
2) What roles and types of licenses exist?
Q: How are permissions structured?
Answer: For B2C, remote gambling/betting operators; for B2B - suppliers, test houses, hosting of critical components (depending on the role). Within the company, key functions (compliance, AML, RG, security) are identified that are personally responsible.
3) Basic documents and "framework" of requirements
Question: What to rely on when preparing?
Answer: To LCCP and RTS. Plus - AML/KYC policies, affordability/Source of Funds/Source of Wealth procedures, RG ladder of interventions, incident management, information security, outsourcing management, advertising standards and affiliate control.
4) Fit & Proper and owner verification
Q: What does "fit & proper" verification involve?
Answer: Evaluation of beneficiaries and managers: reputation, sources of funds, experience, transparency of the structure, absence of conflicts and ability to manage risks.
5) Age/KYC and verification rate
Q: What are the expectations for age and personal verification?
Answer: Checking the age before admission to the game; KYC - risk-oriented, proportional to the client profile. Reliable data providers, risk-reassessment logic, and error-free solution tracing are required.
6) Affordability, SoF/SoW
Question: What is most important in checking the availability of the game and the source of funds?
Answer: Clear triggers (threshold amounts/patterns), evidence base (SoF/SoW), documented decision logic and non-changeability of marketing procedures: player protection always prioritizes conversion.
7) Responsible Gambling: The "ladder" of interventions
Q: What are the minimum expectations for RG?
Answer: Deposit/loss/time limits, timeouts and self-exclusion, "reality checks," early detection of risk patterns, human reassessment after automatic measures, reporting on harm reduction KPI. Any promotional activity must take into account RG signals.
8) Advertising, bonuses and affiliates
Question: Where do violations most often occur?
Answer: Misleading offers, insufficiently visible conditions, targeting of minors/vulnerable groups, unmanaged affiliates. The operator is obliged to maintain a register of partners, approve creatives, document traffic audits and quickly stop violations.
9) Technical standards (RTS) and test houses
Question: What is checked technically?
Answer: RNG/game mathematics, correct calculations and display, log integrity, API reliability, key protection, environment separation, release control, telemetry storage and audit. Testing - through approved laboratories; reporting and regression tests are required.
10) RTP, game design and "intensive" mechanics
Q: Are there requirements for RTP filing and mechanics?
Answer: RTP must be transparent and accessible to the player. Mechanics that increase intensity (fast cycles, autospins without restrictions, aggressive visual stimuli) are viewed through the prism of harm reduction and UX checks.
11) Telemetry, logs and incidents
Q: How deep is logging expected?
Answer: Full tracing of bets/winnings/balances, changes in limits and statuses, KYC/RG/AML events, admin accesses, releases and incidents. The integrity of the logs, retention, SLA for alerts and documented reaction are important.
12) Payments and returns
Question: What are the expectations for the checkout?
Answer: Transparent commissions and ETA, reliable methods, control of lead cancellations, protection against card testing and anomalies, targeted step-up checks, minimizing friction for bona fide customers.
13) Crypto payments and innovation
Q: Are digital assets possible?
Answer: Only within the law and with full AML/sanctions screening, control of "fresh" addresses and clear on/off-ramp policies. RG rules apply equally to all methods.
14) Outsourcing and critical suppliers
Q: Can the key components be taken out?
Answer: Yes, but the responsibility remains with the operator. We need contracts with SLA, audit rights, an incident plan, regular recertification. Lack of control over providers is a common reason for sanctions.
15) Sanctions, fines, license revocation
Question: What is punished most often?
Answer: RG/affordability/AML system failures, misleading advertising, weak affiliate control, log/balance integrity problems, repeated incidents without correcting the causes.
16) Timeline and how to speed up the process
Question: What speeds up the passage?
Answer: Ready-made and applied policies (not "folders for folders"), architecture diagrams, pilot monitoring and logs, certain key functions, proven contracts with suppliers and a crystal clear financial model.
17) Life after launch: "constant compliance"
Q: What makes a mature licensee different?
Answer: Culture of continuous compliance: internal audits, RG/AML/IB metrics and alerts, incident retrospectives, policy updates, front line training, transparent reporting and active outsourcing management.
Practice: checklists and roadmaps
UKGC Bid Preparation Checklist
- Transparent ownership structure, key function profiles (compliance/AML/RG/IB).
- Policies and Procedures: LCCP Alination, AML/KYC, Affordability/SoF/SoW, RG Ladder, Incidents, Outsourcing, Security, Advertising/Affiliates.
- Architecture diagrams, access control, media partitioning, release log, monitoring, and logs.
- Critical supplier contracts: SLAs, audit rights, incident plan and risk reassessment.
- Registries: complaints, incidents, releases, affiliates; personnel training plan.
- Financial plan: reserves, stress scenarios, reporting on GGR and balance sheet transactions.
- Metrics showcases: RG/AML indicators, SLO critical flow, advertising quality.
90-day roadmap for new applicant
Weeks 1-3: gap analysis by LCCP/RTS, key function assignment, draft policies, basic architecture and logging.
Weeks 4-6: AML/KYC/RG/affordability finalization, provider contracts, pilot monitoring, affiliate registry, and advertising rules.
Weeks 7-9: dry audit (internal/external), BCP/DRP stress test, incident procedures, closure of comments.
Weeks 10-12: submission of application, response to UKGC requests, preparation for technical checks and operational inspections.
Common mistakes and how to avoid them
"Off the shelf" policies. Documents should reflect real processes, data and roles.
Underestimation of affordability/SoF/SoW. Without clear triggers and evidence base - a direct path to sanctions.
Weak affiliate control. There is no register, approval of creatives and quick reaction to violations.
Infrastructure without tracing. There are no holistic logs, release control and admin access auditing.
Collision promo and RG. Marketing should not "interrupt" risk signals.
Lack of front-line training. First-line errors are costly.
The UKGC is a "top league" of compliance: transparent rules, a high standard of consumer protection and strict control of technology. Successful companies come with real processes, mature architecture, reporting discipline and a responsible gambling culture. This approach gives access to one of the most valuable markets and builds long-term trust - with players, partners and the regulator.