IoL response to DCMS consultation on Category D machines and bingo licensing

The Institute of Licensing (IoL) has submitted its response to the Department for Culture, Media and Sport’s consultation on Category D gaming machines and proposed changes to the regulation of licensed bingo premises. The organisation focuses primarily on regulatory implications rather than commercial considerations such as stakes, prizes or gross gambling yield.

Position on Category D machine proposals

The IoL does not support the creation of additional sub‑categories within Category D machines, including proposals for a new “slot‑style” non‑money category or a unified “pusher” category. It notes that five sub‑categories already exist and considers further subdivision unnecessary without clear evidence of harm. The organisation highlights the potential for increased administrative and enforcement burdens for licensing authorities.

The IoL also states that it has no comment on proposed changes to stake and prize limits, as these are commercial matters outside its remit.

Age restrictions for ‘cash‑out’ Category D slot‑style machines

The IoL raises several considerations regarding the Government’s proposal to introduce a statutory age restriction for “cash‑out” Category D slot‑style machines. It notes that:

• A voluntary industry agreement already restricts under‑18 play on these machines.
• No evidence has been presented to show that the voluntary approach is ineffective.
• Survey data cited in the consultation does not specifically identify reel‑based Category D machines as a source of harm.

The organisation also highlights potential inconsistencies, as the proposed offence would apply only to gambling‑licensed premises and not to alcohol‑licensed venues, unlicensed FECs or members’ clubs. It suggests this could create uneven regulatory expectations and may discourage some unlicensed FECs from offering reel‑type machines.

Views on bingo premises regulation

The IoL does not support proposals requiring licensed bingo premises to designate a specific “bingo area” or to allocate a minimum proportion of floor space to bingo activity. It notes that existing Licence Conditions and Codes of Practice (LCCP) already require premises to be recognisable as bingo venues and to offer substantive bingo facilities.

The organisation warns that introducing minimum floor‑space requirements, minimum distances between bingo areas and gaming machines, or minimum numbers of bingo positions could reintroduce complex compliance issues similar to those experienced in the early implementation of the Gambling Act 2005.

Tablet‑based gaming content

The IoL supports allowing all currently permitted gaming machine categories (B3, B4, C and D) to be available on tablets offering electronic bingo within the bingo area. It notes that no evidence has been presented to justify restricting tablet content further.

Overall position

The IoL’s response emphasises the need for clarity, proportionality and effective enforcement of existing requirements rather than the introduction of new regulatory structures. It concludes that several of the proposed changes may increase complexity for operators and licensing authorities without clear evidence of associated benefits.