
In a powerful submission made on Monday 30 March, and which drew on economic impact research commissioned from Cebr, Bacta has argued against an increase in Gambling Commission fees.
The submission argued that land-based operators are facing significant and sustained cost pressures, including sharp increases in rent, business rates and employment costs, factors which are compounded by an inability to pass on or share those increases with customers.
Bacta pointed out the 2021 increases were justified by government on the basis that additional regulatory capacity would be required to implement changes arising from the Gambling Act Review and the subsequent White Paper. However, the central White Paper reform impacting the land-based sector, namely the proposed change to the 80/20 machine ratio to 2:1, has yet to be implemented.
Bacta contrasted that with the circumstances facing the casino sector which it said has benefitted from the White Paper with reforms already enacted through legislation.
Bacta President Joseph Cullis confirmed: “Against this backdrop, it is difficult to reconcile the case for further fee increases with the reality that the primary reform affecting our sector, cited as part of the original justification for higher fees, remains outstanding.
“The proposed ratio change was widely recognised during the Gambling Act Review as a modest modernisation measure. It would not increase the total number of machines permitted in AGCs, but would instead provide operators with greater flexibility within existing entitlements.
“The continued absence of this reform is therefore a material contextual factor when considering any further increase in regulatory fees for the sector.”
Drawing a comparison with the online sector, Joseph Cullis argued: “Unlike remote operators, land-based businesses operate from fixed premises and cannot flex pricing freely due to stake and prize limits which are set in law. As a result, increases in regulatory costs cannot easily be absorbed or passed on to consumers.
“This challenge is compounded by the fact that stake and prize limits have not kept pace with inflation. Category C stakes were last reviewed in 2009 and prizes in 2014, while Category B3 stakes were last reviewed in 2007 and prizes in 2011. This creates a structural imbalance whereby operators are unable to increase revenue in line with inflation, while regulatory and operating costs continue to rise.”
Cullis added: “Against this backdrop, significant changes in Gambling Commission fees risk introducing additional fixed regulatory costs into already compressed operating margins, particularly for SMEs which have limited capacity to absorb further overhead.”
Highlighting what Bacta described as the problem of large step increases, the submission argued that it would be more proportionate to adopt a triennial review cycle with capped uplifts or an annual inflation-linked adjustment mechanism.
Joseph Cullis concluded: “If regulatory costs require periodic adjustment to reflect changing economic conditions, it is reasonable to apply the same principle across the wider regulatory framework.
“Bacta therefore recommends that licence fees, alongside key regulatory parameters such as stake and prize limits, should be subject to a regular triennial review cycle.
“Such an approach would promote stability, transparency and predictability for both regulators and operators. Regular, incremental adjustments would avoid the need for infrequent step changes in fees while ensuring that the regulatory framework evolves in line with economic realities affecting both the regulator and the regulated sector.”
Bacta confirmed that it would welcome continued engagement with DCMS and the Gambling Commission to ensure that regulatory funding arrangements protect both consumer standards and the long-term viability of land-based operators in the process supporting high streets and coastal economies across Great Britain.
2 April 2026
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