Gambling Act Application

Need to satisfy the Gambling Commission, a local licensing authority — or both?

Complete Licensing provides practical, independent support with gambling licence applications, changes to existing permissions, regulatory engagement and hearing preparation.

We also help existing operators find compliance weaknesses before they become regulatory problems, and provide clearly scoped technical and expert support to solicitors.

Discuss your gambling licensing matterSolicitors: discuss an expert instruction

Complete Licensing is an independent licensing consultancy. We are not a firm of solicitors and are not authorised or regulated by the Solicitors Regulation Authority.

What do you need help with?

I am starting or changing a gambling business

We can help identify the licences and permissions that may apply, organise the supporting evidence and manage the practical application process with the Gambling Commission or relevant local licensing authority.

Plan my application

I already operate licensed premises

We can independently stress-test your premises, policies, records and everyday working practices before an inspection, compliance assessment or licence review exposes a weakness.

Arrange a compliance review

I am a solicitor or professional adviser

We provide technical consultants, consulting experts and independent expert witnesses for gambling licensing and premises-compliance matters. Your firm retains the legal strategy, conduct of the matter and client relationship.

Discuss a professional instruction

Get the regulatory route right before you apply

The Gambling Act 2005 licensing system involves different permissions and decision-makers. In Great Britain:

• The Gambling Commission issues operating and personal licences.
• Local licensing authorities deal with premises licences and a range of permits, registrations and notices.
• A land-based gambling business may require permissions from both.
• A provisional statement may be appropriate where premises are being built, substantially altered or have not yet been acquired.

The correct route depends on the activity, business structure, individuals involved and proposed premises. Establishing that route early can prevent missing evidence, duplicated work and avoidable delay.

If an application has already been submitted, we can review regulator questions, representations, objections and impending deadlines.

Gambling licence application support

A strong application is more than a completed form. It should demonstrate that the proposed business, people, funding, policies and practical controls are capable of meeting the relevant licensing requirements.

Depending on the instruction, our support can include:

• An initial licensing-route and application-readiness assessment.
• Gambling Commission operating licence applications and variations.
• Personal licence application support where applicable.
• Premises licence applications, variations, transfers and provisional statements.
• Relevant permits, registrations and notices.
• Review of ownership, management, financial and operational evidence.
• Preparation or review of business plans, policies, procedures and risk assessments.
• Premises-specific local area risk assessments.
• Review of the licensing authority’s statement of policy and local concerns.
• Coordination of plans, notices and responsible-authority notifications.
• Document and evidence gap analysis before submission.
• Responses to questions and information requests from licensing officers or Gambling Commission caseworkers.
• Preparation of applicants, managers and witnesses for meetings or hearings.
• Support with implementing application commitments after a licence is granted.

We agree the scope at the outset so that everyone understands what Complete Licensing will handle, what remains the applicant’s responsibility and when another professional adviser should be involved.

Representation before licensing authorities and the Gambling Commission

Even a carefully prepared application may attract questions, representations or a hearing.

For Gambling Act premises-licence matters in England and Wales, Complete Licensing can attend and represent clients at local-authority licensing hearings. For other procedures and jurisdictions, the permitted role is confirmed before accepting the instruction.

We can also support clients through Gambling Commission applications, information requests, compliance assessments, written representations, meetings and hearings. Where the applicable procedure permits, we can present the operational and regulatory case before a Director or Regulatory Panel.

Our work can include:

• Analysing the concerns raised.
• Identifying the evidence needed to answer them.
• Preparing written representations and supporting material.
• Preparing witnesses for likely questions.
• Discussing practical safeguards or proposed conditions.
• Presenting the licensing and operational case.
• Coordinating remedial and follow-up work.

Where solicitors or counsel are instructed, we work alongside them under an agreed division of responsibilities. They retain control of legal advice, legal strategy, litigation and any advocacy requiring regulated legal services. We provide the practical licensing, operational and evidential input.

For an appeal, judicial review, criminal matter, contested point of law or court or tribunal proceeding, clients should obtain advice from an appropriately authorised solicitor or counsel. Complete Licensing can support that legal team with specialist evidence and sector expertise.

Independent gambling premises compliance reviews

Would your premises stand up to scrutiny tomorrow?

Policies can look convincing on paper while everyday practice tells a different story.

Our independent compliance review — or regulatory-readiness stress test — examines whether the premises, people, systems and records support what the licences and policies say should happen.

The aim is to identify potential weaknesses early, give management an evidence-based view of its exposure and provide practical actions that can be implemented and demonstrated.

Depending on the operation and agreed scope, we can examine:

• Operating and premises licence conditions.
• Applicable Licence Conditions and Codes of Practice.
• Local area risk assessments and premises-specific controls.
• Safer-gambling and customer-interaction procedures.
• Age-verification arrangements.
• Protection of children and vulnerable people.
• Self-exclusion procedures.
• Relevant anti-money-laundering controls.
• Staff knowledge, escalation routes and management oversight.
• Incident, refusal, interaction and training records.
• Signage, supervision, CCTV and premises layout.
• Key-event reporting, regulatory returns and licence administration.
• Policies compared with what happens in practice.
• Previous inspection findings, complaints and regulator correspondence.
• Changes in ownership, management or operation that may require action.

What you receive

The scope and testing method are agreed before work begins. Following the review, you receive:

• Clear, evidence-based findings.
• Prioritised risks and areas requiring attention.
• Practical recommendations.
• A management debrief.
• An optional remedial action plan.
• An optional follow-up review to test whether improvements have been embedded.

A Complete Licensing compliance review is an independent consultancy assessment. It is not an inspection, certification or approval by the Gambling Commission or a local authority. It cannot guarantee that regulatory action will not occur, and responsibility for compliance remains with the licensee.

Arrange a premises compliance stress test

Specialist support for solicitors

Gambling licensing expertise beside your legal team — not instead of it

Complete Licensing supports solicitors who require focused operational, regulatory or evidential expertise in a gambling-related matter.

We respect the instructing firm’s retainer and relationship with its client. Your firm retains conduct of the matter, legal advice, privilege decisions and legal strategy. We work within the agreed scope and reporting arrangements and do not expand our role or approach your client directly without prior agreement.

Three clearly separated roles

Consulting or technical expert

Confidential technical analysis for the legal team, including document review, premises assessment, evidential gaps, potential lines of enquiry and practical regulatory context.

Independent expert witness

Objective opinion within the appointed expert’s evidenced experience. Where CPR Part 35 or another procedural framework applies, the instruction and report will be scoped accordingly. The expert’s duty to the court or tribunal takes priority over the interests of the instructing party, and the expert does not act as an advocate.

Licensing consultant or representative

Client-facing application, compliance, regulator-engagement and administrative-hearing support.

The chosen role is recorded in the engagement terms. Complete Licensing will not act as both a partisan representative and an independent expert in the same matter where doing so could compromise — or appear to compromise — the expert’s independence.

We can assist legal teams with

• Early identification and scoping of gambling licensing issues.
• Independent desktop reviews and premises inspections.
• Review of licences, conditions, policies, risk assessments and operating records.
• Review of regulator correspondence and regulatory chronologies.
• Testing whether documented procedures were practical and followed.
• Identification of evidential gaps and further technical questions.
• Independent opinion within the expert’s field.
• Reports prepared to the agreed procedural requirements.
• Conferences with solicitors, clients and other experts.
• Expert meetings and joint statements where required.
• Preparation for licensing authority or Gambling Commission proceedings.
• Oral expert evidence where instructed and permitted.
• Technical support without displacing the legal team.

Expert-witness instructions are accepted only after checking the proposed expert’s relevant expertise, availability, independence, conflicts position, procedural requirements and the precise questions to be addressed.

Request an expert’s CV and availabilityDiscuss a technical consultancy instruction

How we work

1. Tell us the objective

Explain the proposed activity, permissions already held, premises involved, regulator correspondence and any relevant submission or hearing deadline.

2. We define the role and scope

We identify the likely regulatory route, required work and any areas that should be handled by a solicitor or another specialist. Deliverables, responsibilities, communication arrangements and fees are agreed before substantive work begins.

3. We prepare, examine or test

For an application, we coordinate evidence and supporting documents. For a compliance review, we test written controls against operational reality. For a solicitor-led instruction, we work to the agreed questions and reporting protocol.

4. We support the next stage

That may involve coordinating a submission, answering questions, attending a hearing, producing an expert report or helping management implement and evidence corrective action.

Why work with Complete Licensing?

Practical experience

Our consultants draw on operational, regulatory and enforcement backgrounds. This helps us examine both what a decision-maker expects and what can work in a real business.

Evidence rather than generic paperwork

Policies and risk assessments should describe the actual operation. We focus on whether the documents, controls, people and evidence fit together.

Constructive independent challenge

A useful compliance review should identify uncomfortable gaps as well as confirm what is working. Clear findings allow management to act before weaknesses become larger problems.

Support from application to operation

Our involvement does not have to end when an application is submitted or granted. We can support implementation, premises readiness and ongoing improvement.

A solicitor-friendly approach

We add sector, premises and evidential depth while respecting the solicitor’s legal role, reporting arrangements and client relationship.

Clear professional boundaries

You will know whether we are acting as licensing consultants, representatives, technical advisers or independent experts — and when regulated legal advice should be obtained.

Questions and answers

Before you get in touch

Tell us:

• What gambling activity you provide or plan to provide.
• Whether it is remote, premises-based or both.
• What licences or permissions you already hold.
• Which authority or regulator is involved.
• Whether there is an application, inspection or hearing deadline.
• Whether you are an operator, solicitor or other professional adviser.

We will identify the most useful next step: application support, a premises compliance review, regulator or hearing support, or a carefully scoped technical or expert instruction.

Arrange an initial discussionCall 020 7222 2345

Complete Licensing Ltd is an independent licensing consultancy, not a firm of solicitors. We are not authorised or regulated by the Solicitors Regulation Authority or another approved legal-services regulator and do not provide reserved legal services.

Where legal advice, litigation, an appeal or court or tribunal representation is required, clients should instruct an appropriately authorised solicitor or counsel. Complete Licensing can work alongside that legal team by providing licensing evidence, operational analysis and specialist expertise.

Any attendance or representation before a licensing authority or the Gambling Commission is subject to the applicable law, procedure and directions of the decision-maker. No licensing or regulatory outcome can be guaranteed. The applicant or licensee remains responsible for the accuracy of submissions and ongoing compliance.