1 Main Stage Ticket Bingo Game
1.1 Definition of a Bingo Game
The Gambling Act 2005 does not have a statutory definition but describes ‘bingo’ to mean ‘any version of the game, irrespective of by what name it is described’.
Main Stage bingo is usually the primary game (or games) played in any bingo session, involving physical (paper) and/or virtual (electronic) tickets which are typically purchased before the bingo session starts.
The Gambling Commission considers there are three fundamental principles of bingo. These principles are:
a) Bingo must be played as an equal chance game
b) Bingo must involve a degree of participation; and
c) Bingo games must have a clearly defined end point.
1.1.1 Bingo must be played as an equal chance game
In order for a game to be classed as ‘bingo’ it must meet the Gambling Act’s definition (in section 8) of ‘equal chance gaming’ (as opposed to casino gaming). Thus, it:
a) must not involve playing or staking against a bank; and
b) must be a game in which the chances are equally favourable to all participants in the sense that each ticket or chance has the same probability of success as any other.
The Commission has no objection to players in bingo being able to select some, or indeed all, of their numbers provided there is a mechanism to ensure that each player nevertheless has a unique set of numbers and the game therefore remains equal chance. The Commission also considers that fixed odds bingo games are acceptable provided they are structured to ensure there is no banker’s interest.
1.1.2 Bingo must involve a degree of participation
To distinguish a bingo game from a straight lottery, a player must be required to participate in order to be successful. Participation could, and traditionally does, take the form of human interaction with the game, i.e.: players actively marking their cards and/or claiming to have won. Alternatively, as is often the case in modern bingo formats, especially when played on-line, by means of bingo machines or hand-held devices, technology can be used to act as the participant’s agent in playing out the game which the player has initiated. In this way participation can be made up of a combination of activity taking place both within the mechanic of the game and by the player’s own actions.
Bingo games where the winning numbers are pre-selected are acceptable, provided that those numbers are subsequently called or displayed.
1.1.3 Bingo must have a clearly defined end point
A fundamental element of a game of bingo, as with any game, is that it needs to end at a predetermined designated point or time. This end point needs to be appropriate, realistic and clearly communicated to players. The period within which a player is able to claim a prize should be factored into the timeframe of the game; determining who has won is part of the game.
1.1.4 Key Characteristics of Bingo
The Gambling Commission has published a document entitled ‘Key characteristics of bingo’, which had particular relevance to the characteristics of bingo and how it is played on bingo machines. An excerpt from that document is detailed below:
a) Players’ payments must be divided between stakes and participation fees, although they may consist entirely of stake or entirely of participation fee.
b) The way that division is made must be transparent to the player and in particular there must be a notice displayed showing participation fees in a way that makes it readily accessible to players. Any stakes must be returned to players, either in the particular game or in a subsequent one.
c) Each game must be played to a single set of numbers, or symbols; drawing a second set starts a new game.
d) Any game formats must clearly be presented as offering the player the opportunity to participate in a game of bingo. This includes numbers (or symbols) being marked off and the game having the appearance of a game of bingo (rather than a gaming machine).
e) Any ‘added prize money’ stated to be available in a game, once offered (and unless the offer is specifically limited in time), must remain available until won in that or subsequent games i.e.: by way of rollover; the operator cannot rescind on the advertised prize. Prizes clearly advertised as being offered only for a limited period can be claimed back if they are not won. All prizes offered in each game must be transparent to the player.
f) Games may operate with a single player, provided there is a meaningful opportunity for other players to participate in the same game.
g) The game must comply with the requirements of the Gambling Act 2005 and must be capable of audit, where appropriate, to demonstrate legal compliance. Such audit data will demonstrate for example how players’ payments are split between stakes and participation fees and that all stakes are returned to the players, either in that game or subsequent games.
1.2 Linked Ticket Bingo
There are four types of licence condition that may be attached to operating licences, under the Gam
The requirements for bingo tickets are as follows:
a) Every ticket used in a game of bingo must consist of a unique set of letters, numbers or symbols. This applies whether the tickets in play are physical (paper), virtual (electronic), a mix of the two, or any other representations of bingo tickets and applies whether the game takes place in one or at multiple venues.
b) Each ticket in play (whether paper, electronic or other) must have a unique reference number or code associated with it, which can be used for ticket verification purposes.
1.3 The Bingo and Casino Equipment Technical Requirements July 2008
The Gambling Commission issue codes of practice under section 24 of the Gambling Act 2005, about the manner in which facilities for gambling are provided to ensure that the three licensing obThis is issued by the Gambling Commission and sets out specific requirements relevant to the playing of Main Stage Ticket Bingo (ticket and electronic virtual tickets). This document was effective from 31st August 2008 and still applies. A link to the most recent version is attached at the end of this section.
1.4 Prize Information Board
The prize information board together with any associated boards (if needed) must display the information listed below at all times during the game session (scrolling displays are permitted); and the vast majority of players must have a clear and unobstructed view of the board(s) during play, unless they can clearly view the same information, in real time, by other means.
Information to be displayed for main stage games:
a) opening and closing number of tickets. Paper and virtual (electronic) tickets must be displayed separately. There must be provision to display both sets of numbers from any split series permutations.
b) total number of tickets in the game (whether paper, virtual or otherwise)
c) total number of tickets not in the game, e.g. spoiled or unsold
d) total prize fund (this may be subdivided into its constituent parts if required)
e) details of allocation of prizes, e.g. one line, two lines, full house, value, etc.
f) information to allow players to identify the ticket in play, e.g. book colour, page. If equipment produced before 31 August 2008 does not have the capability to display this information, the player must be given the information by other means (e.g. orally).
g) all previously called numbers within the game
h) last number called
1.5 Checking a Claim
During claim checking, a representation of the ticket being checked, including its relevant serial or permutation numbers must be shown, together with its status (valid, not valid or already checked).
Details of winning claims must be displayed so that the information is available to all players simultaneously.
Where a manual check of a ticket or an EBT is required due to equipment failure, it will be necessary to check the ticket in full view of an independent customer in order to verify the claim. Where numbers are not legible (and customers are required to provide this within the club rules) the claim may be refused.
1.6 Bingo Ticket Sales Records
Keep the following sales records for each session:
a) all opening and closing serial numbers, including those of main bingo books, virtual and ancillary bingo books
b) costs of each bingo ticket or book and total amount staked
c) participation fee charges and totals per book
d) allocation of stake money in prizes for each game, together with a record of any prize (cash or otherwise) donated by the proprietor
e) sales records should be kept for a minimum of 6 months or as prescribed by your company’s procedure.
1.7 Unsold Tickets
Have damaged or unsold tickets available for production to members and available for inspection by officials of the Gambling Commission and HM Revenue and Customs at a later date if required. Good practice is that these should be retained on site for a minimum of 14 days or as dictated by your company procedure.
1.8 Can I Destroy Unused Bingo Cards?
Yes, providing you keep a record that provides an adequate audit trail. You can also give unwanted cards to charities, hospitals, etc. again providing you keep full details in your records for HM Revenue & Customs officers to check, as appropriate. Care should be taken that any slogan or advertising is within ASA codes of practice. A company name only on the tickets would normally be acceptable.
1.9 Perm Size
Operators should take great care to ensure that their perm size is sufficient to prevent the possibility of selling duplicate tickets to customers playing the same game. If, however, due to circumstances beyond the reasonable control of the operator, a situation arises whereby duplicate tickets win a game of bingo, then it is suggested that the prize money should be divided equally among the claimants as in the situation where there are traditional multiple winners (as opposed to duplicating the prize). Operators should have a very clear policy on how to avoid this situation, including written procedures to ensure that bingo ticket perm size is large enough to prevent duplicate tickets being in play during the same game and to ensure that bingo tickets are issued and sold in strict sequential order. The operator’s Terms & Conditions should state the procedures to be that will be followed by the operator in the event of this situation arising.
1.10 Duplicate Tickets Additional Guidance
The Bingo Association has discussed with the Gambling Commission the rules of play that relate to duplicate tickets. The Gambling Commission had no issue with a change of game rules to allow the sharing of a prize in the event that the holders of duplicate tickets had won a prize. Any prize won on those tickets would be shared equally between all such holders. This would be subject to the condition that duplicate tickets were present during the game due to a mistake and that they had not been deliberately placed there. This discussion took place following the introduction of the Gambling Act 2005 and the effect of changes which removed prize limits and allowed the creation of rollover games. Under earlier game rules, this could have meant operators paying out multiples of the full prize if there had been duplicate tickets present in a game.
If you want to rely on this change of rule, you are advised to ensure that you have changed your rules of play that are displayed to all players. Example wording could be:
“If more than one player claims a prize, it will be divided equally between all the winners. In the event of the prize consisting in whole or part of a non-monetary prize this shall be carried forward to
another separate game or be the subject of a playoff or be substituted by a cash or a non-monetary
alternative at the manager’s discretion. In the event of a mechanical malfunction, however caused, or of duplication or incorrect game tickets being issued, either paper or electronic, resulting in multiple or duplicate claims, all claimants will share the declared prize equally.”
HM Revenue and Customs require that all bingo records, documents and accounts (including purchase invoices relating to prizes) must be kept for at least two years. For VAT or corporate/taxation purposes these records may need to be kept for a longer time. They should be kept at your main business address. See Bingo Duty Notice 457 (latest edition) issued by HM Revenue and Customs. For the assistance of the Gambling Commission, proprietors should, if possible, maintain copies of bingo records in each club for at least six months and up to two years.