4 Information Requirements
4.1 Introduction
The requirement for information from Bingo Operators and Licensees falls in to two categories:
- The Bingo Annual Regulatory Return and;
- Reportable Events
In both cases the recipient of the information is The Gambling Commission. The Commission collects a range of information from licence holders within the gambling industry in order to monitor compliance with gambling legislation, regulations and the licence conditions and codes of practice. This information enhances their understanding of the industry.
The following sections summarise the information that is required.
4.2 The Bingo Annual Regulatory Return
This information is provided by licenced bingo operators, via the completion of a ‘Bingo Annual Regulatory Return’.
The regulatory returns can be completed through the online regulatory returns system, available on the Gambling Commission website. A link is available within the Resource Centre.
A return needs to be completed for each type of activity for which a licence is held. For example, if an individual holds a licence authorising bingo and adult gaming centre, two returns will need to be completed and submitted, one for each activity.
If a licence holder has ceased trading in any particular activity, or has not yet started to trade, but still holds a valid licence at the time a return is due, a NIL return must be submitted.
The regulatory framework for gambling places the onus for securing the licensing objectives with licensed operators. As part of the Commission’s compliance programme, operators may often be asked to provide evidence that demonstrates how they ensure that the policies and procedures they have put in place to secure the licensing objectives are effective. This may include, as appropriate, information that is not collected through regulatory returns. In practice the data required for the regulatory returns is likely to be a subset of the data needed for operational purposes.
Some data items are snapshots at a particular date rather than aggregations of data throughout the period. In completing these data items, operators should report information as at the latest convenient or appropriate date within the period to which it relates. For example, for staff head count data, this might most easily be calculated at the date of the last pay run in the reporting period.
Licence holders who are required to submit annual regulatory returns should complete and submit their regulatory returns within 42 days of their year end. You may choose to complete regulatory returns according to your business year.
Licence holders who are required to submit quarterly regulatory returns should complete and submit their regulatory returns within 28 days of their period end.
4.3 Licence Conditions – General and Regulatory Returns and Other Reportable Events
It is a licensing condition to provide the Gambling Commission with General and Regulatory returns, this is detailed within the LCCP at Licence Condition 15.3.1
4.4 The Gambling (Licensing & AdInformation Required for the Bingo Annual Regulatory Return
The ‘Bingo Annual Regulatory Return’ requires a variety of information covering such areas as Contact Information; Workforce Information; Operational Information; Details relating to Disputes; Gaming Machine and Electronic Bingo Terminal information; Financial information; Self Exclusion numbers and much more. At the time of writing (May 2020) the Gambling Commission are consulting regarding changes to the information required within these Annual Regulatory Returns.
4.5 Reporting Key Events
A key event is an event that could have a significant impact on the nature or structure of a licensee’s business. Licensees must notify the Commission, or ensure the Commission is notified, in such form or manner as the Commission may from time to time specify, of the occurrence of any of the following key events as soon as reasonably practicable and in any event within five working days of the licensee becoming aware of the event’s occurrence.
Key events fall in to 6 categories and the specific licence conditions will be found in the LCCP at 15.2.1 and 15.2.2.
4.6 Ordinary Code Provision
The Gambling Commission also provide an ordinary code provision for Information Requirements:
Ordinary code provision 8.1.1
Information requirements
- As stated earlier in this code, the Commission expects licensees to work with the Commission in an open and cooperative way and to inform the Commission of any matters that the Commission would reasonably need to be aware of in exercising its regulatory functions. These include in particular matters that will have a material impact on the licensee’s business or on the licensee’s ability to conduct licensed activities compliantly and consistently with the licensing objectives.
- Thus, licensees should notify the Commission, or ensure that the Commission is notified, as soon as reasonably practicable and in such form and manner as the Commission may from time to time specify(1), of any matters which in their view could have a material impact on their business or affect compliance. The Commission would, in particular, expect to be notified of the occurrence of any of the following events in so far as not already notified in accordance with the conditions attached to the licensee’s licence(2):
a) any material change in the licensee’s structure or the operation of its business
b) any material change in managerial responsibilities or governance arrangements
c) any report from an internal or external auditor expressing, or giving rise to, concerns about material shortcomings in the management control or oversight of any aspect of the licensee’s business related to the provision of gambling facilities.
(1) These matters can be reported securely online at the Commission’s website through the eServices system www.gamblingcommission.gov.uk
Events which must be reported, because the Commission considers them likely to have a material impact on the nature or structure of a licensee’s business, are set out in general licence condition 15.2.1
4.7 Summary of Information
The ‘Bingo Annual Regulatory Return’ requires a variety of information covering such areas as Contact Information;
In Summary information requirements may cover several operational and compliance areas including:
a) Gambling facilities
b) Admissions
c) Frequency
d) Staff levels
e) Policies and procedures on problem gambling
f) Interaction and self-exclusion
g) Operational Information
h) Conclusions from any ADR process
i) Any matters the Commission would reasonably need to be aware of that impact on the licensees business and their compliance responsibilities such as company structure or change in management responsibilities
j) Operator Status
k) Relevant persons and positions
l) Financial Information
m) Financial events
n) Legal or regulatory proceedings or reports