What part of an online casino can a new company not hire from someone else? Nearly everything a customer sees is available on contract: the games, the account software, the payment options and even a place under another operator’s licence. The exception is responsibility. Guidance from the Gambling Commission says responsibility for the compliance of every operating gambling website “sits with the licence holder and cannot be transferred to any other party”, white-labelled sites included.
That answer splits the industry’s barriers to entry into two kinds. A newcomer can rent what the customer sees, because a supplier or a licensed operator has already cleared the barrier behind each part. The rest it must earn, and no contract moves them: the regulator’s view of the people in charge, money-laundering controls run in its own name, a compliance history, and customers won under the current rules.
The split shows up in two places: in how fast the roll call of new casino brands grows, and in what happens to a brand built from rented parts when the business it rents from loses its licence. Both turn on who holds the licence.
The supplier’s licence comes bundled with the product
Start with the parts a player touches. No casino has to build its own games, account system or the engine that settles each bet, and in Great Britain not just anyone may build them. Under the Gambling Act 2005 it is an offence to make, supply, install or adapt gambling software in the course of a business without an operating licence, and licence conditions oblige remote casinos to take that software only from holders of a Commission software licence.
That rule is what makes renting possible. The regulator’s advice on gambling software says the last company in a supply chain needs a software licence simply because it signs a supply contract with a licensed operator, even if it builds, adapts and installs nothing itself. The supplier has faced the regulator before any casino signs with it, so a newcomer that buys from it hires a barrier somebody else has already cleared.
The arrangement stops short of the operating licence. A software licence covers making and supplying the product, not offering gambling to the public, and the same advice says a software firm that also hosts a games platform needs a remote casino operating licence as well, because it then answers for the fairness of the gambling. Hiring the technology leaves a newcomer with the question it started with: whose licence will its customers play under?
White labels lend out the operating licence too
Platform suppliers also sell what the trade usually calls turnkey deals, in which the supplier provides the technology to a casino that holds a licence of its own. A white label goes one step further. A licensed operator provides the gambling under its own licence, while a partner business supplies the brand and often publishes the promotions.
The Commission’s compliance and enforcement report for 2019 to 2020, published in November 2020, put the number of white-label partners at more than 700. Its white-label chapter, which current guidance on third parties still points licensees to, voiced a concern that unlicensed operators who might fail the initial suitability checks were looking to use white labels to offer gambling in Great Britain. A partner brand does not hold the licence its customers play under, so the scrutiny it faces comes from the licensee’s due diligence rather than the licensing process.
This is why the roll call of new brands lengthens faster than the list of businesses licensed to run them. Every white-label launch adds a brand, but not a licence holder. Writing for UK readers about the best new casino sites, gambling.com notes that new casinos do not always run on a new platform, since a white-label brand can share software, payment methods and customer support with other brands and may even carry the same UKGC licence number.
That shared number is where the rented barrier shows. However different their logos look, the brands under it rest on one company’s licence application, and that company answers to the Commission for each of them.
Suitability is judged person by person
A newcomer that wants an operating licence of its own faces a test no supplier can sit for it. Section 70 of the Gambling Act 2005 requires the Commission to form an opinion of an applicant’s suitability, and lets it weigh the integrity, competence and financial circumstances of the applicant or of anyone relevant to the application. The evidence it may rely on includes interviews, references and information from other people, requested or not.
The Commission’s guide to personal management licences tells applicants to seek them for people in qualifying management positions at the same time as the operating licence, and says nobody should take on those responsibilities until the regulator issues the personal licence. Each applicant gives every address from the last five years and faces criminality checks, including one through the Disclosure and Barring Service.
Buying an established licensee does not get round any of this. Under section 102 of the Act, a licensed company that gains a new controller must tell the Commission and either surrender its licence or apply to keep it. The Commission then asks whether it would have granted the licence with the new controller in place, and revokes it if the answer is no. A company that fails to act within five weeks also loses the licence, unless the regulator extends the deadline.
Changes of control are common. In 2024 to 2025 the Commission received 169 applications for a change of corporate control, more than the 156 it received for new operating licences, across all licence types.
The anti-money laundering file carries one name
Money-laundering controls are the earned barrier most easily mistaken for a rented one, because so much of the work can be bought in. The duty cannot. The Money Laundering Regulations 2017 cover casinos alongside banks, accountants, lawyers and estate agents. Regulation 18 requires each business to identify and assess its own money-laundering and terrorist financing risks, taking account of its customers, the places it operates, its products, its transactions and its delivery channels. An assessment written for another company describes another company’s risks.
Training follows the same logic. Regulation 24 requires the business itself to take appropriate measures so that its relevant employees are regularly trained to recognise and deal with transactions that may be related to money laundering, and to keep a written record of the training given.
This blog’s look at what mandatory training really means for modern workplaces makes the general point that an organisation has to be able to show its training is done, tracked and current. For a licensed casino the point carries legal force. A course bought from an outside provider still produces a record the licensee must keep and answer for.
White labels stretch the duty across brands. The Commission’s 2020 report found licensees that could not monitor spending and behaviour across all their partners, and anti-money laundering controls that were ineffective, whether for individual partners or across a licensee’s whole group of partner sites. One customer opened 14 accounts across a single operator’s partner sites before anyone noticed, and lost £209,000 without checks taking place.
When the licence goes, the brands go with it
TGP Europe showed what renting a licence can cost the brands that rent it. The company ran a white-label business, which the Commission described as running a gambling business using the branding of other businesses. In 2023 the regulator fined it £316,250 for failures that included not adequately considering and mitigating the money-laundering risks of business-to-business relationships, and ineffective policies and procedures for due diligence before white-label agreements.
The second case ended its British business. According to the Commission’s announcement of TGP Europe’s exit from the British market, published in May 2025, the company gave up its licence after the regulator said it would have to pay a £3.3 million penalty and make significant improvements to carry on trading in Great Britain.
Investigators had found failures to check the ownership of third parties and the source of funds behind business arrangements, and to apply the enhanced due diligence in TGP’s own anti-money laundering policy. In the same announcement, the regulator’s head of enforcement said several online gambling operators could no longer lawfully offer gambling to consumers in Great Britain, and that sites previously operating under TGP’s licence should not be available to them with immediate effect.
The Commission said it expected an orderly closure, with clear information for customers on how to obtain their funds. A business that rents its licence also rents its continuity. Whatever its own conduct, a brand trading under another company’s licence stays open to British customers only as long as that company keeps the licence.
Customers and a history are won slowly
Customers are the last barrier, and the slowest to clear. A white-label brand can buy advertising, but every promotion it publishes goes out under somebody else’s licence, and the customers it signs up are that licence holder’s responsibility. The 2020 report also found that some licensees had little or no control over the marketing and promotional offers their partners published, and that licensees with white-label partnerships had sent marketing material to more than 2,000 previously self-excluded customers.
Failures like those count against the licence holder when the Commission assesses its compliance. In full initial assessments between April 2024 and March 2025, the regulator graded the licensees it examined on a four-step scale, from good down to significant failings, and put 18.31% of them on the bottom step for crime prevention and 19.72% for consumer protection.
The grades go to licensees, not to the brands that use their licences, so a newcomer starts a compliance history only once it holds a licence. From then on it carries, in its own name, the responsibility the regulator will not let anyone transfer.
Checking that every player is at least 18 falls to the licence holder, whichever brand is on the site. Gamstop is free to join, and once someone registers it blocks them from opening or using online accounts with any gambling company holding a British licence. GamCare’s advisers staff the National Gambling Helpline, and calling 0808 8020 133 is free. So is calling 0808 2819 265, the number for Wales.
