Gambling sponsorship in sport: the UK's tightening rules

In brief

In February this year, the Government announced plans to consult on a ban on the sponsorship of sports clubs by unlicensed operators.
It is expected that the consultation will be launched imminently.
This article examines the current legal position and context for the Government’s concerns, which gambling operators and sports clubs should be aware of before responding to that consultation.

The Gambling White Paper

In April 2023, the then Government published its white paper, High Stakes: Gambling Reform for the Digital Age, which set out proposals for reforming the regulatory framework underpinning the Gambling Act 2005 and suggested various further reforms including regarding gambling advertising.

It recognised the amount of sponsorship revenue that comes from gambling operators, and the potentially serious financial impact – particularly for sports and leagues outside the Premier League – if gambling sponsorship were to be restricted or prohibited. In doing so, it also set clear expectations that a Code of Conduct should be adopted by sports governing bodies in relation to gambling sponsorship (which was already in development at the time of the white paper), and recognised the then newly-announced agreement by the Premier League to ban front-of-shirt gambling logos. In light of these voluntary steps by the sports and gambling sectors, the Government stopped short of proposing any legal restrictions on sports sponsorship.

The Premier League shirt-front ban and new Codes of Conduct

In April 2023, Premier League clubs collectively agreed to withdraw gambling sponsorship from the front of matchday shirts. The voluntary ban will take effect from the end of the 2025/26 season, and follows an extensive consultation involving the league, its clubs, and the Department for Culture, Media and Sport. Gambling brands will still be permitted to appear on sleeves, in stadia, and as official partners.

In 2024, the Betting and Gaming Council developed a cross-industry voluntary Code of Conduct for gambling sponsorship deals, working alongside national sports governing bodies and leagues, including the Premier League, the English Football League, The FA, the Women's Super League, the Rugby Football League, the British Horseracing Authority, and official bodies representing darts, snooker and boxing. See our previous article on complying with the Code.

Sponsorship by unlicensed operators – the current position

What does the law say?

Put simply, the relevant provisions of the Gambling Act 2005 (as amended) are as follows:

section 33 provides that it is a criminal offence to “provide facilities for gambling” to persons located in Great Britain without holding an operating licence issued by the Gambling Commission.
section 330 prohibits the advertising of unlawful gambling, in particular gambling facilities where the relevant operator does not hold a licence from the Gambling Commission, and is committing the section 33 offence by offering its facilities to consumers in Great Britain.

A person charged with an offence under section 330 shall (depending on the specific activity) have a defence if the relevant person “reasonably believed that the advertised gambling was lawful”, or otherwise shall only have committed the offence if “he knows or should know that the advertised gambling is unlawful”. Similarly, the Gambling (Licensing and Advertising) Act 2014 came into force in May 2014, and made provisions relating to the application of the law to remote gambling; in particular, it introduced section 36(3A), which clarified that a person shall only commit the section 33 offence if they “know or should know that the facilities are being used, or are likely to be used, in Great Britain".

These provisions mean, broadly, that if a club has confidence in an unlicensed operator’s geo-blocking measures, no offence will be committed under section 330.

Following the passing of the 2014 Act, however, the Commission’s then director, Nick Tofiluk, wrote to sports governing bodies warning about the dangers of sponsorship deals with unlicensed gambling companies, and the risk of liability under section 330 ‘if they do not ensure that the remote gambling activity is actually blocked to consumers in Great Britain’. The Commission has consistently expressed doubt about whether geo-blocking measures are effective – a position it maintains in the current guidance on its website.

The warnings and doubts expressed by the Commission have led to a large number of sports clubs striking deals either with licensed operators, or with ‘white label’ brands (i.e. brands owned by gambling operators that do not hold their own UK licence, but who enter into arrangements with licensed operators in order for the brand to be operated in the UK).

Recent developments

In early 2025, TGP Europe exited from the UK market (following an investigation by the Gambling Commission and a subsequent fine of £3.3 million for breaches of its licence conditions). TGP was a prominent licensed operator that operated several ‘white label’ brands under its licence, including Stake.com. As several of TGP’s brands had sponsorship deals with sports teams, its exit meant that several major teams had deals with brands that no longer benefited from a white label arrangement in the UK (and were therefore, now, unlicensed).

This shift brought the issue of unlicensed sponsors to the fore, and both the Gambling Commission and Government have expressed concern with what they see as a regulatory ‘loophole’ that exposes UK customers to unlicensed websites.

In February 2025, the Gambling Commission published guidance on its website stating that “the Commission will seek assurance from clubs that they have carried out due diligence on their gambling partners and that consumers in Great Britain cannot transact with the unlicensed websites" and that “It is essential that any organisation contracting with brands that do not hold a Gambling Commission licence manage their exposure to risk. This includes satisfying themselves as to the source of the funds for the arrangement.” Following this, in May 2025, the Gambling Commission wrote to certain of the affected clubs (AFC Bournemouth, Fulham, Newcastle United, Wolverhampton Wanderers and Burnley), warning of the risks of promoting unlicensed gambling websites. The letter warned that club officers could face prosecution - and, if convicted, a fine, imprisonment, or both - if they promoted unlicensed gambling operators that were transacting with consumers in Great Britain, largely repeating its warnings from 2014. The Gambling Commission also made clear that it would carry out checks without notice to verify that the sites remained blocked to UK consumers, and would conduct ongoing spot checks to ensure they were not accessible by any means.

While it has taken a robust stance in suggesting what kind of due diligence sports clubs should carry out, the Commission does not have regulatory remit over sports clubs. It does, however, have the ability to prosecute the section 330 offence, and so the risk to sports clubs of committing an offence is real if their unlicensed sponsors do not properly geo-block UK customers.

Planned consultation

On 23 February 2026, the Government announced a consultation on prohibiting unlicensed gambling operators from sponsoring British sports teams altogether. This would mean that only gambling operators licensed by the Gambling Commission would be permitted to sponsor a British sports team. The consultation is expected to be launched in Spring 2026.

While the Government notes that “Clubs are currently not acting unlawfully in maintaining these sponsorship arrangements as long as the gambling operators are not accessible to UK consumers”, its concern is that brand visibility through sport sponsorship could drive consumers towards sites operating outside the Commission's regulatory protections. This forms part of a wider effort by Government and the Gambling Commission to tackle the growth of the black market in the UK.

A newly established Illegal Gambling Taskforce has also been set up to prevent unlicensed operators from advertising on social media, block payments to unlicensed operators, and strengthen cross-agency collaboration.

What this means for gambling operators

The consultation has not yet been launched, but is expected imminently. It is not clear how long the consultation will last, nor how long the Government will take to review responses and publish their conclusions. If the Government does decide to go ahead with the ban, it is likely that this will require the creation of a new statutory offence (or amendment of the current offence under section 330 of the Gambling Act). This will require parliamentary time - meaning the potential timing for a ban becomes even less clear.

Licensed operators and sports clubs should, however, be reviewing their existing sponsorship agreements carefully to understand how changes in the law are managed, and what happens to commercial arrangements - including fees and termination rights - if the legal position changes.

Finally: we always recommend that affected parties engage with consultations and take the time to submit a considered response, as they are often the only way for affected parties to be heard and evidence considered. Post-consultation, there are very limited options to have any impact on the decision taken by government, or the legislative process.