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16th March 2020

Hewitsons LLP contribute to The Gambling Commission Consultation on Society Lottery Reforms

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Whilst the terms “gambling” and “lottery” may make many feel uneasy as they picture groups of men in casino with stacks of coins surrounding them, the reality could not be any more different. Many of us would not consider ourselves to be “gamblers” in the traditional sense, however we have taken part in a form of lottery at some point in our lives. Whether that be buying a scratch card to taking part in a raffle, gambling is more common than we think and something a lot of us have done without considering it as a form of gambling.

Society lotteries exist primarily as a form of fundraising for good causes and to encourage consumer engagement with communities through sport or cultural activities and the success of them has grown. Therefore in June 2018 the Government published a consultation on society lottery reform, seeking views on potential changes to sales and prize limits for large and small society lotteries. In July 2019, the government announced that it intends to raise the per draw limit on lottery proceeds from £4m to £5m. The maximum individual prize will raise from £400,000 to £500,000. In addition, the annual aggregate proceeds limit will rise from £10m to £50m.

The Gambling Commission is required to attach conditions to lottery operating licences. So the current limits will need to be amended to reflect the changes. The Gambling Commission launched a consultation which closed on 12 March 2020, seeking views on strengthening some aspects of the licence conditions and codes of practice (LCCP) and producing guidance related to information available to consumers. Saffa Mir, from our Hewitsons’ Charities, Education and Social Enterprise Team, was part of the Charity Law Association’s working party response, contributing to their submission to the consultation.

The working party went through the proposed license conditions and codes of practice, and whilst overall the party agreed with the need for greater transparency for consumers, concerns were also raised. The concerns focused upon the methods which have been suggested in order to achieve the greater level of transparency, with the group feeling there was a lack of clear guidance on how to apply the suggested changes and therefore suggestions for how it could be clarified were proposed in the submission.

Hewitsons thanks the Charity Law Association for enabling us to be part of the working party response and we look forward to reading the outcome of the consultation.