Gambling software licence: UK supply and hosting roles

What counts as gambling software?

The Gambling Commission distinguishes software used in connection with remote gambling from general-purpose applications used by many industries. Its guidance examines actual manufacture, supply, installation and adaptation activities.

Prepare a component register rather than describing the entire business as “IT”. Record each component’s purpose, clients, developers and deployment method. A game engine, a platform integration and an ordinary accounting package should not be treated as identical just because all three are software.

Where does a distributor fit?

The Commission’s guidance addresses supply chains and the final supplier to a licensed operator. An intermediary should not assume that having no programmers means it has no licensing obligations.

Draw the product journey from developer to operator, including any distributor, aggregator and hosting business. For each contract, identify the party supplying the regulated product and the party changing it. Keep the contractual map aligned with the technical architecture: a reseller that also controls production deployment may have a different role from its invoice description.

When does hosting require another permission?

The UKGC software-licence page explains that a business hosting gambling facilities for another operator’s customers may need the relevant host operating permission in addition to a software licence. The direct player-contract distinction is important.

Consider two models. In the first, a developer delivers software to the operator’s infrastructure. In the second, players use the developer’s live game servers through the operator’s website. The commercial revenue share might look similar, but the hosting activity changes the questions that must be assessed.

What should be prepared for an application?

Follow the current UKGC document requirements and describe the supply process accurately. The following checklist is an organisational aid, not an exhaustive legal test.

• List product components and the regulated activity associated with each.
• Identify licensed customers, suppliers and relevant licence numbers.
• Explain delivery, installation, change approval and production access.
• Document testing evidence and the versions to which it applies.
• Separate overseas deployments from deployments relied on by UKGC-licensed operators.
• Record any hosting role and whether the business contracts directly with players.

How do changes affect the evidence?

A test report for one version or configuration should not be treated as a universal certificate for every deployment. Ask what changed, whether the change affects fairness or regulated records, and what retesting or reporting process applies.

Maintain a release register linking version, change description, approval, test evidence and rollback plan. This gives the licensing and compliance teams a usable record when the product evolves. Before quoting fees, check the official software-licence page: it publishes a fee change effective 1 October 2026, so old fee tables should not be reused without a date check.