Public consultation opens on proposed changes to Isle of Man gambling licensing laws

Gambling operators and service providers on the Isle of Man could face new licensing conditions under proposed legislative reforms, including expanded disclosure obligations, post-surrender requirements, and mandatory fit-and-proper assessments throughout a license's duration.

The Isle of Man Gambling Supervision Commission (GSC) has launched a public consultation covering proposed changes across six Acts. The revisions are intended to update regulatory processes, unify inspection powers, and prepare for the 2026 Moneyval evaluation.

Licensing and surrender provisions

Under the proposed changes to the Online Gambling Regulation Act 2001 (OGRA) and the Casino Act 1986, applicants and existing licensees would undergo continuous scrutiny. The fit-and-proper test, based on integrity, competence, and financial standing, would apply not only during the application stage but also throughout the license term.

The proposed requirements apply to controllers, beneficial owners, and senior managers, with thresholds set at 5% of voting shares for privately held firms and 20% for public entities. The GSC will issue guidance on how it will apply the test to these individuals, who include compliance officers and money laundering reporting officers.

Voluntary license surrender will also be subject to a formal process. License holders would need to submit wind-down plans, return strategies for player funds, and other documentation. The GSC may impose post-surrender conditions. Refusals to accept surrender or conditions applied to the process would be subject to appeal.

Inspection and enforcement powers

A consolidated set of inspection and investigation powers is proposed across all major gambling laws. These powers are modeled on the Financial Services Act 2008 and would replace existing fragmented provisions.

The proposed powers include routine on-site inspections, statutory rights of entry, compulsory information requests, interviews, and seizures under warrant. These can be used on licensees, former licensees, and related individuals such as associates, senior managers, and beneficial owners. In some cases, powers may extend to unlicensed individuals engaged in gambling activities regulated under Manx law.

Private residences would require consent and 24-hour notice before entry unless a warrant is obtained. New offenses are also proposed, covering obstruction, failure to comply, and provision of false or misleading information. All enforcement actions would carry rights of appeal under the Gambling (Amendment) Act 2006.

AML/CFT personal liability and corporate responsibilities

Amendments to the Gambling (AML/CFT) Act 2018 would clarify the GSC’s authority, allow for sanctions instead of or in addition to criminal proceedings, and establish personal civil liability for senior managers, controllers, and key persons. Liability may arise where the GSC can demonstrate consent, connivance, or negligence. Appeal rights are included.

Other changes include updates to the Gaming, Betting and Lotteries Act 1988 and the Gaming (Amendment) Act 1984 to revise terminology and introduce new appeal rights. The Gambling Supervision Act 2010 would be updated to list regulatory and reputational objectives as primary responsibilities, with CEO Mark Rutherford leading the GSC’s regulatory agenda, while removing the duty to promote economic development.

The public consultation is ongoing. The proposed legislation will be presented to Tynwald (Parliament of the Isle of Man) after feedback is reviewed.