Earlier this year, we reported on the Government’s announcement that it would launch a consultation on preventing gambling operators that were not licensed in Great Britain from sponsoring British sports clubs and organizations. On 15 July 2026, the consultation was launched. Here we consider the detail of the consultation and what this could mean for British sport organisations once the outcome of the consultation is published.

Background and rationale

Although it is an offence to advertise unlawful gambling under the Gambling Act 2005 (the “Act”), unlicensed operators may still be able to advertise to consumers via British sports entities if: (i) the operator has a white label arrangement with a licensed operator, meaning that the unlicensed operator’s services are not, per se, unlawful; or (ii) the unlicensed operator’s services cannot be accessed by consumers in Great Britain, for example via geo-blocking.

The new consultation reflects Government concerns that consumers may be continuing to access unlicensed operators’ services despite geo-blocking measures, including through the use of VPN technologies. With this in mind, the new consultation hopes to achieve the following objectives:

1. Protecting consumers: the Government is concerned that sponsorship agreements with high-profile sports opportunities act as stamps of legitimacy and may encourage the use of unlicensed operators’ services. As unlicensed operators do not need to implement the player protections or safer gambling measures mandated by UK gambling regulation, using an unlicensed operator carries a greater risk of gambling harm and the Government is therefore keen to discourage the use of these services.
    
2. Ensuring the integrity of the domestic gambling market: as only licensed operators are required to comply with UK gambling regulation and contribute to the new statutory levy, the view of the Government (and licensed operators, who face higher compliance costs than unlicensed operators yet lose UK consumers’ business to those competitors) is that unlicensed operators should not be afforded advertising opportunities which drive UK customers to their services and increase the unlicensed operators’ share of the UK market (which they do not contribute to). 
    
3. Combatting money laundering: the connections between unlicensed operators and organised crime means that sponsorship arrangements can be used as a vehicle to launder funds, and the Government is keen to prevent this occurring.

New Proposals

The new consultation proposes to implement legislation to ban anyone, across all sectors, venues and events (including those relating to sports), from entering into a sponsorship or advertising arrangement with a gambling provider that is not licensed by the Gambling Commission. Anyone who continues to advertise or have a sponsorship deal with an unlicensed sponsor after the ban comes into effect would commit a criminal offence punishable by imprisonment for up to 51 weeks and/or an unlimited fine. 

This is a far wider ban that was originally expected, covering all sectors across British industry not just sport. In a sports context, it would cover all sponsorship and advertising displayed at and associated with sporting and other cultural events such as kit and equipment sponsorships, event paraphernalia such as programmes, ground and field advertising, venue infrastructure, and naming of leagues, events and venues. However, it should be noted that the ban will not include: 

1. Online advertising and sponsorship, which would require primary legislation (though it should be noted that the consultation states the Government has not ruled this out in future); or
    
2. Gambling operators who partner with B2B white label providers licensed by the Gambling Commission. The Government does not expect to extend the ban to cover these unlicensed white label partners, which is a reasonable position to take given that many white label arrangements contain terms which require the partner to comply with British gambling regulation.

Timing

The consultation outlines two potential options for the timeline of implementation, being: (i) commencement on a fixed start date in August 2027 to align with the start of the 2027/28 football season, by which time all agreements with unlicensed operators must have ceased; or (ii) commencement from a specified date, from which new agreements with unlicensed operators will be prohibited but existing agreements would continue provided they do not extend beyond the beginning of August 2028. The Government’s preference is route (i) in the interests of clarity, though respondents to the consultation may give feedback on this proposal.

Comments

As we set out in our previous article on this topic, the transition from an "access"-based test (i.e. whether consumers can access the unlicensed sponsor’s services) to a "status"-based test (i.e. whether the sponsor is licensed) has significant practical consequences for sports rights-holders. The Government estimates that approximately 40% of Premier League clubs had sponsorship or advertising deals with unlicensed gambling operators for the 2025/26 season and, whilst these high-profile organisations may be able to absorb a reduction in sponsorship revenues, smaller sports organisations that are more heavily reliant on sponsorship may face greater impact from the changes (particularly if there are fewer sponsors available to the rights-holder as replacements to the unlicensed operator).

For commercial legal teams, the consultation reinforces points we have previously raised about the importance of robust change-in-law provisions and exit mechanics in sponsorship agreements. Clubs currently negotiating or renewing deals (particularly those running into 2027/28) should pay close attention to how regulatory risk is allocated and ensure that contracts address the possibility of a mid-term ban. Conversely, as it’s not currently known whether the government will allow a transition period, organisations should consider the benefits of a two year deal to take advantage of any leeway for existing agreements. 

This eight-week consultation will enable the Government to consider the best available evidence before any possible legislation is laid before Parliament, with the Government planning to formally respond to announce its decision later this year.  The government is keen to collect information and evidence to understand the impacts that any ban could have, including its impact on the financial viability of sports, clubs, leagues, events, and other sectors, and whether a ban would cause any unintended risks, strongly encouraging all impacted stakeholders to provide robust data and evidence. 

It should be noted that the consultation was published under the previous Prime Minister's government. Following the appointment of Andy Burnham as Prime Minister, it remains to be seen whether the proposed ban will be afforded the same level of priority by the new administration, and stakeholders should be mindful that the Government's position may evolve as the new leadership sets out its legislative agenda, although we wouldn’t put money on a material change in course. 

Sports clubs, leagues, broadcasters and gambling operators with a view on the scope, timing or impact of the proposed ban should give serious consideration to submitting a response.  The consultation closes on 9 September 2026, leaving a relatively narrow window for affected stakeholders to respond.