What this means
Start with the exact decision in front of you.
The Commission can commence a licence review under section 116 of the Gambling Act 2005 on specified grounds. A PML holder should identify the ground, alleged breach and material relied upon before addressing outcome.
Immediate priorities
Organise the position before responding.
Obtain the formal review notice and cited statutory ground
Build an issue-and-evidence schedule
Separate operator failings from the holder's own decisions
Detailed guidance
The procedure, evidence and possible route from here.
01
Read the review grounds
Under section 116 of the Gambling Act 2005, the Commission can review an operating or personal licence on specified grounds. The notice should identify the licence, grounds, procedure and opportunity for representations. Mark each alleged breach, suitability concern or relevant event separately. Do not treat a review of the operator as automatically establishing a review finding against the PML holder, even where the same systems are examined.
Create a procedural calendar for any initial meeting, document requests, interviews, preliminary findings, representations and regulatory hearing. Confirm whether the PML remains active or an interim suspension has been imposed. A review can change course as evidence develops, so keep versions of allegations and Commission correspondence. That record helps identify whether a later finding was fairly notified and whether the holder had a real opportunity to answer it.
- List each statutory ground and alleged breach
- Create a complete review timetable
- Track changes in the Commission's case
02
Separate operator systems from personal action
A PML holder may have responsibility for strategy, finance, compliance, marketing, AML or another specified office. Define the actual authority, reporting lines and resources during the relevant period. Evidence should show what information reached the holder, what decision was taken and what follow-up occurred. An organisational chart or title alone rarely answers whether the individual took reasonable and diligent management action.
The operator's control failure may provide essential context without resolving personal suitability. Review board papers, committee challenges, risk acceptance, resource requests and escalation. If the individual relied on a specialist team, explain the basis for reliance, monitoring and follow-up over time. If warning signs were missed, address them directly and distinguish contemporaneous limitations from remediation introduced after the Commission intervened.
- Map personal decisions to the evidence
- Show oversight of delegated work
- Distinguish historic systems from later remediation
03
Prepare for outcomes under section 117
At the end of a review, the Commission may take no further action, give advice or a warning, change licence conditions, suspend or revoke the licence and, where the statutory basis exists, impose a financial penalty. Powers may be combined. Prepare submissions on findings first, then suitability, the licensing objectives and proportionality. A warning and revocation carry very different practical consequences.
If the Commission sends preliminary findings, check the stated representation period and evidence relied upon. Twenty-eight days is common in the published process, but the actual letter governs and may specify less. Decide whether to accept a proposed outcome or seek decision through the Regulatory Panel route. Preserve appeal rights by recording when the final decision was received and what forum is identified.
- Address findings before sanction
- Check the preliminary-findings deadline
- Record the route to Panel or appeal
Key questions
Keep the analysis tied to this stage.
Whether a review ground is established
How the conduct affects ongoing suitability
Which regulatory outcome is available
Advice is provided only by the regulated firm that accepts a matter.
Common questions
Clarifying the route without assuming the outcome.
Can section 116 apply to a Personal Management Licence?
Yes. The Commission's licensing principles expressly contemplate reviews of operating and personal licences.
Does an operator breach automatically prove the PML holder is unsuitable?
No. The evidence must address the holder's role, conduct and suitability, although operator failures can be highly relevant context.
Connected guidance
Continue through the topic map.
Use the hub for the full sequence or choose the connected route that matches the notice.
Official sources
Check the material for this question.
Sources checked 19 September 2026. Rules change, so compare the current notice and linked official material and tell the operator if a citation or summary needs correction.