The Institute of Licensing has submitted its response to DCMS consultation on Cat D gaming machines and regulation of licensed bingo premises, raising concerns over inconsistencies and a lack of evidence to support amending regulation.

The response emphasised the need for “clarity, proportionality and effective enforcement of existing requirements” as opposed to the introduction of new regulatory structures, such as those proposed for Cat D operators.

“Several of the proposed changes may increase complexity for operators and licensing authorities without clear evidence of associated benefits,” said a spokesperson.

“The IoL does not support the creation of additional sub-categories within Category D machines, including proposals for a new ‘slot-style’ non-money category or a unified ‘pusher’ category.”

The IoL noted that five sub-categories already exist, and that further subdivision is unnecessary “without clear evidence of harm,” while the subdivision would cause “increased administrative and enforcement burdens for licensing authorities.” 

Regarding age restrictions for cash-out Cat D slot-style machines, the IoL observed that no evidence has been presented to show that the current voluntary approach is ineffective, and that “inconsistencies” in the proposals would create “uneven regulatory expectations.”

The organisation also warned that introducing measures such as minimum floor-space requirements for bingo and minimum distances between bingo areas and gaming machines could “reintroduce complex compliance issues similar to those experienced in the early implementation of the Gambling Act 2005.”