08 July 2026: Civil Penalties Guidance Stakeholder Engagement: Feedback response
The story so far
Between 23 March 2026 and 25 May 2026, the Gambling Supervision Commission ("GSC") undertook a stakeholder engagement exercise on the proposed changes to the civil penalty regime that will be introduced through the Gambling Legislation (Amendment) Bill 2026.
As part of this exercise, the GSC hosted an in-person Q&A session on 14 April 2026, covering both the draft Gambling (Civil Penalty) Regulations 2026 and the associated civil penalty guidance for individuals.
The GSC received 10 formal responses on the draft Regulations and associated guidance. We would like to thank everyone who took the time to engage with the process and provide detailed feedback.
Having reviewed all responses received, a number of amendments have been made to both the proposed Regulations and guidance. While some changes have been made to the Regulations, the majority of feedback related to the accompanying guidance for individuals, which has consequently undergone more substantial revision.
Provided at the bottom of this page is a response document issued by the GSC, which details the changes made since the previous versions of these documents, plus a summary of the main points raised and the GSC’s commentary on these.
Have your say
The Gambling (Civil Penalties) Regulations 2026 are now substantially finalised and are intended to be progressed for approval at the 21 July 2026 sitting of Tynwald.
Given the extent of the changes made to the guidance following stakeholder feedback, the GSC is publishing a revised draft and inviting a final round of comments. This is intended to give stakeholders an opportunity to review the amendments and confirm whether the concerns raised during the initial engagement exercise have been appropriately addressed.
The GSC remains committed to working constructively with the industry to ensure that the final guidance is clear, proportionate, and practical to apply.
What civil penalty provisions is the GSC seeking feedback on?
At this stage, stakeholders are invited to:
- Note the version of the Gambling (Civil Penalties) Regulations 2026 that is intended to be progressed for Tynwald approval; and
- Provide any further comments on the revised Civil Penalties for Individuals Guidance, which will operate alongside the Regulations.
How to provide feedback
If you have any comments on the revised guidance, you can:
- Complete the response form linked on this page; or
- Email your comments directly to Consultations.GSC@gov.im
The GSC will accept comments on the revised guidance until 31st July 2026.
Frequently Asked Questions
What are the Gambling (Civil Penalty) Regulations?
The Regulations are intended to be made following amendments to section 22 of the Gambling (Anti‑Money Laundering and Countering the Financing of Terrorism) Act 2018, brought about by the Gambling Legislation (Amendment) Bill 2025.
These Regulations set out the framework for how the GSC may impose civil penalties on operators and relevant individuals. They address three areas:
- The maximum civil penalty that may be imposed on an operator or individual;
- The factors the GSC must consider on a case‑by‑case basis when determining the amount of a civil penalty; and
- The process the GSC must follow once it has made a decision to impose a civil penalty, including notice and appeal requirements.
What is the civil penalty guidance for individuals?
Currently, civil penalties may only be imposed on an operator.
The Gambling Legislation (Amendment) Bill 2025 expands this power so that a civil penalty may also be imposed on certain individuals (specifically “controllers”, “key persons” and “senior managers”), where an AML/CFT contravention by the operator is attributable to that individual’s consent, connivance, or negligence.
The new guidance explains how the GSC will apply this extended power, including:
- Examples of how “consent”, “connivance” and “negligence” may arise;
- How penalties will be calculated; and
- How the decision‑making process will operate in practice.
This guidance is separate from, and complementary to, the operator-focused discretionary civil penalty guidance already in effect.
When will these changes be coming into operation?
The civil penalty reforms are dependent upon the Gambling Legislation (Amendment) Bill 2026 receiving Royal Assent and being brought into operation.
It is currently anticipated that Royal Assent will be announced at the 21 July 2026 sitting of Tynwald. If this occurs, the GSC expects the new civil penalty regime to become operational during summer 2026, and in any event before October 2026. Advance notice will be provided before the changes take effect.
If Royal Assent is not announced at the July sitting, implementation of the new regime is likely to be delayed until after the next scheduled sitting of Tynwald, currently expected on 20 October 2026.
Thank you again to those who have responded so far for your contributions. The GSC encourages all who are yet to respond to use this final opportunity to have your say in shaping the future of the sector on the island.