21 September 2026: Fitness and Propriety Stakeholder Engagement: Feedback response
The story so far
Between 16 March 2026 and 25 May 2026, the Gambling Supervision Commission ("GSC") undertook a stakeholder engagement exercise on the proposed fitness and propriety suitability changes that are being 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 Fitness and Propriety Guidance.
The GSC received seven formal responses to the draft guidance.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.
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
Stakeholders are invited to provide any final comments in respect of this next draft of the Fitness and Propriety Guidance. This is intended to give stakeholders an opportunity to review the amendments and confirm whether comments 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 and practical to apply.
What is the GSC seeking feedback on?
Stakeholders are invited to provide any further comments on this next revised version of the Fitness and Propriety Guidance.
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 12 October 2026.
Frequently Asked Questions
What is the Fitness and Propriety Guidance?
This guidance will underpin the new suitability requirements for operators licensed under the Online Gambling Regulation Act 2001 and the Casino Act 1986 (“regulated entities”), as well as key individuals such as controllers, directors and senior managers (“regulated persons”).
The guidance explains how the GSC assesses whether individuals and entities meet the required standards of integrity, competency and financial standing. It is intended to promote transparency and help stakeholders understand what the GSC expects at licensing stage and throughout the ongoing supervisory relationship.
The proposals build on the GSC’s 2025 public consultation on the draft legislation, which first outlined the move to a new suitability standard. The draft guidance clarifies how these “Fitness and Propriety” criteria will apply during both onboarding and ongoing integrity assessments.
What is new about this guidance?
The current integrity guidance focuses solely on character‑based assessments. The new regime retains this element but adds two further categories: competency and financial standing. Together, these three criteria form the GSC’s overall assessment of a regulated person’s or entity’s fitness and propriety.
The guidance also clarifies several aspects of the updated licensing framework, for example, how the GSC may consider the integrity of an applicant’s associates, reflecting changes introduced by the Bill.
When will these changes be coming into operation?
These new suitability requirements are being introduced by the Gambling Legislation (Amendment) Bill 2025 and are expected to come into force following Royal Assent being announced for the Gambling Legislation (Amendment) Bill. This is currently expected no later than 20 October 2026. Once commenced, they will replace the current, differing suitability requirements across both Acts. The new guidance will also replace the GSC’s existing Integrity Guidance.