10 Vital Top Tips for Drafting Consultation Proposals
The end of September deadline is now quickly approaching for the Gambling Commission’s call for proposals to reduce unnecessary regulatory burdens.
Against a backdrop of continued pressure and uncertainty across the gambling industry, this is a valuable opportunity to be proactive. Operators can highlight the day-to-day compliance requirements that create unnecessary work, cost or complexity and suggest practical ways they could be improved.
We know from talking to operators that there can often be some disconnect between what the regulator is seeking and what the industry believes it expects. That makes it even more important for operators to explain their experiences clearly, support their arguments with evidence, and propose workable alternatives.
1. What is the Commission looking for?
This is not a conventional consultation in which the Commission has set out specific proposals and questions for the industry to answer. Instead, it is inviting operators and other stakeholders to put forward their own ideas about how regulation, guidance and regulatory processes could be improved or streamlined.
Proposals can cover a broad range of areas, including:
License Conditions and Codes of Practice
Technical standards
Regulatory reporting
Guidance and regulatory requirements
Wider interactions with the Commission
Any proposed changes must continue to maintain strong consumer protections and uphold the licensing objectives. Submissions must be made before the end of September 2026, so now is the time to start shaping your response and make your voice heard.
A strong submission should do more than identify a frustration or ask for a requirement to be removed. It should explain exactly what the problem is, demonstrate its practical impact, and propose a credible alternative.
2. Start with a clearly defined problem
Avoid trying to address too many unrelated concerns in one proposal. Focus on a particular requirement, process or regulatory interaction and explain:
What the current requirement involves
Why it creates an unnecessary or disproportionate burden
Which operators, customers or other stakeholders are affected
Whether the issue applies across the industry or to a particular sector
How frequently the problem arises
The more precisely the issue is defined, the easier it will be for the Commission to understand and assess it.
3. Back up your argument with evidence
Evidence will make your proposal much more persuasive. Consider whether you can provide information about:
The staff time required to meet the current requirement
Development, technology or third-party costs
Duplicated work or reporting
Delays created by the existing process
The number or proportion of customers affected
Differences between the intended and actual outcomes
Inconsistencies in how a requirement is interpreted or applied
Real operational data can be particularly valuable. Rather than simply saying that a process is time-consuming or expensive, show the scale of that impact wherever possible.
4. Explain why the burden is disproportionate
Compliance will always require time and resources, so cost or inconvenience alone may not demonstrate that a burden is unnecessary.
A stronger proposal will explain why the effort involved is disproportionate to the risk being addressed or the benefit delivered. For example, does a process require significant manual work while producing very little useful regulatory information? Does it duplicate data that is already supplied elsewhere? Could the same outcome be achieved in a simpler or more targeted way?
A proportionate regulation argument should consider both sides of the equation: the burden created and the regulatory benefit achieved.
5. Propose a practical alternative
Do not stop at identifying what is wrong. Explain what should happen instead. Your alternative might involve:
Simplifying or consolidating reporting
Removing duplicated requirements
Clarifying ambiguous guidance
Taking a more risk-based approach
Changing the frequency or format of a submission
Improving communication or interaction with the Commission
Using existing data more effectively
Allowing greater flexibility in how an outcome is achieved
Be specific about how the proposed alternative would work in practice. If there could be implementation challenges or unintended consequences, acknowledge them and explain how they could be managed.
6. Keep consumer protection at the heart of the proposal
The Commission has made clear that reducing regulatory burdens must not compromise consumer protections or the licensing objectives. Your submission should therefore consider how the proposed change would continue to:
Prevent gambling from being associated with crime or disorder
Ensure gambling is conducted fairly and openly
Protect children and vulnerable people from harm
If your proposal could maintain or even improve consumer outcomes, explain how. Demonstrating that you have considered regulatory risk, and not only the commercial benefit to your organisation, will make for a more balanced and credible submission.
7. Involve the right people
Although the compliance team may lead the response, the issue could affect several areas of the business. Depending on the proposal, it may be useful to involve colleagues from operations, safer gambling, AML, legal, finance, technology, data and customer services. Each team may have a different understanding of how the current requirement works in practice.
Bringing these perspectives together can help you identify the full impact of the problem, test whether your proposed solution is realistic and uncover evidence that may otherwise be missed.
8. Consider the wider industry view
If other businesses experience the same problem, there may be value in speaking to industry peers or representative bodies. This can help establish whether the issue is isolated or widespread, identify different impacts across sectors, and strengthen the evidence behind a proposal.
However, even if an industry body is raising the same point, operators should still consider submitting their own evidence and examples. First-hand operational experience can add valuable detail to a broader industry argument.
9. Make the submission easy to assess
Before submitting your proposal, check that it answers five key questions:
What is the current regulatory burden?
Why is it unnecessary or disproportionate?
What evidence supports that view?
What specific change are you proposing?
How would consumer protection and the licensing objectives be maintained?
Keep the submission focused, clearly structured, and supported by relevant evidence. Avoid general complaints or arguments based entirely on commercial inconvenience.
10. Do not miss the opportunity
The Commission is actively asking the industry to identify tangible opportunities for improvement. This is a valuable chance for businesses to share their practical experience and suggest changes that could make regulation more effective, proportionate, and workable.
Submissions must be made using the Commission’s online form before the end of September 2026. Link to form here.
Betsmart Consulting has extensive experience in regulatory consultations and understands the importance of combining operational insight, regulatory knowledge, and strong supporting evidence.
If you would like help developing, reviewing or strengthening your proposal before the deadline, please get in touch with the Betsmart team on info@betsmartconsulting.com.