The games are also part of a wider package of entertainment at some venues and it’s great to see so many different people engaging in this classic game.
We do notice however that some operators may not be fully aware of the legal requirements in respect of providing bingo in pubs, and we do get a number of questions on this.
It is important to know and understand the rules as failure to comply with the regulatory requirements could be considered the provision of illegal gambling.
While a licence review may be unlikely, operators could find themselves in breach of the crime and disorder Licensing Objective under the Licensing Act 2003.
Bingo is permitted in pubs as Exempt Gaming but there are a number of very specific rules that need to be followed:
- Premises must contain a bar from which alcohol is served for consumption on the premises and the sale of alcohol must not be restricted to only those customers consuming food.
- Games can only be played at times when alcohol can be supplied in reliance on the premises licence (or sold for consumption on the premises in reliance on a Scottish premises licence providing the operating schedule also permits bingo type gaming).
- There must be no separate participation fee, which would include a ticketed event whereby customers are provided with food, beverages and bingo cards for a single price.
- No amount can be deducted from stakes with all money taken being returned to the player(s) as prizes.
- The maximum stake for any game of bingo is £5 per person. So if each bingo card in a game costs £1, a player cannot buy more than 5 cards in that game.
- The bingo games cannot be linked with another bingo game played on another set of premises.
- Under 18s are not permitted to play.
Premises managers should ensure that the limits are not breached.
There is no limit to the value of prizes for all games (you can donate additional prizes in excess of the total stakes received) but the gaming must not be classified as high turnover, which means that neither the stake nor the prize total can be greater than £2,000 in any seven day period.
A lot of operators are also unaware the Gambling Commission has a Code of practice for Equal chance gaming in clubs and premises with an alcohol licence pubs and this available on its website.
The Designated Premises Supervisor (DPS) is responsible for ensuring the Code’s requirements are met, which include:
- All gaming carried out on the premises must be in a place where it can be supervised by staff whose duties include supervision of gaming (including bar or floor staff).
The DPS should put into effect procedures designed to prevent underage gambling. This should include:
- Holding the gaming in premises or parts of premises, which are restricted to adults
- Checking the age of potentially underage players and refusing access to the gaming to anyone apparently underage who cannot produce an acceptable form of age verification and identification.
Procedures should also be in place for dealing with cases where an underage person repeatedly attempts to gamble including verbal warnings and reporting the offence to the Commission and the police.
The DPS should take reasonable steps to ensure that all employees understand their responsibilities under this code, including:
- Stakes need to be paid prior to the commencement of the bingo game, and no credit can be offered.
- For all organised games, the rules of the game being played should be displayed or otherwise made available to all players before and during the game.
- The DPS has to ensure a pleasant atmosphere and deny participation to customers who cheat or collude with other players or employees, threaten other players or employees or damage equipment.
Making sure you have the right procedures in place means that you can offer your customers a fun game of bingo at your pub safe in the knowledge that you are following the rules correctly. Now, eyes down for a full house!
- Imogen Moss is an associate solicitor at Poppleston Allen
