I asked the Gambling Commission for advice on this issue.The response from the policy department:In short, wholly electronic bingo premises are permitted. There are two common ways this might be offered, that is via handheld electronic bingo terminals (EBTs) or stand alone cabinet based terminals, commonly referred to as bingo machines/video bingo terminals (VBTs). For these types of offering (and more broadly) there are two issues we’ve had to address. The first is around how to ensure that the primary offer remains bingo in this type of premises, and the second is what we accept as being a genuine bingo machine. Licence condition 16 (currently contained in supplement 4 to the LCCP) deals with the requirements for primary gambling activity in bingo premises that are wholly electronic. It essentially requires there to be a higher number of bingo machines than gaming machines. It states: 'In cases where bingo is exclusively offered by means of electronic bingo terminals or bingo machines, there must be more individual player positions made available for bingo than there are gaming machines made available for use.' In addition to this, there are ordinary code provisions contained within the same supplement that also apply (Ordinary code 9, Primary Gambling Activity). These provide indicators of what we consider needs to be available in order to demonstrate that the primary activity is that permitted by the licence, for example the frequency of bingo offered, the extent the activity is promoted, the expected or actual use of the facilities and so on. The supplement can be found here. We are also content that bingo can be offered wholly by way of machine and the Act allows for this, creating an exemption that stops these machines being subject to the same controls as gaming machines. Machines that play bingo are exempt from limits on numbers, and stakes and prizes. Traditionally, bingo by way of machines has been commonly offered through EBTs, but more recently (over the last two years) the industry has sought to develop a stand alone bingo machine offering. Some of the initial developments in this area gave rise to concern, as although purporting to be bingo, they were found to be gaming machines essentially hiding behind a bingo ‘badge’. In order to address this and following discussions with the Bingo Association and BACTA, the Commission published a list of characteristics which we consider must be present in games, whether or not played by machine, to be classed as bingo. The characteristics are particularly relevant to bingo machines. If these characteristics are not present it is likely that the Commission will view the machines as gaming machines and regulate accordingly. The non-compliant machines were removed from the market. The key characteristics document can be found here.
Sara Nathan ● 5733d