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Regulatory

Personal Management Licence (PML)

Definition

The individual licence Britain's Gambling Commission requires people in specified senior roles at a licensed operator to hold, including the chief executive, the chair and the heads of finance, compliance, marketing, gambling IT and anti-money laundering, making each personally accountable.

Key takeaways

  • A PML is the individual licence Britain requires for senior managers in specified functions, making them personally accountable.
  • Holders can be investigated and sanctioned independently of the company, and findings follow them to future roles.
  • The Commission expects PML holders to challenge commercial decisions that create compliance risk.
  • Malta, the American states, Ontario and Ireland have equivalents; the common feature is action against the person.

Why it matters

British gambling regulation licences people as well as companies, and the personal management licence is how. An operator’s licence conditions require that the individuals responsible for specified management functions (overall management and direction, chairing the board, finance, regulatory compliance, anti-money-laundering, marketing, gambling-related information technology, and oversight of the day-to-day management of licensed premises) each hold a PML, granted after the Commission has assessed their identity, integrity, competence and history. The holder is then personally subject to the Commission's jurisdiction: they can be investigated, have conditions attached, and have the licence suspended or revoked, independently of anything that happens to the company.

The purpose is accountability. When an enforcement case finds that an operator's anti-money-laundering controls failed, the Commission can, and increasingly does, examine the PML holder responsible for that function, and a personal finding follows a person to their next role. Boards and executive teams therefore treat PML functions as positions of personal regulatory exposure, and the Commission has said explicitly that it expects PML holders to challenge commercial decisions that create compliance risk and that a holder who did not is themselves at fault.

Other jurisdictions have equivalents under different names: Malta's key function holders, the American states' individual licences and findings of suitability for officers and key employees, Ontario's registration of key individuals, and Ireland's fit and proper assessment of relevant officers under the Gambling Regulation Act 2024. The common feature is that the regulator can act against the person, which is the feature that changes how compliance decisions are made inside the company.

Sources

  1. LCCP Condition 1.2.1: Specified management offices, personal management licences - Gambling Commission
  2. Gambling Regulation Act 2024 - Irish Statute Book (Office of the Attorney General)

Frequently asked questions

  • Who needs a personal management licence?

    Individuals responsible for the management functions listed in the operator’s licence conditions: overall management and direction, chairing the board, finance, regulatory compliance, anti-money-laundering, marketing, gambling-related information technology, and oversight of the day-to-day management of licensed premises. Small operators may have one person holding several.

  • Can a PML holder be fined personally?

    The Commission can attach conditions to, suspend or revoke a personal licence and can issue warnings, and its reviews of individuals are published. Personal financial penalties are limited, but losing the licence ends a career in the regulated sector.

  • What is the difference between a PML and a personal functional licence?

    A PML covers management functions. A personal functional licence covers operational roles in land-based gambling such as croupiers and cashiers. Remote operators mainly deal with PMLs.

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