Unlicensed FEC Permits issued under the Gambling Act 2005 authorise the holder to make category D gaming machines available for use. They are valid for 10 years. The first Unlicensed FEC Permits, issued in September 2007 will therefore be due for renewal in September 2017. An application to renew a Permit should be made at least 2 months before it is due to expire.
In the early months after the Gambling Act came into effect, many Permits were, to all intents and purposes, automatically granted upon receipt of an application. However, over the years there has been a significant change in the way local authorities understand and interpret the Gambling Act. In the 5th edition of its Guidance to Local Authorities, issued in September 2015, the Gambling Commission reminded local authorities that Unlicensed FECs are premises which are wholly or mainly used for making gaming machines available and cannot be granted for an entire shopping centre airport or bowling alley. In its latest Local Authority Bulletin the Gambling Commission has mentioned one local authority that intends to review all the permits it has issued to assess whether they are still suitable. It is therefore likely that others will do the same.
Arcade owners are therefore advised to make an early application to renew existing Unlicensed FEC Permits. If necessary they should have an early conversation with their local licensing team if there are any doubts about whether the permit will be renewed.