Guide
What to do when your gambling licence application is queried or returned
A query is normal, and a returned file is rarely the end. What matters is how you respond, and how fast. Here is a plan for the first ten working days.
Queried, returned or refused: what is the difference?
- A query asks you for information or clarification while the review continues. It is the most common outcome.
- A returned application is sent back, usually because it is incomplete or inconsistent, and has to be corrected and resubmitted. Whether the review clock stops depends on the regulator.
- A refusal is a decision. It ends the application, and the routes that follow depend on the regulator and on strict time limits.
The wording and the consequences differ between regulators, so start by reading the letter or message closely. It states what is being asked, by when, and how to reply.
The first ten working days
- 1
Day 1: read it, log it and set the deadline
Read the whole query twice. Log the date, the deadline stated in it and the exact questions. Tell everyone who might be asked to contribute, and name one person who owns the response.
- 2
Days 1 to 2: triage the questions
Sort the questions into those you can answer from the file, those that need new evidence, and those that point to a real gap. Decide early whether the deadline is achievable, and if not, ask the regulator for more time before it passes.
- 3
Days 2 to 6: gather the evidence
Collect the documents and statements each answer needs, from the people who hold them. Check every figure and every name against what the file already says.
- 4
Days 6 to 8: draft and test against the file
Write the answers. Then read them against the whole file and against anything you have filed with other regulators. Any difference is a new question waiting to be asked.
- 5
Day 9: independent review and sign-off
Have someone who did not write the answers read them cold, ideally your adviser, then have the named owner sign off. Update the underlying documents if an answer changes them.
- 6
Day 10: submit and confirm receipt
Send the response by the route the regulator specifies, in one complete package, and confirm that it was received. Keep a copy of exactly what was sent.
Who should answer
- One named person owns the response and is the only contact. A single voice keeps the answers consistent.
- The people the question concerns supply the facts: the owners for ownership, the finance lead for funds, the compliance officer for policies.
- An adviser reviews the response before it goes, and where the regulator allows, speaks to it on your behalf.
- The licensed entity's responsible people sign off. The regulator is relying on their word.
What not to say or do
- Do not contradict the file. If the answer differs from what you filed, explain why and correct the file.
- Do not guess. If you do not know, say that you are checking and when you will answer.
- Do not blame a former provider or adviser. The file is yours.
- Do not send a partial answer without saying what is still to come and when.
- Do not introduce new facts without checking them against everything else you have told the regulator.
- Do not argue with the regulator. Answer the question that was asked.
- Do not let a question go unanswered. A silence is read as a gap.
What queries usually point to
| The query asks about | It usually means | How to answer |
|---|---|---|
| The ownership chain | The chain to the UBOs is unclear or inconsistent | Provide a current chart and the identification for each person on it, and explain every holding structure. |
| Where the money comes from | Source of funds or wealth is not evidenced | Give dated, independent evidence of the capital actually used, not a statement. |
| Your policies | They read as templates | Show how the policy works in your business: named owners, real processes, examples. |
| Local presence | Premises, people or decision-making are not credible | Describe where staff and infrastructure sit and what decisions are taken there. |
| Key people | A fit-and-proper concern | Provide complete personal information, and explain any matter the regulator raises candidly. |
See UBO, source of funds and source of wealth, and the article on the five most common reasons applications are rejected.
Ask for time early, not late
If the deadline cannot be met, ask for more time before it passes, say what you need and why, and say when you will deliver. A request made in good time is routine. A deadline missed in silence is not.
Questions about queries and returned applications
Keep reading
Insight
The five most common reasons applications are rejected
Where files fail, and how to avoid it.
Guide
UBO, source of funds and source of wealth
What regulators actually ask for, what a good file looks like, and where files go wrong.
Guide
How to get an online gambling licence
The decisions to make, the eight steps of an application, the documents regulators ask for, and where operators lose time.
Received a query and not sure how to answer?
Send us the letter. A short call is usually enough to tell you what the regulator is really asking, and what to send back.