Think 25 Age Assurance for Gambling Venues

Preventing underage gambling is a fundamental licensing objective, and Think 25 is how most land-based venues put it into practice. Since 2024 the Gambling Commission has expected operators to challenge more customers, test themselves more often and show that their controls work.

This guide explains what Think 25 means for gambling venues, why consistent age assurance is hard on a busy shop floor, and how AI age estimation can support — not replace — your staff.

What is Think 25?

Think 25 (sometimes written Think25) is a simple principle: anyone who appears to be under 25 may be asked to provide acceptable proof of age before accessing an age-restricted product or service.

The legal age for most gambling is 18. Setting the checking threshold higher creates a safety margin. Staff don't have to judge whether someone is 17 or 18 — a notoriously difficult call — but whether they might be under 25, which is far easier to apply consistently.

Think 25 and the 2024 rule changes

Following its consultation, the Gambling Commission confirmed↗ two changes to the Licence Conditions and Codes of Practice (LCCP), effective 30 August 2024:

1. Think 25 replaced Think 21 for casinos, adult gaming centres (AGCs), bingo and family entertainment centres (FECs), and betting premises.
2. Smaller venues lost their test purchasing exemption. Category A and B licensees in betting, bingo, FECs and AGCs must now carry out age verification test purchasing too.

The consultation singled out bingo and AGCs as areas of concern: commentary on the consultation↗ reported that 16% of bingo test purchasers and 18% at AGCs were not challenged at all.

Why age assurance is difficult in gambling venues

Think 25 is simple to state and hard to apply every time. Common pressures include:

• Busy entrances. Customers arrive in groups or at peak times, often while staff are serving someone else.
• Inconsistent human estimation. Judging age by eye is subjective. Make-up, beards, clothing and lighting all change how old someone looks.
• Different staff, different judgements. One colleague may challenge a customer whom another would wave through, so a policy is applied differently from shift to shift.
• Multiple access points. Larger venues have several entrances and gaming areas, and customers can head straight for machines without passing a counter.
• High customer volumes. The more people come through the door, the more likely someone is missed.
• Proving consistency. Even where staff do challenge well, it can be hard to show regulators and licensing authorities that the policy is applied consistently.

How AI age estimation can support Think 25

AI age estimation analyses a face in a camera feed and produces an estimate of apparent age — how old the person appears to be. It does not determine anyone's actual age.

ClientScan estimates apparent age in real time from a standard camera at your entrance. If the estimate falls within a threshold you configure — for example, customers who may appear under 25 — staff receive an alert on-screen, by WhatsApp or by email.

This is decision-support technology. The alert is a prompt, not a decision: the member of staff remains responsible for judging whether an ID check is appropriate, and for checking acceptable proof of age before the customer gambles. Read more about ClientScan's age verification capability.

How it works in practice

The process is deliberately simple:

1. Customer enters the venue.
2. Camera detects the face as they walk through the entrance.
3. AI estimates apparent age in real time.
4. Customer falls within the configured age threshold — for example, may appear under 25.
5. Staff receive an alert, on-screen, by WhatsApp or by email.
6. Staff determine whether proof of age should be requested, and follow your normal ID-checking procedure.

Good results depend on good images. Our camera placement guide explains how to position cameras and manage lighting at the entrance.

Where Think 25 age assurance can be used

Betting shops

Betting shops often run with one or two staff, and customers may go straight to machines or the counter. Automated prompts help staff apply betting shop age verification consistently, including at busy times such as major sporting events.

Adult gaming centres

Long opening hours, small teams and customers who never visit a counter make adult gaming centre age verification particularly challenging — and AGCs were highlighted in the Commission's consultation.

Bingo halls

Session start times bring many customers through the door at once. Alerts help staff focus their checks on the customers who most need them in bingo halls.

Casinos

Casinos typically check ID at reception, but alerts can extend consistent age assurance to other entrances and gaming floors in casinos.

Think 25, Think 21 and Challenge 25

You will see several terms used across retail and leisure. Think 21 was the previous threshold in many gambling venues; Challenge 25 is a widely used retail scheme name with a similar principle. Organisations may use different thresholds and terminology depending on their sector and internal policy.

The common thread is a threshold above the legal age that triggers a check. AI age estimation supports this because the threshold is configurable: the system prompts staff according to whatever apparent-age threshold your policy sets.

Privacy and responsible deployment

Age estimation processes images of people's faces, so it must be deployed with care. Key considerations include:

• Transparency. Tell customers clearly, before they enter, that cameras and age estimation are in use and why.
• Proportionality. Use the technology for a defined purpose — supporting your age policy — and only where it is needed.
• Responsible processing. Process only the data required to generate an alert for staff.
• Appropriate retention. Set clear retention periods for any images or alert records, and delete them when no longer needed.
• Access controls. Restrict who can see alerts and records, and keep systems secure.
• Data protection. Assess the processing in a Data Protection Impact Assessment, and take account of the ICO's guidance on biometric recognition↗, particularly where the same system also recognises individuals.
• Human oversight. Staff — not the system — decide what happens next.

Not legal advice. Every deployment is different. Involve your Data Protection Officer or adviser. Our UK GDPR guide covers the main questions.

Test purchasing: making results count

The Commission's test purchasing guidance↗ expects operators to use results to improve. A good programme tests every premises at different times and on different shifts, records and submits results as required, follows up failures with retraining, and looks for patterns — particular sites, times or entry points where challenges are missed. Consistent alert records can help you identify those patterns.

Benefits for gambling operators

Used responsibly, AI age estimation can offer:

• More consistent application of age policies, regardless of who is on shift.
• Support for frontline staff, especially when they are busy or working alone.
• Faster identification of customers who may require an age check, ideally before they start to gamble.
• Reduced reliance on subjective visual assessment alone, while keeping staff judgement at the centre.
• Multi-site deployment, with the same threshold applied across your estate.
• Operational insight and auditability, through records of alerts that support your internal reviews and conversations with licensing authorities.

The same entrance camera can also support self-exclusion compliance, so one installation helps with two of your most important duties.