Think 25 in gambling venues: age verification after the 2024 rule changes

Preventing underage gambling is a fundamental licensing objective. In 2024 the Gambling Commission tightened the rules for land-based venues, and operators are now expected to challenge more customers, test themselves more often and show that their controls work.

What changed on 30 August 2024

Following its consultation, the Commission confirmed↗ two changes to the 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. Staff must now ask for ID from anyone who appears to be under 25.
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 Commission said it was proceeding "exactly as proposed" after considering consultation responses.

Why the rules were tightened

Test purchasing has been required for most land-based licensees since 2015. It uses young-looking adults aged 18–21 to check whether staff challenge them. 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.

Raising the threshold to 25 creates a wider safety margin: a 17-year-old is far more likely to be challenged if staff are looking for anyone who might be under 25.

The practical problem

Think 25 asks staff to make a snap judgement about age, for every customer, all day. That is hard when:

• a venue is busy, or staffed by one person;
• customers enter while staff are serving someone else;
• people deliberately avoid the counter, heading straight to machines;
• judging age is inherently subjective — and inconsistent between colleagues.

How technology can help

Age estimation technology analyses a face and estimates an age range in real time. Used well, it acts as a consistent prompt: when a customer who may be under 25 enters, staff are alerted and can ask for ID before the customer starts to gamble.

ClientScan provides age validation in under one second as part of the same system used for self-exclusion, so a single camera at the entrance supports both duties.

It is important to be clear about what this is and isn't:

• It supports, not replaces, ID checks. An alert means "check ID", not "refuse" or "allow".
• It helps evidence your controls. Consistent prompts and records support your test purchasing results and conversations with licensing authorities.
• It must be deployed lawfully. Facial analysis involves personal data; see our UK GDPR guide.

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 results and submits them as required;
• follows up failures with retraining, not only reminders;
• looks for patterns — particular sites, times or entry points where challenges are missed.

Key takeaways

• Think 25 now applies across all main land-based gambling sectors.
• Test purchasing applies to smaller venues too.
• Technology can prompt staff consistently, but ID checks remain the control.
• The same entrance camera can support age verification and self-exclusion.