Since Tim Miller’s speech at the Betting and Gaming Council Annual General Meeting on the 26^th of February 2026, there has been a stir in the industry about the Gambling Commission starting to consider how crypto-assets could fit within its regulatory framework.  For many years the UK Gambling Commission have been receiving “interest from stakeholders about the use of crypto-assets, such as Bitcoin or blockchain technology” either as a currency to fund a gambling business or as a means to deliver gambling products. Indeed, the UK Gambling Commission’s website set out its position in March 2023.

For licence applications involving crypto-assets, the UK Gambling Commission’s stated approach to assessing crypto-asset source of funds was that they needed to be provided with sufficient evidence to “be assured the business was not being funded by the proceeds of crime”. This was and is now, no different to how they assess any other source of funds, so crypto-asset applications would have needed the same level of assurance as other applications – no more, no less.

For typical applications and due diligence source of funds checks, evidence can be provided to support the investment being built up over time as savings (being funded by income such as salary or inheritance) or being successful stock investments traded on regulated platforms.  However, when it comes to crypto-asset funded applications, the difficulty crypto-assets have is the lack of regulation around them and an applicant’s ability to provide complete and satisfactory evidence to answer the questions on where the funds originated. The lack of regulation meant that crypto-assets could be traded on platforms anonymously leading to a failure by applicants to provide sufficient comfort the crypto-assets weren’t linked to criminality. Also meaning granting a licence would put the licencing objectives at risk, notably keeping crime out of gambling.

In terms of gambling products, during the last two crypto cycles we have seen many unique forms of gambling rise and fall in popularity such as metaverse casinos, NFT betting, and crypto lotteries.  More recently certain game formats have become more established in the industry such as crash games and Plinko. These formats have gained traction by marketing via streaming platforms, social media, and endorsements by well-known influencers.  The best example of this model is Stake.com, who are now widely considered to be the world’s largest crypto casino and one of the most visited globally.

This rise in crypto-asset related products has not been reflected in the UK due to restrictions that have meant these new game types were not permitted as they would be considered too high risk from a player protection perspective, not aligning to the remote technical standards along with not sufficiently meeting KYC and AML regulation.

Social responsibility aside, the difficulty UK crypto-asset related applications and products face have derived from a lack of historical regulation on crypto-assets, but recent times have brought about regulation with some countries already implementing regulatory frameworks and other countries in the process of doing so.

In the UK the Financial Conduct Authority (FCA) recently announced it is implementing a crypto focused regulatory framework that is scheduled to go live in 2027.  The introduction of policy from the UK’s financial conduct regulator will bring crypto asset activities within the FCA’s remit requiring authorisation and oversight, this will reshape how it is viewed in the UK and the gambling sector.

If the proposed regulatory framework is implemented as intended, it will address some of the key barriers that have historically prevented crypto from being used in regulated gambling. For instance, it would set clearer standards for transaction transparency, increase AML and financial crime regulations, and improve consumer protection, which would help reduce the some of the main risks that have typically made crypto a poor fit for the regulated gambling industry.

The Gambling Commission has always worked closely with the FCA, reflecting the significant connections between the regulated gambling and financial sectors in the UK. It is unlikely to be a coincidence that the Gambling Commission is now indicating that it may reconsider its approach to crypto assets at the same time as the emergence of crypto regulation.  This suggests the Commission will be keeping a close eye on the FCA’s crypto regulation road map as it reconsiders its own position. Any change in UK gambling regulation could open the door to a new wave of gambling products and game formats potentially entering the UK market and should remove some of the barriers applicants may have previously experienced.

Here at Luke ARC our expectation is that any crypto-asset regulation will include requirements for firms to carry out KYC and source of funds checks, amongst other things, that will inevitably increase the amount and quality of evidence a prospective applicant could provide to the Gambling Commission if it sought a licence.

In addition, we believe the Commission will likely face difficulty fitting the novel crypto-based products seen in the global industry into the current UK regulatory format. Particularly given the strict requirements around online controls and responsible gambling. These areas present potential difficulties for crypto-based products under current regulatory expectations. However, it’s clear that if crypto assets are made acceptable in the long term, this is likely to influence not only payment methods but also the types of gambling products offered within the regulated market.

If you have any questions about crypto-based gambling and the UK regulatory perspective on it, please do not hesitate to Contact Us.

Credit to Luke ARC Consultants Stephen Spencer and Lewis Stewart.