UK Gambling Commission Suspends Tom Horn Gaming Licences for LCCP Breaches

The UK Gambling Commission suspended Tom Horn Gaming’s gambling software and game host licences effective 8 September 2026. The regulator’s action followed the identification of breaches across several sections of the Licence Conditions and Codes of Practice (LCCP), prompting an immediate halt to the supplier’s UK operations.

Details of the Gambling Commission’s licence suspension

The Gambling Commission undertook a review of Tom Horn Gaming’s operating licence and determined there were breaches in four LCCP areas:

1. General and regulatory requirements, including providing timely information and submitting quarterly regulatory returns.
2. Reporting key events—covering incidents or changes with significant impact on the licensee’s business or structure.
3. Qualified persons and qualifying positions, specifically the notification process when individuals are appointed or step down from these key positions.
4. Technical standards (LCCP requirement 2.3.1), which mandate compliance with approved testing timelines and procedures.

The regulator did not specify the precise failures under each section. A further compliance gap was identified regarding ordinary code provision 8.1.1, which, while not a formal LCCP requirement, sets out expectations for open and cooperative communication between licence holders and the Commission.

“The Commission expects licensees to work with the Commission in an open and cooperative way and to inform the Commission of any matters that the Commission would reasonably need to be aware of in exercising its regulatory functions," the GC illustrated in code 8.1.1.

Background: Tom Horn Gaming and UK market activity

Tom Horn Gaming was founded in 2008 as Tom Horn Enterprise, rebranding in 2016 and receiving its Gambling Commission licences in October 2017—a year after being licensed by the Malta Gaming Authority. The company’s publicly available timeline highlights its UKGC licence as a major milestone but does not currently list the United Kingdom as an operational market on its website.

While the business’s profile has included both gambling software and game hosting for casino operators, the UK licence suspension now prevents Tom Horn Gaming from providing these services in the GB-regulated market.

LCCP breaches and operational implications

The LCCP framework covers core obligations for all UK-licensed gambling suppliers, with breaches triggering substantial regulatory response including suspension or revocation of licences. In Tom Horn Gaming’s case, the Gambling Commission cited breaches tied to:

• Submission and accuracy of regulatory returns
• Proper reporting of events with material business impact
• Notification of changes among persons in qualifying positions
• Adherence to technical standards for game and platform testing
• Cooperative and transparent engagement with the Commission (as per ordinary code 8.1.1)

The Commission enforced the suspension under sections 117(e) and 118(1) of the UK Gambling Act, referencing its licensing, compliance and enforcement policy, indicative sanction guidance, and penalty principles.

Regulatory context for software suppliers

Tom Horn Gaming joins a list of suppliers facing enforcement for LCCP non-compliance. The Gambling Commission’s approach signals continued prioritisation of open reporting, regulatory returns, and strict adherence to technical standards within the UK’s gambling frameworks.

The ordinary code 8.1.1, while not technically binding, is repeatedly cited in recent GC actions as critical to regulatory trust. Suppliers are expected to notify the regulator of issues or changes that could affect the compliance or viability of licensed operations. Non-cooperation, or failure to proactively inform the regulator of material developments, increasingly draws scrutiny.

For other businesses seeking to maintain a presence in the UK market, maintaining strong governance and communications with the Gambling Commission is a clear compliance necessity.

Summary and next steps

Tom Horn Gaming’s licences for gambling software and game hosting have been suspended and the company is no longer authorised to provide regulated gaming software in the UK. EGR has reached out to Tom Horn Gaming for comment, but no public statement has yet been issued.

Ongoing developments in regulation and enforcement action across the UK market underline the importance for all licensees of robust reporting, transparent operations, and full alignment with both LCCP requirements and good practice recommendations from the Gambling Commission.