Official regulatory body • Gambling Commission subsidiary
Home Register of Violations Violation Report #006
Compliance Assessment Report • Severe Non-Compliance

www.freespinstoday.uk/no-deposit-bonuses

Affiliate review site
Active violation
8 critical violations

This URL has been assessed as severely non-compliant with UK gambling regulations following comprehensive evaluation against 47 compliance indicators. Eight critical violations identified - the highest number in current Register of Violations - spanning age verification, operator licensing, and responsible gambling categories. Systematic failures across multiple regulatory domains indicate fundamental deficiencies in compliance framework implementation.

Assessment Summary

Assessment Date 03 October 2025
Published Date 28 October 2025
Critical Violations 8 of 47 indicators
Weighted Score 52%
Classification Non-compliant (N)

⚠️ HIGHEST VIOLATION COUNT: This URL has the most critical violations in the current Register of Violations, indicating severe and systematic non-compliance requiring immediate comprehensive remediation.

Assessment Timeline

1
Assessment Completed
03 October 2025
2
Operator Notified
06 October 2025
3
Appeal Period Expired
03 November 2025 (28 days)
4
Published to Register
28 October 2025

Violation Categories Overview

2

Age Verification

AV-01, AV-02

No visible 18+ warnings and no age verification gate implemented before content access - fundamental child protection failures.

2

Operator Licensing

OL-01, OL-03

Promotion of multiple unlicensed operators through "no deposit bonus" offers - direct breach of GA 2005 s.330.

4

Responsible Gambling

RG-01, RG-02, RG-03, RG-09

Complete absence of responsible gambling infrastructure - no BeGambleAware branding, helpline links, GamStop information, or support service signposting.

Systematic non-compliance pattern: The breadth of violations across multiple regulatory categories indicates fundamental failure to implement UK gambling compliance framework. This is not isolated technical oversight but systematic absence of required consumer protections, particularly concerning given site explicitly targets UK market via .uk domain and "no deposit bonus" content popular with financially vulnerable individuals.

Critical Violations Identified

Detailed analysis of 8 critical regulatory violations (showing first 3 below - full documentation available in complete report)

AV-01

Prominent 18+ warning visible on landing page without scrolling

Legal basis: LCCP 3.2.3(1) - Protection of children and young persons
Critical

Violation Description

No visible 18+ age warning present anywhere on /no-deposit-bonuses landing page. Page header contains only site logo, navigation menu, and "Sign Up" call-to-action - no age-related messaging visible above-the-fold. Hero section promotes "Free Spins No Deposit Required" without age qualification. Tested on desktop (1920×1080), tablet (768×1024), and mobile (375×667) viewports - no 18+ warnings visible on any device without scrolling. LCCP Provision 3.2.3(1) requires prominent display of 18+ warnings on all gambling content.

Assessment Evidence: Manual inspection conducted 03 October 2025 at 10:15 GMT across three viewport sizes. Above-the-fold content captured via screenshots. No age verification symbols, 18+ text warnings, or age-related disclaimers identified. Footer (below-the-fold) contains small "18+" text in light grey - fails prominence requirement.

Remediation Guidance

To achieve compliance:

  • 1. Add prominent 18+ symbol or text warning in header (above-the-fold, all pages)
  • 2. Use contrasting colors for visibility (red/orange on white)
  • 3. Minimum size: 24px height for text warnings, 32px for icon-based
  • 4. Ensure mobile visibility (fixed header position recommended)
AV-02

Age verification gate present before content access (affiliate sites)

Legal basis: LCCP 3.2.3(2) - Age verification for affiliate sites
Critical

Violation Description

No age verification gate implemented at any point in user journey. Users can immediately access casino reviews, "no deposit bonus" claim instructions, and operator affiliate links without age confirmation. Tested access via: direct URL entry, Google search result click, and social media referral link - no age gate interception on any entry path. Site allows unrestricted browsing of gambling content and affiliate link clicking without age verification step. Particularly concerning given "no deposit" focus attracts users seeking risk-free gambling - demographic likely includes financially vulnerable individuals and potentially minors seeking to gamble without payment information.

Assessment Evidence: Tested site access from fresh browser session (cleared cookies/cache) across 5 different entry points. Zero age verification prompts encountered. Clicked through to 8 different casino affiliate links - all redirected to operator sites without age gate interception by freespinstoday.uk.

Remediation Guidance

Implement age verification gate:

  • 1. Modal overlay or dedicated landing page requiring age confirmation on first visit
  • 2. Clear "I am 18 or over" checkbox + confirmation button
  • 3. Cookie/session storage to prevent repeated gates during same visit
  • 4. Link to support resources for under-18s
OL-01

All promoted operators hold valid UK Gambling Commission licence

Legal basis: Gambling Act 2005 s.33 - Operating without licence offence
Critical

Violation Description

Site promotes 11 unlicensed operators through "no deposit bonus" listings on assessed page. Featured operators include: "FreeSpinsCasino" (Curacao license 8048/JAZ2020-015), "NoDepositKings" (unlicensed - no regulatory information displayed), "BonusSlots247" (Curacao license 365/JAZ), "InstantWins Casino" (Malta MGA without UK remote licence), and 7 additional operators verified as lacking UK Gambling Commission authorization. Cross-referenced all 18 operators featured on page with GC public register (accessed 03 October 2025) - only 7 hold valid UK licenses. Site presents unlicensed operators without disclosure of licensing jurisdiction or warnings about legality for UK players. "No deposit bonus" promotion particularly harmful as directs users to unlicensed sites offering free play designed to convert to real-money gambling.

Assessment Evidence: /no-deposit-bonuses page lists 18 casino operators. Verified each via GC register API and operator website licensing disclosure. Results: 7 UK-licensed, 6 Curacao-licensed only, 3 Malta MGA without UK remote authority, 2 completely unlicensed (no regulatory info). Unlicensed operators featured prominently in "Top No Deposit Bonuses" table at page top.
Consumer Protection Failure: 61% of promoted operators lack UK licensing. Users directed to gambling sites without UKGC consumer protections including GamStop, ADR schemes, fund safeguarding, and responsible gambling tools.

Remediation Guidance

Immediate corrective actions:

  • 1. Remove ALL unlicensed operators from site immediately (11 operators identified)
  • 2. Verify remaining 7 UK-licensed operators via GC register to confirm ongoing validity
  • 3. Implement automated licence verification in CMS workflow - prevent unlicensed operator publication
  • 4. Add editorial policy: "We exclusively promote UK Gambling Commission licensed operators"
  • 5. Display GC license numbers for all promoted operators (transparency measure)
  • 6. Monthly audit of all promoted operators for license validity

Additional Critical Violations (5 remaining)

Full detailed analysis of remaining violations included in complete assessment report. Summary of additional critical violations:

OL-03

No promotion of unlicensed operators

Systematic promotion of Curacao and Malta-only licensed operators without UK authorization. "International Bonuses" section exclusively features unlicensed operators.

RG-01

BeGambleAware branding absent

No BeGambleAware logo or "When the fun stops, stop" messaging present anywhere on site. Complete absence of responsible gambling branding.

RG-02

Helpline links absent

No National Gambling Helpline (0808 8020 133) or GamCare links visible on any pages. Users cannot access support resources.

RG-03

GamStop information absent

No information about GamStop self-exclusion scheme anywhere on site. No links to gamstop.co.uk. Users seeking self-exclusion cannot find resources.

RG-09

Support service links absent

No links to BeGambleAware, GamCare, or Gambling Therapy. Complete absence of signposting to recognized gambling support services.

Complete report access: Full detailed analysis of all 8 critical violations including specific evidence, legal basis, and comprehensive remediation guidance available via formal request to BeGamblewareSlots. Operator notification package included complete evidence documentation for all violations.

Assessment Team

MW

Marcus Williams

Senior Compliance Analyst
Primary Assessor
40-hour methodology training completed (September 2024)
Inter-rater reliability κ = 0.95
163 assessments completed to date
NH

Nina Harper

Compliance Analyst
Secondary Verifier (Dual Verification Protocol)
40-hour methodology training completed (September 2024)
Inter-rater reliability κ = 0.94
128 assessments completed to date

Dual verification protocol: This assessment was conducted independently by two trained analysts. Both analysts reached consensus on all 8 critical violation determinations. Given the exceptionally high violation count, assessment was additionally reviewed by Senior Technical Advisor (Dr. Helen Morrison, methodology development lead) to ensure accuracy and consistency with assessment framework. Assessment methodology version 2.1 applied throughout. Evidence package includes comprehensive screenshots, GC register API verification logs, and detailed violation documentation for all 47 assessed indicators.

Next Steps for Site Operator

Comprehensive Remediation Required

Implement corrective actions across all three violation categories: age verification, operator licensing, and responsible gambling. Given scale of non-compliance (8 critical violations), recommend engaging compliance consultant to ensure systematic implementation. Priority: immediate removal of 11 unlicensed operators to halt ongoing GA 2005 s.330 breach.

Comprehensive compliance guide

Request Reassessment

Following complete remediation, submit evidence package demonstrating compliance with all 8 violated indicators plus documentation of systematic compliance framework implementation. Reassessment will evaluate all 47 indicators comprehensively. Target timeline: 120 days from evidence submission given remediation scope.

Request reassessment

Important Information

Appeal rights: You may submit formal appeal to Independent Advisory Board within 30 working days of this report date (deadline: 27 November 2025). Appeals must include supporting evidence demonstrating compliance at time of assessment for each contested violation. However, given breadth of violations across multiple categories, successful appeal would require demonstrating systematic assessment error - threshold rarely met.

Regulatory referral: This case has been referred to the Gambling Commission due to exceptionally high violation count and serious nature of violations (promotion of 11 unlicensed operators, absence of age verification, complete lack of responsible gambling infrastructure). Referral includes complete assessment evidence package and recommended enforcement actions. Commission may initiate independent investigation and enforcement proceedings.

Criminal liability consideration: Promotion of unlicensed operators may constitute offence under Gambling Act 2005 s.330 (advertising unlicensed gambling). Violations carry potential unlimited fines. Recommend seeking legal advice regarding exposure, particularly given systematic nature of unlicensed operator promotion through "no deposit bonus" listings.

Financial impact: Presence on Register of Violations with highest violation count may impact: affiliate revenue (UK-licensed operators may terminate partnerships due to compliance failures), search engine visibility (algorithm treatment of non-compliant gambling content), and payment processor relationships (increased due diligence scrutiny). Immediate remediation critical to minimize ongoing financial harm.

Public register: This URL will remain on Register of Violations until either (a) successful appeal demonstrates systematic assessment error (unlikely given violation breadth), or (b) successful reassessment following comprehensive remediation. Presence on register is publicly searchable and will be discovered by due diligence reviews, compliance audits, and investigative journalism. Reputational impact likely significant and persistent until remediation completed.

Domain consideration: .uk TLD signals UK market focus. Operating UK-targeting gambling affiliate site with systematic non-compliance creates particularly egregious regulatory breach. Consider whether business model viable given compliance investment required or whether domain/business model pivot necessary.

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