4 training duties across 2 instruments binding Gaming & Gambling, plus 10 that bind you whatever your sector — statute, rulebook, statutory guidance and licence conditions. Every one traced to its clause, its date and its published source, and each one labelled with what makes it a training duty.
The provision you are probably working to is the advisory one. The binding one asks you to prove the training worked.
Gambling is the only sector in this series where the regulator attaches an efficacy test to a training duty. Everywhere else, the obligation is discharged by delivering training and keeping a record. Here you must test-purchase against your own controls and hand the results to the Commission.
It is also the sector where the binding and advisory provisions are most easily swapped. Induction and refresher training — the thing most operators build their programme around — sits in an ordinary code provision. What binds is a different provision, with different content, and a different proof.
Each clause carries a label saying why it is a training duty. Where the instrument does not use the word, we cite the guidance or the case that makes training the way you discharge it. Where we cannot cite anyone, it is not listed as a training duty at all.
| Clause | Who must be trained or assessed | What is required | Interval | Evidence required |
|---|---|---|---|---|
| Money Laundering Regulations 2017 | ||||
| Regulation 24(1)(a) and 24(1)(b), with regulation 8(2)(h) says train | named role — 'relevant employees' as defined at reg 24(2), plus agents whose work is of the kind described at 24(2) | Quoted, 24(1): a relevant person must "(a) take appropriate measures to ensure that its relevant employees [and any agents it uses...] are— (i) made aware of the law relating to money laundering, terrorist financing and proliferation financing, and to the requirements of data protection, which are relevant to the implementation of these Regulations; and (ii) regularly given training in how to recognise and deal with transactions and other activities or situations which may be related to money laundering, terrorist financing or proliferation financing; (b) maintain a record in writing of the measures taken under sub-paragraph (a), and in particular, of the training given to its relevant employees". | "Regularly" — no interval stated. | EXPRESS. 24(1)(b) requires a written record of the measures and, in particular, of the training given. |
| Licence Conditions and Codes of Practice (LCCP), Gambling Commission | ||||
| Social responsibility code provision 3.2.1 (Casinos) says train | all staff — the duty is that ALL staff understand their responsibilities for preventing underage gambling | Quoted: "Licensees must take all reasonable steps to ensure that all staff understand their responsibilities for preventing underage gambling. This must include appropriate training which must cover all relevant prohibitions against inviting children or young persons to gamble or to enter gambling premises, and the legal requirements on returning stakes and not paying prizes to underage customers." The provision also requires designated entrance supervisors whose responsibilities "include ensuring compliance with this section of the code". AND, in the same provision: "Licensees must conduct test purchasing or take part in collective test purchasing programmes as a means of providing reasonable assurance that they have effective policies and procedures to prevent underage gambling, and must provide their test purchase results to the Commission." | None. The measure is that all staff understand, tested by test purchasing rather than by interval. | EXPRESS AND UNUSUAL — test purchase results must be provided to the Commission. The regulator asks for evidence that the training WORKED, not evidence that it happened. |
| Ordinary code provision 3.2.2 (Casinos) guidance LCCP ordinary code provision 3.2.2 itself names the training: "licensees should have, as a minimum, policies for induction training and refresher training" — read at source 2026-08-12. Recorded as guidance-based rather than express BECAUSE it is an ordinary code provision: the binding duty is SR code 3.2.1, and 3.2.2 describes how the Commission expects it to be discharged. ⚠️ The precise enforceability difference between social responsibility code provisions and ordinary code provisions is stated in the Gambling Act 2005 and the LCCP introduction, NEITHER of which has been read — see not_yet_searched. | all staff, in respect of preventing underage gambling | Quoted: "In providing training to staff on their responsibilities for preventing underage gambling, licensees should have, as a minimum, policies for induction training and refresher training." Note "should", not "must" — this is an ordinary code provision. It is the ONLY place in this sector's map where induction and refresher training are named, and it is the non-binding limb. | Induction plus refresher — but no interval is attached to 'refresher', and the provision is an ordinary code. | Not specified. |
| Licence condition 14.1.1 (Access to premises) says train | all staff who may encounter a Commission enforcement officer | Quoted in full: "Licensees must have and put into effect policies and procedures (including staff training programmes) designed to ensure that their staff co-operate with the Commission's enforcement officers in the proper performance of their compliance functions and are made aware of those officers' rights of entry to premises contained in Part 15 of the Act." | None. | Not specified beyond having the policies and procedures and putting them into effect. |
10 further obligations sit outside Gaming & Gambling regulation and bind you as an employer or as a deployer of AI. They are the ones a sector-by-sector review misses, because nobody who reads only their own rulebook ever reaches them.
| Clause | Who must be trained or assessed | What is required | Interval | Evidence required |
|---|---|---|---|---|
| EU AI Act (Reg (EU) 2024/1689) | ||||
| Article 4 (AI literacy) says train | defined population — quoted from the pre-amendment text: "their staff and other persons dealing with the operation and use of AI systems on their behalf" | AS ENACTED: providers and deployers were to take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account technical knowledge, experience, education and training, the context of use, and the persons on whom the systems are used. AS AMENDED from 2026-07-27 by the Digital Omnibus on AI: AI literacy remains an obligation on providers and deployers, but no specific or 'sufficient' level is mandated; the Commission and Member States take a stronger role in promoting AI literacy. The obligation on deployers of HIGH-RISK AI systems to ensure staff are trained for human oversight remains in place. | none specified | none specified |
| Article 26(2) says train | named population — the natural persons assigned to exercise human oversight | Quoted: "Deployers shall assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support." | none specified | none specified in this paragraph |
| Employment Rights Act 2025 | ||||
| Whole Act — training provisions at s.65 and related says train | named role — trade union equality representatives, not the general workforce | The Act's training provisions concern whether a trade union equality representative has undergone sufficient training to carry on those activities, with notice requirements on the union and reference to a relevant ACAS or Secretary of State Code of Practice. It is not a mandatory workforce training duty of the kind the rest of this map records. | none specified | Written notice from the trade union to the employer |
| Equality Act 2010 | ||||
| Section 109(4), with section 109(1) case law Allay (UK) Ltd v Gehlen [2021] UKEAT/0031/20 — stale or inadequate training defeats the s.109(4) 'all reasonable steps' defence, making training the operative discharge. | all staff — the defence turns on steps taken to prevent employees doing discriminatory acts | An employer is liable for anything done by a person in the course of their employment. Quoted from 109(4): "In proceedings against A's employer (B) in respect of anything alleged to have been done by A in the course of A's employment it is a defence for B to show that B took all reasonable steps to prevent A—(a) from doing that thing, or (b) from doing anything of that description." | none specified | The employer must SHOW the steps taken. The burden sits with the employer. |
| UK GDPR | ||||
| Article 24, read with Article 5(2) guidance UK GDPR Article 39(1)(b) — read at source 2026-08-12 — names staff training as an element of compliance with the Regulation: the data protection officer must "monitor compliance with this Regulation... including the assignment of responsibilities, awareness-raising and training of staff involved in processing operations, and the related audits". LIMIT OF THIS CITATION, stated plainly: Article 39 applies only where Article 37 requires a DPO to be appointed, so it does not by itself establish a training duty for every controller. It establishes that the Regulation treats staff training as part of compliance. The unconditional citation would be the ICO Accountability Framework, which has NOT been read — see not_yet_searched. | not specified — training is not expressly named in Article 24 | Quoted: "the controller shall implement appropriate technical and organisational measures to ensure and to be able to demonstrate that processing is performed in accordance with this Regulation." Those measures must be reviewed and updated where necessary, and are to include appropriate data protection policies where proportionate to the processing activities. Article 5(2) supplies the accountability principle itself: "The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1" — that is, with all six data protection principles: lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; and integrity and confidentiality. | measures to be reviewed and updated where necessary — no interval | The controller must be able to DEMONSTRATE compliance. This is the accountability limb. |
| The Regulatory Reform (Fire Safety) Order 2005 | ||||
| Article 21, with articles 3 and 6 says train | all staff — quoted: "his employees" | Quoted, 21(1): the responsible person "must ensure that his employees are provided with adequate safety training (a) at the time when they are first employed; and (b) on their being exposed to new or increased risks because of" transfer or change of responsibilities, new or changed work equipment, new technology, or a new or changed system of work. 21(2): that training must "(a) include suitable and sufficient instruction and training on the appropriate precautions and actions to be taken by the employee in order to safeguard himself and other relevant persons on the premises; (b) be repeated periodically where appropriate; (c) be adapted to take account of any new or changed risks; (d) be provided in a manner appropriate to the risk identified by the risk assessment; and (e) TAKE PLACE DURING WORKING HOURS." | Trigger-based, not periodic: on first employment AND on each of four listed changes. "Repeated periodically where appropriate" — no interval stated. | none specified in the article |
| The Management of Health and Safety at Work Regulations 1999 | ||||
| Regulation 13(2), with 13(1) and 13(3) says train | all staff — every employee, on recruitment and again on each triggering change | Quoted, 13(2): "Every employer shall ensure that his employees are provided with adequate health and safety training— (a) on their being recruited into the employer's undertaking; and (b) on their being exposed to new or increased risks because of— (i) their being transferred or given a change of responsibilities within the employer's undertaking, (ii) the introduction of new work equipment into or a change respecting work equipment already in use within the employer's undertaking, (iii) the introduction of new technology into the employer's undertaking, or (iv) the introduction of a new system of work into or a change respecting a system of work already in use within the employer's undertaking." 13(1) separately requires the employer, "in entrusting tasks to his employees, [to] take into account their capabilities as regards health and safety." | No fixed interval. The duty is TRIGGER-BASED — on recruitment, and on each of the four changes listed in 13(2)(b). | Not specified in the regulation itself. |
| Health and Safety at Work etc. Act 1974 | ||||
| Section 2(2)(c), with section 2(1) says train | all staff — scoped by what is 'necessary to ensure' their health and safety | Quoted, s.2(2)(c): the employer's general duty extends in particular to "the provision of such information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of his employees." This is the primary-legislation parent of the MHSWR reg 13 duty. Note the double qualifier: training is owed only so far as it is BOTH 'necessary to ensure' health and safety AND 'reasonably practicable'. | None. The measure is necessity, not interval. | Not specified in the section. |
| Council Directive 89/391/EEC (the Framework Directive) on the introduction of measures to encourage improvements in the safety and health of workers at work | ||||
| Article 12(1) and 12(4) says train | all staff — 'each worker' | Quoted, 12(1): "The employer shall ensure that each worker receives adequate safety and health training, in particular in the form of information and instructions specific to his workstation or job: — on recruitment, — in the event of a transfer or a change of job, — in the event of the introduction of new work equipment or a change in equipment, — in the event of the introduction of any new technology. The training shall be: — adapted to take account of new or changed risks, and — repeated periodically if necessary." Quoted, 12(4): "The training referred to in paragraphs 1 and 3 MAY NOT BE AT THE WORKERS' EXPENSE... The training referred to in paragraph 1 MUST TAKE PLACE DURING WORKING HOURS." | No fixed interval. Trigger-based on four named events, PLUS two standing qualities the UK implementation does not spell out as clearly: adapted to new or changed risks, and "repeated periodically if necessary". | Not specified in Article 12. |
| Article 12(2) says train | named population — workers from OUTSIDE undertakings and/or establishments engaged in work in your undertaking. Contractors, agency staff, visiting engineers, maintenance crews. | Quoted in full: "The employer shall ensure that workers from outside undertakings and/or establishments engaged in work in his undertaking and/or establishment HAVE IN FACT RECEIVED appropriate instructions regarding health and safety risks during their activities in his undertaking and/or establishment." | None — triggered by the outside workers being engaged in work in your undertaking. | Not specified, but note the wording: the employer must ensure they "have in fact received" the instructions. That is a verification duty, not a provision duty — it is not discharged by having issued something. |
Ordinary code provision 3.2.2: “In providing training to staff on their responsibilities for preventing underage gambling, licensees should have, as a minimum, policies for induction training and refresher training.”
Social responsibility code provision 3.2.1: “Licensees must take all reasonable steps to ensure that all staff understand their responsibilities for preventing underage gambling. This must include appropriate training which must cover all relevant prohibitions against inviting children or young persons to gamble or to enter gambling premises, and the legal requirements on returning stakes and not paying prizes to underage customers.”
Induction-and-refresher is the ordinary code. The mandated content is the social responsibility code. A firm can run a textbook induction-and-refresher programme and still not have delivered the two subjects 3.2.1 names.
Also in 3.2.1: “Licensees must conduct test purchasing or take part in collective test purchasing programmes as a means of providing reasonable assurance that they have effective policies and procedures to prevent underage gambling, and must provide their test purchase results to the Commission.”
Read that against how training is normally evidenced. A completion report proves attendance. A failed test purchase proves the training did not work — and the Commission receives it either way. This is the only duty in this series where the proof is an outcome rather than a record.
Licence condition 14.1.1 applies to all operating licences, not just casinos: “Licensees must have and put into effect policies and procedures (including staff training programmes) designed to ensure that their staff co-operate with the Commission’s enforcement officers… and are made aware of those officers’ rights of entry to premises contained in Part 15 of the Act.”
It is a licence condition, so it binds directly rather than through a code. And it is nobody’s idea of compliance training — it is training staff on a regulator’s statutory power of entry, filed in a section about premises access, which is exactly why a search for training obligations does not surface it.
Regulation 8(2)(h) of the Money Laundering Regulations 2017 lists casinos among the relevant persons. It does not list betting, bingo, arcades or lotteries.
So the regulation 24 training duty — including its express requirement to maintain a record in writing of the training given — reaches the casino product and not, by that route, the rest of the estate. The same split runs through the LCCP: 3.2.1 and 3.2.2 are the casino code provisions. Parallel provisions exist for betting, bingo, arcades, lotteries and remote, and we have declared those unread rather than assume they say the same thing.
This map states what it did not check as well as what it did. A map that quietly omits its own gaps is worth less than one that marks them.
4 obligations across 2 instruments, each read directly from the published source on 2026-08-12.
Recorded because “we searched and found nothing” is a different fact from “we did not search”.
Their absence is not evidence that they contain no training duty.
Ten minutes on where your obligations actually sit. Fifteen watching a module built live from your own source documents. Five on whether there is a next step. Nothing to prepare and nothing to send beforehand.