Personal Management Licence vs Personal Functional Licence: What's the Difference?

Why personal licences exist at all

An operating licence covers the company. But the Gambling Commission also wants assurance about the individuals who run and staff a gambling business, particularly those who could influence how safely and fairly it operates. That assurance comes through personal licences held by named individuals, not the corporate entity.

There are two distinct categories: the Personal Management Licence (PML) and the Personal Functional Licence (PFL). They look similar on paper, both are issued to individuals and both involve fit-and-proper checks, but they cover very different roles and carry different obligations. Confusing the two, or assuming one covers what the other does, is a common compliance gap in growing operators.

What a Personal Management Licence covers

A PML applies to people in specified management positions who exercise a genuine influence over the way a licensed business is run. Think directors, senior compliance officers, heads of key functions such as anti-money laundering, safer gambling or marketing, and anyone else whose decisions materially shape how the operator meets its licence conditions.

The underlying idea is that the Commission needs confidence in the people setting strategy and policy, not just the people executing it. Someone holding a PML is personally accountable in a way that goes beyond their job title. If things go wrong in an area under their oversight, their personal licence can be reviewed, suspended or revoked, separately from any action taken against the operator’s licence.

Whoever manages the licensing process at an operator needs to map out which roles trigger a PML requirement, because this is defined by the nature of the influence someone has, not simply their seniority on an org chart. A newly created head-of-department role, or a restructuring that shifts decision-making authority, can bring someone into PML territory even if their previous role never required one.

What a Personal Functional Licence covers

A PFL, by contrast, applies to people carrying out specified operational or functional roles that involve direct contact with gambling activity but sit below the level of strategic management. Classic examples are casino dealers and other gaming staff working in premises where this kind of licensing is required.

The emphasis with a PFL is on the individual’s conduct while performing the specific function itself, for example handling equipment, dealing games, or supervising play at the table. It is about competence and integrity in that operational context rather than accountability for wider policy or business decisions.

Because a PFL is tied to a functional role, it typically becomes relevant in premises-based settings rather than purely online operations. Remote (online) gambling businesses are far more likely to need PMLs across their management team than PFLs, since there is no equivalent floor-level function of dealing cards or running a table.

The core distinction in practice

The cleanest way to separate the two is to ask what kind of influence a role has. A PML is about strategic or managerial control, the ability to shape how the whole business, or a significant function within it, complies with licence conditions and treats customers. A PFL is about direct, hands-on delivery of a licensed activity, where personal conduct and competence in that specific task is what matters to the regulator.

A person can, in some structures, need consideration for both if their role blends operational duties with a genuine management function, though this is unusual and worth getting professional advice on rather than assuming.

Both licence types involve an application to the Gambling Commission, background and fitness checks, and ongoing obligations to notify the Commission of relevant changes in circumstances, such as convictions, insolvency events or changes to the role itself. Failing to hold the correct personal licence for a role, or continuing to act in a role after a change means a different licence type is now required, is a compliance failure that sits with both the individual and the business that allowed it to happen.

Getting the mapping right

For operators, the practical task is an honest audit of every role that touches management decisions or direct functional delivery, checked against the Commission’s current definitions and thresholds for each licence type. These definitions and the specific roles caught by each category are set out in the Commission’s guidance and are the only reliable source to check against, since organisational titles vary enormously between businesses and are not a safe proxy for what the regulator actually requires.

Getting this wrong is not a technicality. It can mean individuals are operating without the licence their role legally requires, and it is the kind of gap that tends to surface during a compliance assessment or licence review, at which point it is far more costly to fix than it would have been to identify during onboarding or restructuring.

Where to check the current position

Given how specific the role definitions and application requirements are, and that they can be updated, always confirm the current criteria directly with the regulator rather than relying on summaries, including this one, as a final word.