Key Changes in the 2025 Licensing Act Guidance: What Operators Need to Know

Simon Francis
Nov 28
4 min read

The Home Office has released the revised Section 182 Guidance (November 2025), bringing with it some important updates that every premises operator, licence holder and DPS needs to understand. While the core principles of the Licensing Act 2003 remain unchanged, the new guidance places fresh emphasis on compliance, management standards, immigration checks, and enforcement powers.

For operators, these changes matter. They affect how applications are assessed, how reviews are handled, how temporary events are managed, and what licensing authorities now expect in terms of due diligence and day-to-day control of licensed premises.

In this blog, we break down the key changes in clear, practical terms—so you know exactly what’s new, why it matters, and how to stay compliant as we move into 2025 and beyond.

1. Briefing for DPSs (Designated Premises Supervisors)

Key regulatory updates you need to know:

Stronger focus on illegal working
- Home Office Immigration Enforcement is now notified on more types of applications (DPS changes, transfers, interim notices).
- Licensing authorities may take tougher action where illegal working is suspected.
Stricter processes on summary reviews
- Interim steps (e.g., suspension, changes to conditions) can now be imposed more quickly and even via telephone notification.
- Expect closer scrutiny of your venue if linked to any serious crime/disorder incident.
Increased focus on evidence of good management
- Reviews now emphasise whether problems stem from poor DPS decisions.
- Authorities may remove the DPS if management is considered weak or non-compliant.
Updated requirements around live/recorded music
- Deregulation still applies, but audience thresholds, times (08:00–23:00) and conditions remain critical.
More precise rules around TENs
- TENs must include clearer descriptions of event locations and activities.
- Police and EHA can intervene faster under clearer timelines.

What you should do now:

✔ Ensure all staff have right-to-work checks documented

✔ Reinforce compliance procedures (searches, CCTV, incident logs)

✔ Be ready to demonstrate management competence at short notice

✔ Review music provisions and capacity limits

✔ Tighten TEN submission and event-planning processes

Briefing for Premises Operators / Licence Holders

Important updates affecting operators:

Illegal working is a major enforcement priority
- Transfers, interim authority notices and DPS changes now involve Home Office checks.
- Licences can be suspended or revoked where immigration offences are linked to the premises.
Interim steps following serious incidents are more immediate
- Licensing sub-committees can impose urgent steps (including suspension) with minimal notice.
- Costly conditions (CCTV upgrades, safer glassware, structural changes) will be tested against proportionality.
Cumulative Impact Assessments (CIAs) strengthened
- More robust evidence required and authorities must summarise them in policy.
- While CIAs don’t automatically block applications, expect tighter scrutiny in affected zones.
Clearer guidance on community premises and management committees
- Stronger governance proof required where no DPS is in place.
More detailed Minor Variation rules
- White notices, clearer advertising rules, and shorter determination timelines.
TEN rules clarified
- More specifics on what counts as “the premises”.
- Event details must be precise—especially for outdoor or temporary structures.

What operators should do:

✔ Review staffing/right-to-work compliance

✔ Strengthen incident management and reporting

✔ Audit licence conditions—particularly for music, search policies, and CCTV

✔ Ensure variation applications and TENs are prepared correctly

✔ Keep evidence of good management for hearings or police engagement

3. Briefing for Local Authorities (Licensing Teams & EHOs)

Key changes for licensing authorities:

Home Office must now be notified earlier and on more applications
- Transfers, DPS variations, TENs, interim authorities now trigger mandatory Immigration Enforcement notifications.
Summary reviews guidance significantly expanded
- Authorities may issue immediate non-written notices (e.g., telephone).
- Clearer rules on proportionality when imposing costly interim steps.
- Representations against interim steps must be heard within 48 hours.
Strengthened guidance on CIAs
- Must be summarised in licensing policy.
- Evidence must be robust, local, and objectively linked to the licensing objectives.
- CIAs cannot apply to TENs, but CIA evidence can support objections.
More prescriptive interpretation of Minor Variations
- Delegation to officers encouraged.
- Requirement to consult responsible authorities where doubt exists.
- Strict 10-working-day and 15-day decision limits.
Greater clarity on community premises
- Emphasis on governance, transparency, and ongoing supervision of alcohol supply.
- Authorities may request constitutions, management documentation and committee details.
Updates to TENs guidance
- Authorities must ensure that premises boundaries are clearly defined (particularly open-air or multi-plot locations).
- Objection processes clarified.
Wales-specific requirements emphasised
- Forms and communications must be bilingual.

What local authorities should action:

✔ Update statement of licensing policy (especially CIA summaries)

✔ Review internal workflows for TENs, minor variations and interim notices

✔ Train committee members on updated summary review procedures

✔ Improve consultation routes with Immigration Enforcement

✔ Ensure bilingual compliance where applicable