Adult gaming centres and amusement arcades in planning

An adult gaming centre needs planning permission almost everywhere, because amusement arcades and gaming centres sit outside every use class in the Town and Country Planning (Use Classes) Order 1987. The 2020 reforms that swept most high street uses into Class E left them where they were, as sui generis uses, so moving into a former shop is a change of use that has to be applied for. The premises licence under the Gambling Act 2005 is a separate exercise with a separate authority and a separate test.

Applicants routinely assume that one consent implies the other. It does not, and the legislation says so in terms.

Where gaming centres sit in the Use Classes Order

Article 3(6) of the Use Classes Order lists the uses that belong to no class at all, and an amusement arcade or centre is among them. A licensed betting office and a pay day loan shop are treated the same way. Bingo, by contrast, moved into Class E as part of the 2020 changes, which is why a former bingo hall converting to a gaming centre still needs permission while the reverse move may not.

The practical effect is that no permitted development right gets you into a gaming centre use. Class MA in Part 3 of the General Permitted Development Order 2015 takes Class E premises to residential, and other Part 3 classes handle specific movements, and none of them reaches sui generis gambling uses. If the unit was a shop, a café or an office, you are making a full planning application for change of use.

Where the previous use was itself sui generis, check what it was precisely. A change from one sui generis use to another is still development requiring permission, because there is no class within which to move. Our note on funeral directors and the use class question works through the same problem for a different high street use.

Two consent regimes that must not look at each other

Section 210 of the Gambling Act 2005 is the provision to have to hand. In deciding a premises licence application, the licensing authority may not have regard to whether the proposal is likely to be permitted under planning law. And a planning authority deciding the change of use may not have regard to whether the activity is likely to be licensed.

So the two applications run in parallel and neither waits for the other. In a unitary authority the same council does both, through different committees, applying different tests. The licensing authority works to the three licensing objectives in section 1 of the Act: keeping gambling free of crime, keeping it fair and open, and protecting children and other vulnerable people. The planning authority works to the development plan and other material considerations.

This separation matters when the objections arrive. Representations about problem gambling, about the vulnerability of customers or about the number of gambling premises in the area belong to the licensing process. Representations about the loss of retail frontage, about noise, about parking or about the effect of an inactive shopfront belong to the planning process. Expect both sets to be submitted to both authorities anyway.

Frontage, clustering and town centre policy

Most adopted local plans carry a primary and secondary shopping frontage policy, or a town centre uses policy that controls the proportion of non-retail units within a defined frontage. Many add a specific limb on the concentration of gambling premises, hot food takeaways and similar uses, sometimes expressed as a maximum percentage of units in a frontage, sometimes as a rule against two such uses standing next to one another.

Find the policy first, then count. Walk the frontage, record the current use of every unit, note the vacancies and their length, and present the count as a plan and a schedule. Officers will do this exercise themselves, and an application that has already done it accurately starts from a better place than one that argues in the abstract.

The National Planning Policy Framework (August 2026 edition) supports the vitality and viability of town centres and applies a sequential approach to main town centre uses. Leisure and entertainment uses are generally treated as main town centre uses, so an edge of centre or out of centre gaming centre may need a sequential assessment, and a larger proposal may need an impact assessment against the threshold in the development plan or the national default. Where that applies, a Retail Impact Assessment is the document the authority will expect.

Shopfronts, windows and signage

The obscured or heavily filmed window is the detail that sinks otherwise reasonable applications. Gambling operators want privacy and low light inside; conservation officers and town centre policies want active frontage and visual interest at street level. Those two positions have to be reconciled on a drawing before submission.

What tends to work is a retained clear glazed zone at eye level with a display or a seating area behind it, internal blinds rather than applied film, and a shopfront that keeps the original stallriser, pilasters and fascia proportions. In a conservation area or on a listed building the bar is higher, and an Article 4 direction may have removed the deemed consent for some signage.

Illuminated signs need advertisement consent under the Control of Advertisements Regulations 2007, assessed on amenity and public safety only. Internally illuminated box fascias are commonly refused in historic frontages. Submit the signage with the change of use rather than afterwards, so the authority sees the finished appearance rather than an unadorned elevation.

Hours, staffing and the conditions councils impose

Opening hours are the condition most often imposed, and they are the one most often negotiated. Authorities in residential settings tend to restrict late night opening, and an unrestricted 24 hour application in a mixed use street usually attracts a refusal or a heavily conditioned approval.

Other conditions to expect cover the management of the frontage, door supervision at defined times, restrictions on external seating or queuing, a limit on the floorspace given over to machines, and controls on plant noise. Where air conditioning or a refrigeration unit is proposed, the plant assessment sits with the Noise Impact Assessment and should be done against measured background levels rather than assumed ones.

Illustrative example: a vacant unit in a secondary frontage, adjoining flats above two neighbouring shops. The application offered 9am to 11pm opening, a clear glazed frontage panel, an internal lobby to control door noise, and a condenser relocated to a rear roof with an acoustic enclosure. The hours condition ended at 10.30pm and the permission was granted with a plant noise limit expressed relative to background.

The evidence a gaming centre application needs

Assemble five things. A Planning Statement that addresses the frontage policy directly with the unit count. A frontage survey plan and schedule. A shopfront and signage drawing set at 1:50 with a section through the stallriser. A plant noise assessment where mechanical services are proposed. A management statement covering hours, staffing and how the frontage will be kept active.

Add a transport note where parking or servicing is contentious, though in most town centre locations the trip generation argument is weak on both sides. The comparable problem for a family oriented use is set out in our piece on soft play centres and their use class, parking and noise conditions.

This is general guidance, not legal advice; check the position with your local planning authority, your licensing authority or a qualified professional before relying on it.

Enter your postcode on PlanScope to see which supporting documents a change of use in your frontage is likely to need.

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