
London Calling: What the Mayor’s new licensing call-in powers mean in practice
The Licensing Act 2003 (Applications of Potential Strategic Importance to Greater London etc and Consequential Amendment) Regulations 2026
Section 51 of, and Schedule 26 to, the English Devolution and Community Empowerment Act 2026 amended the Licensing Act 2003 to give the Mayor of London new powers to call-in and determine certain premises licence applications of potential strategic importance to Greater London. On 3 November 2026, the Licensing Act 2003 (Applications of Potential Strategic Importance to Greater London etc and Consequential Amendment) Regulations 2026 ("the Regulations") come into force, confirming which applications are of potential strategic importance ("PSI"), as well as setting out the procedural framework and statutory timescales for the new regime. The s182 Guidance to the Licensing Act 2003 has also been updated in relation to the Mayor's call-in powers.
The call-in power forms part of wider reforms giving the Mayor and Greater London Authority (GLA) a greater role in licensing decisions with implications for the capital. GLA is also now a responsible authority under the Licensing Act 2003, while the Mayor can issue a London-wide Strategic Licensing Policy ("LSLP").
In our view, the significance of the new regime goes beyond the prospect of individual applications being called in. It has the potential to change how strategically significant applications are approached from the outset, with applicants needing to consider London-wide priorities alongside local licensing policy and potentially engage with GLA earlier in the process. Below, we look at what the Regulations mean in practice and the key questions that remain.
What is the call-in process and what do the Regulations confirm?
The call-in process applies to 'relevant licence applications', which are applications for a new premises licence or a full variation where the premises are to be used for the retail of alcohol (particularly for premises that sell alcohol for consumption on the premises), the provision of regulated entertainment, or providing late-night refreshment. Such premises include, but are not limited to, pubs, bars, restaurants, nightlife spaces, cafés, beer gardens, hotels, festivals, and events. The draft LSLP also indicates the Mayor does not intend to use the call-in powers in relation to premises that engage primarily in off sales of alcohol, such as off-licences, supermarkets, convenience stores, and other retail outlets primarily selling alcohol for takeaway. Excluded from the call-in process are temporary event notices, club premises certificates, SEV licences and Gambling Act premises licences. The call-in powers do not apply to reviews or summary reviews.
Importantly, the Regulations now confirm what is a PSI application, which is where a relevant licence application falls into one of the following five categories:
- Premises in Fee Band D or E;
- Licensable activities proposed after 11pm at premises in Fee Band B or C;
- A premises with a proposed maximum occupancy exceeding 5,000 persons;
- A premises licence that is for a limited period of less than three months; or
- A premises licence that includes live music at premises in Fee Band B or C.
The actual call-in process begins at the point of application and involves a series of notifications, all of which must be transmitted electronically in a form that is capable of being accessed, reproduced and stored by the recipient, and is "legible in all material respects".
First, the licensing authority must notify Greater London Authority (GLA) of any relevant application. This should be done as soon as is practicable (which is expected to be within one working day).
Upon receipt of a valid notice, GLA mustnotify interested parties within ten working days whether the application should be formally treated as an application of potential strategic importance. If the PSI criteria are not met, then notice does not need to be given.
Upon receipt of that notice, the London licensing authority must advertise it as soon as is reasonably practicable and for five working days before the end of the consultation period for the application.
Any responsible authority wishing to make a representation must do so by the end of the application's consultation period. Where the London licensing authority then proceeds to determine the application at a hearing, GLA is entitled to participate much like residents and other responsible authorities who object.
In any event, the licensing authority must always notify GLA of a hearing, including its date, time, place, relevant procedure, and representations, no later than 10 working days before the hearing.
Then, within five working days of the last day of the hearing, the licensing authority must provide the Mayor's office with a statement of the determination and reasons, along with a copy of the record of proceedings, any officer's report, and all other documents before the committee. In cases where a decision is made without a hearing, then the London licensing authority must send notice to GLA as soon as possible.
Where an application is granted in full, there is no further action for GLA to take. Where an application is declined completely or approved with conditions, the Mayor's office then has 20 working days to consider the determination. The 20 working days start only from the day on which the licensing authority has complied with its post-hearing notification obligations. During this time, the licensing authority's decision does not take effect.
During the 20 working days, the Mayor has to decide whether to either:
- let the licensing authority's original decision stand (take effect) and so the application is either declined or granted with conditions; or
- "call-in" the application and use his discretionary power to substitute the determination by giving a direction.
The direction given may:
- Have the same substantive outcome as the licensing authority's original decision (that the application is either declined or granted with conditions). In such cases, for example, the reasons given by licensing authority may be too locally narrow and the Mayor arrives at the same substantive result by applying different strategic reasoning.
- Grant the application in full or with less restrictive conditions than those imposed. Such grant may also exclude licensable activities that were excluded by the local licensing authority's decision. It may also refuse to specify a particular person as the designated premises supervisor where the local licensing authority refused to do so.
Importantly, the Mayor can only reject an application if the London licensing authority rejected the application in their initial decision.
Once the Mayor's office has signed off its decision, notice of the decision must be given to the interested parties within five working days.
The London licensing authority must then advertise as soon as reasonably practicable and keep published the Mayor's decision until the licence is revoked, surrendered, or — in the case of a time-limited licence — until the licensed period has ended.
The local London licensing authority must send out a formal notification to the applicant of the outcome of the application following the Mayor's decision to let the licensing authority's decision stand or to issue a direction granting the application in full or with less restrictive conditions.
The 21-day appeal window starts on the day the local London licensing authority sends out its formal notification to the applicant of the outcome.
Where the call-in power is exercised, the Mayor's substituted decision becomes the operative decision, and it is the Mayor's decision that is subject to appeal. Courts considering such appeals shall have regard to the LSLP.
Key questions
Whilst the types of applications defined as being of PSI are broader than anticipated, it is expected that only a small number of applications will be subject to the Mayor of London's call-in powers.
The draft LSLP states that the call-in power is intended to be used sparingly and as a last resort. To support this, the GLA - which is now a responsible authority under the Licensing Act 2003, is expected to support early engagement, encourage proportionate outcomes and strengthen partnership working. This should help to reduce the number of times the Mayor exercises the call-in powers.
In practice, the wider impact of the new regime may therefore be felt even where the Mayor does not ultimately exercise the call-in power. The GLA's increased involvement could influence how applications are developed, discussed and determined before formal intervention becomes necessary.
Most likely, this is something that will be understood more once the regime has had time to bed in. The Regulations also provide for the Secretary of State to review the operation and effect of the Regulations, with the first report due within two years of commencement. We might expect the first report to examine and make findings on this particular point.
By defining a PSI application, the Regulations provide a gateway for further review by the Mayor’s office.
Further details about the features of an application that will make Mayoral intervention more likely are expected to be confirmed in the LSLP. The draft presently indicates call-in will be used where an application is likely to have an impact that extends beyond a single premises or neighbourhood.
As a result, applications will be assessed on three broad factors (which may be subject to change): economic impact; locations of strategic importance (which ensures the Mayor can review applications in cumulative impact areas if they are PSI applications); and premises or events that are of reputational importance (i.e. that affect London's reputation as a global city).
The precise methodology for making these assessments is unclear, but the draft LSLP indicates that the call-in power aims to ensure that licensing applications of strategic importance are transparent, evidence-based, proportionate and in line with London-wide Mayoral priorities.
This means that applicants may increasingly need to demonstrate not only how an application satisfies the licensing objectives and local policy, but how it sits within the wider strategic context for London.
The answer to this important question is unclear and raises further issues, such as:
- Once the application is before the Mayor’s office, how does an applicant engage with it and what might that look like?
- Will there be further opportunities to make submissions and how will new information arising post-committee be dealt with?
- The ability to discuss and negotiate conditions is an embedded feature of the existing licensing framework. How might conditions be negotiated or revised when an application is called in?
- Will other interested parties be invited to participate in the Mayor’s call-in process?
These are important practical issues. Until the process becomes clearer, applicants will need to ensure that their case is put as fully as possible before the licensing committee, rather than assuming there will necessarily be a further opportunity to develop or negotiate their position if the matter reaches the Mayor's office.
Will the Mayor’s office make a decision ‘on the papers’ or by other means, noting that the Mayor has a short period of time in which to make and notify its decision?
The answer could have important implications for applicants and interested parties, particularly in terms of how they present evidence and whether there is a further opportunity to test or respond to competing arguments.
First, operators will need to take into account the additional timescales introduced by the call-in framework and build in additional contingency plans. Even though the powers are to be used sparingly, it is clear that these additional powers increase the complexity of determinations and will extend the time in which operators will receive a degree of certainty regarding the outcome of their application.
Secondly, applicants should consider whether there is value in engaging with the GLA prior to lodging an application. Taking this further, it remains to be seen whether a formal pre application process will be available to applicants. If so, applicants need to factor that engagement into their project plans at an early stage.
Thirdly, applicants should consider whether their operating schedules and supporting material need to address relevant strategic licensing considerations expressly. When making and determining applications in London, operators and licensing committees should consider not only local policy but also the wider strategic aims for London that underpin the introduction of the call-in powers such as supporting a much-beleaguered hospitality, entertainment and night-time economy. London licensing authorities will also need to consult the Mayor when developing and revising their own licensing policy. The GLA will publish a London Licensing Playbook to assist applicants, borough councils and responsible authorities apply the LSLP and standardise best practice. A key issue as the regime develops will be how licensing authorities and the Mayor of London balance the strategic aims for London against local risk and concerns about noise and antisocial behaviour.
Ultimately, the most significant effect of the new regime may not be the number of applications the Mayor actually calls in. Instead, it may be the way the possibility of Mayoral intervention changes how potentially significant applications are prepared, consulted on and determined from the outset. For applicants, early consideration of London-wide strategic priorities, alongside the local licensing position, is therefore likely to become increasingly important.
Author: Claire Morris
This publication is intended for general guidance and represents our understanding of the relevant law and practice as at November 2026. Specific advice should be sought for specific cases. For more information see our terms & conditions.
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