Licensing Consultation on Market Diversity and Innovation: why we’re responding and what others may want to say
The Department for Communities is consulting on whether Northern Ireland’s liquor licensing system supports market diversity and innovation.
We have submitted a full response to the consultation, which you can read here.
You can respond to the consultation here.
This consultation is narrower than the wider licensing reform Free The Night has been calling for. It mainly asks whether the current list of premises that can apply for a liquor licence should be expanded, including whether more venues should be able to apply through the existing “place of public entertainment” route.
Our view is that this may help in some cases, but it will not deliver the kind of change our members, and many in the music and cultural sectors, have been asking for.
What the Department is looking at
At the moment, a “place of public entertainment” licence applies to a limited set of premises, including theatres, cinemas, ballrooms and racetracks.
The Department is considering whether this category could be widened. That may be possible through secondary legislation, and we support doing that where it helps.
For example, a wider category could support venues such as listening bars, comedy spaces, retro arcades, gallery/event spaces, community venues or other cultural premises that are not trying to operate late into the night.
For those kinds of spaces, this could be useful. It may give some operators a more appropriate route than trying to fit into a pub, hotel or restaurant model.
But that is a limited fix.
Why this does not solve the main problem
The “place of public entertainment” licence is limited to alcohol sales between 11.30 am and 11.00 pm on weekdays and 12.30 am and 11.00 pm on Saturdays and Sundays, and only during the entertainment, 30 minutes before it begins and 30 minutes after it ends.Venues like the Oh Yeah centre (operating on a theatre license) regularly have to apply for an occasional license through a third party to run later events, and even then, they must close earlier than most pubs.
That will not work for much of the music sector, electronic music culture, nightclubs, late-night cultural venues, or any promoters trying to build sustainable activity outside traditional pub settings.
There are already venues operating through theatre-style licensing routes which recognise that the model does not give them the flexibility they need, for example The Black Box and Banana Block. If that route is not working properly for these cultural venues already, simply adding more premises to the same category will not solve the structural issue.
So our position is:
Yes, expand the place of public entertainment category where that helps.
But do not present that as a proper Cultural Venue licence.
What we are calling for
We believe Northern Ireland needs a standalone Cultural Venue licence, created through primary legislation.
That licence should be designed around cultural activity rather than traditional hospitality. It should be available to venues where the primary purpose is music, performance, dance, art, creativity, community or cultural programming.
It should not be subject to the surrender principle. If a cultural venue has to buy or surrender an existing pub licence, then the reform will not open the market in any meaningful way.
It should also allow safe, well-managed venues to apply for later alcohol hours where justified. That does not mean deregulation. It means proper regulation that reflects how cultural activity actually works, with conditions around safety, welfare, safeguarding, noise, transport, management and community impact.
We are also calling for reform of occasional licensing. Not every promoter, artist collective or cultural organisation can own or lease a permanent venue. Temporary and meanwhile-use spaces are part of how culture develops. The law should allow cultural organisations and independent promoters to use those spaces responsibly, without being completely dependent on existing licence holders.
What you might want to say in your response
You do not need to answer every question. You can respond to the parts that matter to you. The questions are also quite repetitive and this is reflected in our answers.
If you are a venue, promoter, artist, audience member, cultural worker, community organisation or someone affected by the current system, it is useful to explain how the licensing framework affects you directly.
For Question 6, on the level of diversity in licensed venue type, you may want to say that Northern Ireland has a low level of diversity. The system works best for traditional pubs, hotels and restaurants, but does not properly support grassroots music venues, nightclubs , independent cultural spaces, temporary venues, LGBTQ+ nightlife, late-night venues or artist-led spaces.
For Question 7, on whether the current regime supports market diversity, you may want to say that it does not. You could explain how the current system affects consumers, prospective licensees, current venues, promoters, artists or communities.
For Questions 9 and 10, you may want to give examples of the venues and activities that are not currently supported. This could include music venues, electronic music spaces, nightclubs, listening bars, studios, galleries, warehouses, temporary venues, community-led spaces or small venues used by independent promoters.
You may also want to say that alcohol should be allowed where it is ancillary to cultural activity. For most cultural events, bar income is necessary to help cover programming, production, artist fees, staffing, security, welfare and accessibility.
For Question 12, you may want to say that you support expanding the categories of premises that can apply for a liquor licence, but that this must not be limited to minor changes to the existing system.
For Questions 13, 14 and 15, you may want to say that expanding the place of public entertainment category could help some venues, especially those that do not need late hours. But you should also say clearly that this will not solve the problem for music venues, late-night cultural spaces, electronic music spaces, or nightclubs because the permitted alcohol hours are too limited.
For Question 16, please make the wider point: Northern Ireland needs a proper Cultural Venue licence, reform of permitted hours, better alignment between liquor licensing and entertainment licensing, and reform of occasional licensing.
Final point
This consultation may lead to some useful changes, especially for venues that do not need to operate late into the night.
But for the music sector, late-night culture and many of the people Free The Night works with, secondary legislation will not be enough.
We need the Department to recognise that distinction and commit to the wider reform that is actually needed.
Respond to the consultation here. Closing 23 June 2026, 11.59 pm
