Ministers have not had any discussions with local authorities on the effect of the Licensing Act 2003 on carols or Christmas songs. However, officials have shared previous advice they have given on this issue with the local authorities coordinators of regulatory services (LACORS) and this has been disseminated by LACORS and is available on the DCMS website. Most singing of carols and Christmas songs is either spontaneous, incidental to other activities or part of a religious service and therefore not usually licensable.
Licensing requirements depend on the type of event at which songs are being performed and not whether the songs themselves are religious or secular. For example, secular songs being performed as part of a religious service would not make that service licensable. Conversely, a rock band choosing to play a religious carol as part of its set would not make a rock concert an exempt religious service. It is not possible to describe every scenario, which is why it is ultimately for licensing authorities to determine what requires a licence and what does not.