High Value Customer schemes: new findings
Our Head of Evidence Assurance and Evaluation David Taylor introduces new findings looking at the ongoing impact of changes to High Value Customer schemes.
Posted 17 July 2025 by David Taylor
In 2020, the Gambling Commission outlined concerns about the management and incentivisation of customers that were members of so called ‘VIP schemes’ or ‘High Value Customer’ (HVC) schemes. This was particularly due to the increased risks of gambling related harm for customers and, in some cases, a failure to prevent criminal proceeds from being spent on gambling. That year, the Commission consulted on, and then introduced, changes to the way that these schemes could be operated.
We reported the initial impact of the regulatory changes in our Advice to Government which showed that the prevalence and membership of the schemes had reduced by as much as 90 per cent. Those findings were based on a data request exercise conducted in 2021 with a sample of operators. We have today published the results of an updated exercise which looks at the ongoing impact of the policy change - High Value and VIP Scheme Monitoring report.
This new report is based on 2024 data and followed a similar process to the one in 2021, so that the results can be considered comparable. Still, the new report benefits from the addition of further questions and a consideration of whether HVC or ’VIP’ schemes are referenced in Commission casework. Full findings and further details about the methodology and its limitations are detailed in the report. The headline findings are that these schemes are no more commonplace now than they were in 2021 - after the regulatory change. The number of consumers in them has also remained consistent and the data collected from operators indicates every HVC scheme now has a senior executive appointed to oversee and be held accountable for how the scheme is operated. Through this exercise, we also found that HVC schemes were less often assessed as being a contributory factor in issues under investigation within Commission casework.
In this exercise, we calculated the proportion of Gross Gambling Yield (GGY) generated by HVC schemes within the sample as being approximately 3 per cent, although there was considerable variation between different operators and different sectors. One sector in this exercise which seems to have a greater reliance on scheme members as a proportion of GGY is land-based casinos, which is in line with our expectations. This is a sector that the Gambling Act Review White Paper (opens in new tab) recognised as presenting some distinct characteristics. It has the opportunity through staff supervision and interventions to help to identify and support people suffering gambling harms and the vast majority of customers in high-end casinos are high net worth individuals based overseas. This factor, in particular, may have led to the difference in GGY proportions compared to other sectors and it’s worth noting that this finding isn’t accompanied with any allegations of consumer harm, but it is something that can be factored into the Commission’s assessment work.
Whilst we remain mindful that this exercise is reasonably modest in scope, the findings indicate that the intended impact is being achieved. Limitations are detailed in the report and include details about the sample of operators and how this is intended to provide a relatively high-level overview of the policy’s effectiveness. It’s also worth noting that the impact of this policy is also influenced by other changes to regulatory requirements on topics such as customer interaction, for example. Although evaluation exercises like this will never be able to give total assurance, it does provide an indication that the regulatory objectives have been delivered and further changes are not currently required. Where operators fail to meet requirements, we will continue to take action.
The Commission remains committed to evaluation activities to learn more about the impact of the changes that we make. Details of the approach being taken to evaluate the Gambling Act Review have been shared in previous blog posts.