Socially responsible incentives: what operators need to know
Senior Policy Manager Pradeep Rajania sets out the principles that help operators be compliant with new requirements coming into effect from 19 January 2026. Promotional offers designed on the basis that a consumer plays different gambling products will no longer be allowed.
Posted 12 December 2025 by Pradeep Rajania
What are the new rules?
The new Licence Conditions and Codes of Practice (LCCP) Social Responsibility Code (“Code”) 5.1.1(3b) provision sets out that licensees “must not include more than one type of gambling product (betting, casino, bingo and lottery) within an incentive”.
Currently, LCCP Social Responsibility (SR) Code 5.1.1 (1) sets out a wide definition of the kinds of arrangements the Code encompasses, including ‘an incentive or reward scheme or other arrangements’ as part of the definition. This captures a wide range of promotional offers and bonuses. Examples include, but are not limited to, free bets or free spins, sign-up offers, and daily reward offers.
The aim of new LCCP SR Code provision 5.1.1(3b) is to ban the mixing of products within an individual incentive or promotional offer, including where terms are linked and shared.
The Commission in its consultation response document clarified that the ban on mixing of products does not affect incentives which allow the customer to choose or select the product on which to use credits or bonus money on an unrestricted basis. For example, an incentive which provides a customer with £10 bonus to use as they wish on products is permitted, so long as the list of available product categories is unrestricted. We have considered the extent to which this principle may apply and go into detail further below.
What are the key principles?
Typically, incentives are constructed in two parts:
- i) the initial customer activity required. The customer activity could be gambling or non-gambling related activities, such as, requiring customers to participate in a bet, or a non-gambling activity where the customer may be required to log on to an App or website.
- ii) the reward or prize offered to the customer for successfully completing the activity set out in para i) above.
Incentives that are constructed in a way that requires the customer to participate in a specific product category, must offer prizes in respect of the same category.
- an offer that states ‘Bet £5 to get a free £5 bet’ is compliant
- an offer that states 'Spend £5 on casino products and get 20 (casino product) spins free’ is compliant.
Therefore, an incentive that is designed to require a customer to stake, or participate in product X, to get a reward of product Y, would be non-compliant, as there is a clear mixing of products in this scenario.
- an offer that states ‘Bet £5 and get 20 free spins’ is non-compliant
- where the prize is comprised of mixed products, such as, ‘Bet £5 and get a £5 free bet and 20 free spins’, this would be non-compliant.
Irrespective of whether a stake is required on the product category, if the reward/prize is mixed, this would not be permitted under the new Code provisions. For example, an incentive that required the customer to open a gambling app and play a daily free award game, which gives the customer the opportunity to win the right to participate in a range of licensed products in casino and betting, would not be compliant, even though a stake was not required. In contrast, a daily free award game which offers prizes from the same category (being ‘bets’), for example, £10 free bet, £5 free bet, etc, would be a compliant offer.
Clarification on credit/bonus facility giving consumer choice
The Commission’s consultation response document (referenced above) clarified that the ban does not apply if the incentive is constructed in a manner that allows the customer to choose or select the products on which to use credits or bonus money (on an unrestricted basis). The important point to note is that the customer must have full freedom of choice in which product category (betting, bingo, casino, lottery) to use their credits or bonus money – it must not be restricted in any way by the operator. For clarity, see the following bullet points:
- an incentive may be constructed in a manner that offers the customer bonus money to be used on any licensed product type available across the site, from which the customer can choose. The licensed product type (e.g. betting, bingo, casino, lottery) should not be limited, to enable full customer choice. There may be circumstances where specific games are excluded from a product category—for example, instant win games and specific table games, such as roulette, that are available within the casino category —these exclusions must be clearly stated and easily accessible within the incentive’s terms and conditions
- licensees could construct an incentive that would require the customer to participate in a specific gambling activity to get the bonus money (which can be used on a range of licensed products). For example, ‘Bet £5 and get £5 bonus money to spend on a gambling product of your choice’
- licensees could also construct an incentive that allowed customers to spend £10 on any licensed product of their choice and get £10 credit/bonus to spend on their choice.
We would expect the terms and conditions attached to any credit/bonus facility, to be drafted in a way that is clear, easily accessible, fair and open, and socially responsible. We will keep this area under review and may consider whether to consult on further requirements if it is found that industry practices do not meet policy objectives.
What types of incentives could be offered?
As an outcomes focussed regulator, the Commission cannot offer prior approval for different incentives. The principles behind the rules are clear and if operators have doubts about a particular incentive they should consider whether such an incentive may expose them to risk of non-compliance. However, to support operators here are some examples that may be deemed as compliant or non-compliant, along with the rationale. Please note this is not an exhaustive list and should be used as guidance only.
| Example of offer | Compliant Yes or No | Rationale |
|---|---|---|
| Bet £5 and get £10 free bet | Yes | This does not mix product types between the initial customer activity and the prize |
| Spend £5 on casino products and get 20 free spins | Yes | This does not mix product types between the initial customer activity and the prize as both are part of the casino category |
| Bet £5 to get 20 free spins | No | This type of offer clearly mixes product types. The offer is inviting the customer to participate in one type of gambling activity (betting), to get a prize from a different product category (casino product spins) |
| Bet £5 and get a £5 free bet and 20 free spins. | No | This type of offer mixes product types. The prize is comprised of mixed products, such as a free bet and casino product spins |
| Bet £5 to get £10 credit or bonus to be used on all products available. | Yes | The exception allows licensees to offer a bonus where it’s the customer’s choice as to which product category they choose for their reward. Licensees can specify participation in the gambling activity in order to qualify for the prize |
| Spend £10 on any licensed product of your choice and get £5 free bet. | No | While the customer gets a choice on which qualifying activity to participate in (spending £10), the customer does not have a choice of the prize or reward with the operator dictating the product category and limiting this to betting only |
| Spend £10 on any licensed product of your choice and get £10 credit or bonus to spend on your choice. | Yes | This would be compliant because it’s the customer’s choice as to which product category they choose to play, and which prize or reward they choose, and it is not stipulated or limited by the operator |
| Deposit £5 (not linked to participation of a product category) and get £5 credit or bonus of any licensed product | Yes | This would be compliant because it’s the customer’s choice as to which product category they choose to play and which prize or reward they choose, and it is not stipulated or limited by the operator |
| Log on to the app and play and enter the daily free reward game which gives you the opportunity to win £1 free bet, 5 free spins, or £10 cash | No | The new provision applies irrespective of whether a stake on the product category is required or not in order to receive the reward. The prize gives an opportunity to win a range of mixed products which are stipulated by the operator which means this offer would be non-compliant. There is not full or unrestricted consumer choice as to which product they can win as a prize or reward |
| Log on to the app and play and enter the daily free reward game which gives you the opportunity to win £1 free bet, £5 free bet, £10 free bet, £100 cash, or other non-gambling prizes | Yes | The new provision applies irrespective of whether a stake on the product category is required or not to receive the reward. The prize gives an opportunity to win a number of denominations in one licensed product category, so is compliant |
What are the rules on the advertising of incentives?
The aim of LCCP SR Code provision 5.1.1(3b) is to ban the mixing of products within an individual incentive, including where terms are linked and shared. The requirement relates to how individual incentives are designed and constructed. The advertising of such incentives must always also continue to comply with existing advertising rules as applicable as set out in LCCP SR Code 5.1.6 (Compliance with advertising codes).