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  3. Autumn 2023 consultation – Proposed changes to LCCP and RTS - Socially responsible incentives: Consultation Response

Consultation response

Autumn 2023 consultation – Proposed changes to LCCP and RTS - Socially responsible incentives: Consultation Response

This response sets out our position in relation to the consultation on socially responsible incentives

Published
26 March 2025

Last updated
26 March 2025 - Changes

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Contents

Executive summary

In April 2023, the then government published its white paper High Stakes: gambling reform for a digital age (opens in new tab), which set out a plan for reform of gambling regulation following a review of the Gambling Act 2005.

In Autumn 2023, we consulted on a number of changes to the Licence Conditions and Codes of Practice (LCCP) requirements placed on gambling businesses. This consultation package included the second set of proposed changes to the regulatory framework required to implement the Gambling Commission’s commitments as part of that review.

This response sets out our position in relation to the consultation on socially responsible incentives.

The aim of the consultation was to ensure that incentives such as free bets and bonuses are constructed in a socially responsible manner and do not encourage excessive or harmful gambling.

We consulted on proposals to ban or limit the use of wagering requirements in promotional offers and a proposal to ban the mixing of product types (for example, betting, bingo, casino and lotteries) within incentives. We also consulted on changes to the section of LCCP that covers rewards and bonuses to make it explicit that incentives should be constructed in a manner that does not lead to excessive or harmful gambling.

We asked

The consultation covered 3 issues.

Issue 1: Wagering requirements

The evidence showed that high levels of wagering requirements attached to bonuses can lead to higher intensity of gambling activity, and adds complexity to offers, which in turn increases the risk of excessive gambling and risk of harm. Therefore, we consulted on 2 alternative proposals to address this issue, which were:

  • a proposal to ban wagering requirements applied to all bonus funds in promotional offers
  • a proposal to set a cap on wagering requirements to all bonus funds applied to promotional offers. We consulted on 3 alternative thresholds, which were a maximum of 1, 5, or 10 times.

Issue 2: Mixing of products within incentives

Some promotional offers are structured to combine different product types, primarily for new customer sign up offers. This typically involves gambling licensees providing a combination of free bets and free casino spins. The evidence shows that these can be problematic because they can lead to consumer confusion and likelihood of experiencing harm. We therefore consulted on a proposal to introduce a ban on the mixing of product types within promotional offers, for new and existing customers.

Issue 3: Changes to the drafting and structure of LCCP to make it clearer and easier to understand

LCCP Social Responsibility Code 5.1.1 (Rewards and Bonuses) sets out rules to ensure incentives are constructed in a socially responsible manner. Based on compliance engagement and casework, it was apparent that the structure and wording of aspects of this provision are not as clear as they ought to be. Therefore, we consulted on a new structure and wording to make it explicit that incentives should be constructed in a manner that does not lead to excessive or harmful gambling.

You said

On 29 November 2023 we issued our consultation on a number of changes to the LCCP and RTS requirements (opens in new tab) placed on gambling businesses, including socially responsible incentives. The consultation ran for 12 weeks until 21 February 2024.

Annex 1 lists organisations that consented to the publication of their name when responding to the consultation.

We did

Following careful consideration of the responses received during the consultation, we have decided to proceed with:

  • wagering requirements capped to a maximum of 10 times in promotional offers
  • a ban on mixing of products within incentives
  • implementing changes to the structure of LCCP SR Code 5.1.1 (Rewards and Bonuses). We have decided to proceed with deleting the current LCCP SR Code 5.1.1 1(b)(i) which states ‘neither the value nor amount of the benefit is dependent on the customer gambling for a pre-determined length of time or with a pre-determined frequency’.

We have decided not to proceed with the proposed wording requiring licensees to ‘ensure the design and structure of the incentive does not lead to excessive intensity of gambling which may risk customers experiencing harms associated with gambling.’

These new elements of the LCCP will come into effect on 19 December 2025.

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