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
Proposal 2 - Ban mixing of products within incentives
We sought views on our proposal to ban the inclusion of more than one type of gambling product (for example, betting, casino, bingo, and lotteries) within the incentive, for new and existing customers. For example, gambling licensees would not be able to offer an incentive containing both a bingo and lottery product, but it could include more than one type of the same type of gambling product, for example, a lottery scratchcard and a raffle.
Consultation questions
To what extent do you agree with the proposal to ban the mixing of more than one type of gambling product within an incentive? Please give your reasons, including any evidence.
Do you have any comments about implementation issues, timelines and practicalities?
Please provide an estimate, including any evidence, of the direct costs associated with implementing this proposal.
Respondents’ views
Responses to this proposal were mixed, with just over half of all respondents in support of the proposal.
Respondents in support of a ban commented as follows:
- agreed with our evidence base and rationale for introducing the requirement
- some respondents cited additional research to support the policy intent to reduce the risk of gambling harm. This included findings from the final report of Pattern of Play research (2022) (opens in new tab) which considered the demographic characteristics of customers experiencing heavy losses. The report suggests that certain groups may be more susceptible to negative outcomes. Limiting the promotion of multiple gambling products may be considered a responsible approach to protect specific demographics from heightened risks associated with dual participation.
With regard to responses that strongly disagreed with the proposed ban, most gambling licensees reflected the submission from the trade association, which set out the following reasons:
- they expect concerns outlined in the consultation to be addressed by our Summer 2023 consultation on giving consumers power to choose what direct marketing they receive by product and channel
- criticisms of the evidence base used to support the proposal, such as limitations of research and lack of representation of the consumer base. Comments also included that the research did not substantiate claims that the mixing of products could impact consumer understanding of an offer
- some gambling licensees submitted their own research showing their customers liked the mixing of products and make conscious and informed choices when deciding whether to use a bonus offer. There were concerns that the proposed ban would severely restrict consumer choice
- sought clarification on whether incentives which provide credits or bonus money that allow the customer to select gambling products of their choice, are not in scope of this proposal. For example, an incentive which provides a customer with £10 ‘credit’ to use as they wish across products, such as betting and casino.
Our position
We have considered the comments and concerns raised by stakeholders in the consultation responses.
Links to Summer 2023 direct marketing consultation
The outcome of the consultation led to new rules (Licence Conditions and Codes of Practice (LCCP) Social Responsibility (SR) Code 5.1.12 - Direct marketing preferences) requiring licensees to provide customers with options to opt-in to direct marketing on a per product and per channel basis. This will come into effect in May 2025. Although there is some overlap in expected outcomes, these are distinct policy interventions. The proposal to ban the mixing of incentives is not about direct marketing, instead it is about the basis of the incentive. It applies to incentives wherever they may appear, for example, licensees’ websites, programmatic online marketing and so on, not just those sent by direct means. It seeks to protect a broader range of consumers, not just those who hold a gambling account with a licensee and who have opted in to receive direct marketing about certain products.
For clarity, the term incentive covers activity that encourages a person to gamble, covering the range of inducements made available by licensees. These are sometimes described as promotional offers.
We confirm that the aim of this proposal is to ban the mixing of products within an individual incentive or promotional offer, where terms are linked and shared.
Gambling licensees will be permitted to send more than one offer on products via the same channel, according to the marketing preferences opted in by the customer. For example, should a customer opt-in to receiving marketing for betting and casino products, a licensee can send bonus offers for betting, and bonus offers for casino products, within the same email.
Clarification on incentives containing credit or bonus money
We do not consider the proposed ban to affect incentives which allow the customer to select the product on which to use credits or bonus money. For example, an incentive which provides a customer with £10 ‘credit’ to use as they wish on products is permitted.
Evidence base and research
We took on board respondents’ concerns raised on the evidence base and points that research did not substantiate claims that the mixing of products could impact consumer understanding of an offer.
We revisited the methodology used in our Consumer Voice research programme (2023) and are satisfied that we have used a rigorous, consistent, and transparent evidence assurance process to collate, interpret and weigh up the overall strength of the evidence base for this topic. We are also ensuring that we have access to a range of research approaches to answer complex questions on this topic via the procurement of the next iteration of our Consumer Voice programme.
We consider that the evidence base outlined in the consultation document, combined with consultation responses, is sufficient to support proceeding with the intervention to ban mixing of products within incentives.
For the purposes of correcting grammar, we have made one minor change to the final wording to the LCCP SR Code provision, which replaces ‘the’ with ‘an’ incentive.
Final wording
This requirement will come into force on 19 December 2025.
Applies to: All licences (including ancillary remote licences), except gaming machine technical and software licences.
LCCP Social Responsibility Code 5.1.1 Rewards and Bonuses
- Licensees must not:
b. include more than one type of gambling product (betting, casino, bingo, and lottery) within an incentive.
Proposal 1 - Ban or limit the use of wagering requirements Next section
Proposal 3 - Proposed changes to Licence Conditions and Codes of Practice (LCCP) Social Responsibility (SR) Code 5.1.1 (Rewards and Bonuses) to make the structure and wording clearer
Last updated: 26 March 2025
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