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Customer interaction guidance - for remote gambling licensees (Formal guidance under SR Code 3.4.3 - not in effect)

Customer interaction guidance for remote gambling licensees (Formal guidance under Social Responsibility Code 3.4.3 - not in effect)

Section D - Evaluate - Requirement 14

This guidance was originally published in June 2022. It is not in effect and operators are not required to take it into account.

Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling licensees has been introduced and the majority of requirements are in effect from 12 September 2022.

We have issued this update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators. We intend to conduct further consultation on matters to be addressed in the guidance associated with Social Responsibility Code Provision 3.4.3, by way of a consultation on the guidance document itself, likely to commence in late September. This consultation will be available on our consultations page.

14. Licensees must take account of problem gambling rates for the relevant gambling activity as published by the Commission, in order to check whether the number of customer interactions is, at a minimum, in line with this level. For the avoidance of doubt, this provision is not intended to mandate the outcome of those customer interactions.


Customer interaction is designed to identify customers at risk of harm. If the licensee’s systems do not identify numbers of customers at least in line with the problem gambling rates for the relevant activity, those systems are likely to be failing to identify the right proportion of customers.

This requirement provides a backstop protection – to ensure that customer interaction takes place as a minimum for the proportion of the customer base as the problem gambling rate for the gambling activity (or activities).

Formal guidance

Systems and processes must be designed to as a minimum undertake customer interactions with at least the same proportion of their customer base as the problem gambling rate for the gambling activity or activities they offer. Because licensees should be identifying people at risk of harm the proportion of customers who receive a customer interaction should be greater than the problem gambling rate. Operators must ensure that they are on track to meet the minimum levels of customer interactions over an annual period, and to do so should assess progress monthly.

The Commission considers that the current problem gambling rates relevant for this provision are the problem gambling rates from the Health Survey for England: Supplementary analysis on gambling (2018) (opens in a new tab), and specifically the problem gambling rates for the individual activities.

We consider this to be appropriate for all licensees, although the survey is based in England. Therefore the rates for each activity are:

  • online gambling on slots, casino or bingo – 8.5 percent of customers
  • online betting with a bookmaker – 3.7 percent of customers
  • other lotteries – 1.3 percent of customers.

We will update the guidance over time where we consider it necessary to reflect recent problem gambling prevalence statistics.

Operators who offer more than one product or activity will need to work out their overall problem gambling rate to check they are compliant with this requirement. This should be based on the proportions of gross gambling yield (GGY) that they generate for each activity. For example, casino games have a higher problem gambling rate. Where a licensee generates more GGY from casino games than from betting, the overall problem gambling rate for this requirement should be proportionate to the GGY from each activity.

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Section D - Evaluate - Requirement 13
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