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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 B - Identify - Requirement 7

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.

7. A licensee’s systems and processes for customer interaction must flag indicators of risk of harm in a timely manner for manual intervention, and feed into automated processes as required by paragraph 11.


To ensure that once licensees identify harm or potential harm that action is taken in a timely way to minimise further potential harm. The greater the harm identified the more important it is to take swift action, often this is best achieved by automated processes.

Formal guidance

We have seen examples through our casework of licensees correctly identifying harm but then not acting sufficiently quickly so the harm is exacerbated before they act. It is therefore important that systems and processes are developed to flag indicators of harm in a manner that allows for swift action to minimise harm. Where this action is manual, the processes must take account of the time for manual action to be taken.

The licensee will need to include indicators of harm and aggregated indicators that trigger automated action. In many cases, automated action will be appropriate due to volume of customers and inability to be able to monitor accounts manually. Where such automated processes are applied, the licensee must manually review their operation in each individual customer’s case and the licensee must allow the customer the opportunity to contest any automated decision which affects them. For example, if a significant level of harm is identified, it will often be appropriate to place a block on further gambling until an action has taken place.

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Section B - Identify - Requirement 6
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