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Customer interaction guidance - for remote gambling licensees (Formal guidance under SR Code 3.4.3)

Customer interaction guidance for remote gambling licensees (Formal guidance under SR Code Provision 3.4.3).

Section C - Act - Requirement 9

This current guidance was issued in August 2023 and is in effect from 31 October 2023. It replaces all earlier versions of guidance issued for remote gambling operators.

9. Licensees must tailor the type of action they take based on the number and level of indicators of harm exhibited. This must include, but not be limited to, systems and processes which deliver:

  • a. tailored action at lower levels of indicators of harm which seeks to minimise future harm
  • b. increasing action where earlier stages have not had the impact required
  • c. strong or stronger action as the immediate next step in cases where that is appropriate, rather than increasing action gradually
  • d. reducing or preventing marketing or the take-up of bonus offer where appropriate
  • e. refusing service or ending the business relationship where necessary.


There are two key aims of this requirement:

  • to set minimum requirements for the type of action that must be included within a licensee's systems and processes to minimise harm
  • to ensure that a licensee’s response is proportionate to the indicators of harm.

Formal guidance

9.1. Licensees have a range of actions they will apply in response to identified indicators of harm. This measure requires licensees to have the suite of actions set out in requirement 9 paragraphs a to e in place. In addition to this suite of actions, there are separate safer gambling and preventative measures that licensees may also use such as reducing risk to customers upfront through product and system design and the provision of generic safer gambling messages. At any time, if a customer is seeking help, a hot transfer to support may be appropriate.

The following content sets out information and guidance about the customer interaction suite of actions in requirement 9.

Early tailored action

At lower levels of indicators of harm which seeks to minimise future harm.

Actions at this level would include:

  • the licensee encouraging the customer to use the gambling management tools they offer through pop-ups, safer gambling emails or other
  • sharing information on spend or behaviour to encourage change
  • having in place backstop protections or limits while checks are being undertaken
  • enhancing their knowledge and monitoring of the customer.

Medium tailored action

Increasing action where earlier stages have not had the impact required.

Actions at this level would include:

  • phone calls to conduct a customer interaction
  • more emphasis on tailored encouragement for the customer to consider behaviour
  • signposting to help and support
  • limiting direct marketing.

Medium strong or Strong

As the immediate next step in cases where that is appropriate, rather than increasing action gradually.

Actions at this level would include:

  • requiring the customer to set a spend limit
  • using technological solutions to help support a customer for example by reducing the visibility of products in a tailored way
  • preventing the take up of new offers or incentives
  • setting spend limits or setting time outs on behalf of a customer.

Very strong

Ultimately, if the licensee’s concerns about a customer persist because the licensee’s actions have not resulted in sufficient protections in place or behaviour change by the customer, the licensee should refuse service or completely end the business relationship. In these cases, signposting to support and help will be important.

Examples of types of action at increasing strength levels

A visualisation of the types of actions at increasing strength levels is set out as follows:

  1. Early tailored customer interactions

    Encouraging the use of gambling management tools through pop-ups, emails or other.

    Sharing information on spend or behaviour to encourage change.

    Setting backstop limits for customers while checks are being conducted.

    Enhanced checks and/or enhanced monitoring.

  2. Medium tailored customer interactions

    Phone calls to conduct an interaction.

    More emphasis on tailored encouragement to customers to consider behaviour.

    Signposting to help and support.

    Limiting direct marketing.

  3. Medium-strong customer interactions

    Requiring the customer to set a spend limit.

    Technology solutions: reducing the products visible to the consumer.

  4. Strong customer interactions

    Preventing direct marketing or access to new bonus offers.

    Setting spend limits on behalf of customers.

    Setting a time out on behalf of a customer.

  5. Very strong customer interactions

    Ending the customer relationship.

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Section C - Act - Requirement 8
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Section C - Act - Requirement 10
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