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New remote Customer Interaction requirements and guidance update

02 September 2022

Remote gambling operators are advised to read this update on the introduction of new remote Customer Interaction requirements and guidance.

In April this year, the Gambling Commission published a set of new requirements, Social Responsibility Code Provision 3.4.3, which ensured that remote gambling operators had to do more to identify customers at risk of harm. Guidance to assist operators to comply with these requirements was published in June. These new requirements, and the accompanying guidance, were due to take effect on 12 September 2022.

The industry has requested an extension to the timeframe for implementing these new requirements. This is due to the technical challenges that some remote operators indicate they are facing in delivering full compliance by the 12 September 2022 deadline.

After careful consideration, we have decided that the majority of the new requirements will come into force as planned on 12 September. Remote gambling operators are already subject to a duty to conduct effective customer interaction, and the new requirements reflect the minimum steps that we consider are necessary to meet that duty.

However, we have also decided that the following requirements will not be brought into effect in September:

  • The requirement to take timely action where indicators of vulnerability are identified and to take account of the Commission’s approach to vulnerability as set out in the Commission’s guidance (paragraph 3)

  • The requirement to prevent marketing and the take-up of new bonus offers where there are strong indicators of harm (paragraph 10).

In light of this extension, the Commission considers that it would be beneficial to use the time now available to conduct further consultation on matters to be addressed in the guidance associated with SR Code 3.4.3, by way of a consultation on the guidance document itself. Therefore, the requirement to take into account the Commission’s guidance on customer interaction for remote operators (paragraph 2, and the reference to the guidance in paragraph 1) will also not be brought into effect in September.

The guidance is a living document which is intended to be amended over time. As part of the consultation, we will be particularly interested to hear about good practice in implementing the requirements, based on the lessons learned by operators during the period between April and September and to hear about any implications arising out of recent research, evidence and casework.

The consultation is likely to be launched during late September and will last six weeks. All views expressed in response to this six-week consultation will be carefully considered before a decision is taken on the contents of the guidance on the new requirements.

Subject to consultation, the Commission’s provisional intention is to publish the guidance on the requirements in December 2022, with it taking effect approximately 2 months after publication. In the circumstances, we consider this will allow the industry a reasonable period to consider the guidance before it takes effect.

It is the Commission’s intention, subject to consultation, to bring the remaining requirements of SR Code 3.4.3 and the associated guidance into effect on 12 February 2023.


Last updated: 2 September 2022

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