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This response sets out our position in relation to the consultation on socially responsible incentives
Published: 26 March 2025
Last updated: 26 March 2025
This version was printed or saved on: 23 May 2025
Online version: https://www.gamblingcommission.gov.uk/consultation-response/autumn-2023-consultation-proposed-changes-to-lccp-and-rts-socially
In April 2023, the then government published its white paper High Stakes: gambling reform for a digital age (opens in new tab), which set out a plan for reform of gambling regulation following a review of the Gambling Act 2005.
In Autumn 2023, we consulted on a number of changes to the Licence Conditions and Codes of Practice (LCCP) requirements placed on gambling businesses. This consultation package included the second set of proposed changes to the regulatory framework required to implement the Gambling Commission’s commitments as part of that review.
This response sets out our position in relation to the consultation on socially responsible incentives.
The aim of the consultation was to ensure that incentives such as free bets and bonuses are constructed in a socially responsible manner and do not encourage excessive or harmful gambling.
We consulted on proposals to ban or limit the use of wagering requirements in promotional offers and a proposal to ban the mixing of product types (for example, betting, bingo, casino and lotteries) within incentives. We also consulted on changes to the section of LCCP that covers rewards and bonuses to make it explicit that incentives should be constructed in a manner that does not lead to excessive or harmful gambling.
The consultation covered 3 issues.
The evidence showed that high levels of wagering requirements attached to bonuses can lead to higher intensity of gambling activity, and adds complexity to offers, which in turn increases the risk of excessive gambling and risk of harm. Therefore, we consulted on 2 alternative proposals to address this issue, which were:
Some promotional offers are structured to combine different product types, primarily for new customer sign up offers. This typically involves gambling licensees providing a combination of free bets and free casino spins. The evidence shows that these can be problematic because they can lead to consumer confusion and likelihood of experiencing harm. We therefore consulted on a proposal to introduce a ban on the mixing of product types within promotional offers, for new and existing customers.
LCCP Social Responsibility Code 5.1.1 (Rewards and Bonuses) sets out rules to ensure incentives are constructed in a socially responsible manner. Based on compliance engagement and casework, it was apparent that the structure and wording of aspects of this provision are not as clear as they ought to be. Therefore, we consulted on a new structure and wording to make it explicit that incentives should be constructed in a manner that does not lead to excessive or harmful gambling.
On 29 November 2023 we issued our consultation on a number of changes to the LCCP and RTS requirements (opens in new tab) placed on gambling businesses, including socially responsible incentives. The consultation ran for 12 weeks until 21 February 2024.
Annex 1 lists organisations that consented to the publication of their name when responding to the consultation.
Following careful consideration of the responses received during the consultation, we have decided to proceed with:
We have decided not to proceed with the proposed wording requiring licensees to ‘ensure the design and structure of the incentive does not lead to excessive intensity of gambling which may risk customers experiencing harms associated with gambling.’
These new elements of the LCCP will come into effect on 19 December 2025.
On 29 November 2023 we issued our consultation on a number of changes to the LCCP and RTS requirements (opens in new tab) placed on gambling businesses, including socially responsible incentives. The consultation ran for 12 weeks until 21 February 2024.
We received 74 written responses to the consultation from the following categories of respondents:
Annex 1 lists organisations that consented to the publication of their name when responding to the consultation.
We consulted on 2 alternative options to address this issue:
If one of these proposals were to be adopted, which do you prefer? Choose one of the following: Option A – ban wagering requirements, or Option B – cap wagering requirements.
To what extent do you agree with the proposed option A to ban wagering requirements? Please give your reasons, including any evidence.
To what extent do you agree with the proposed option B to cap wagering requirements? Please give your reasons for your answer.
If wagering requirements were to be capped, which threshold do you prefer? Please give your reasons, including any evidence.
Do you have any further comments on these proposals?
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 these proposals, identifying to which proposals the estimated costs relate.
Responses showed that, when asked which option is preferred, just over half agreed with a limit, while just under half agreed with a ban. A few respondents who supported a ban, also noted that, should a limit be introduced, no more than 1 times would be acceptable.
Regarding Option A, the main themes and comments in support of a ban were as follows:
Respondents representing charities and academic organisations, commented they agree with the evidence provided in the consultation document, that wagering requirements could lead to customers gambling excessively. A few respondents commented that although there is limited evidence on the impact of wagering requirements, there is evidence to support greater restrictions on marketing and advertising more generally. Some respondents provided comments and research to demonstrate a case to ban all new customer sign up offers and incentives more widely.
Respondents suggested that customers are unable to estimate the true economic value of an offer and very high wagering requirements lead to lower comprehension of how much is needed to bet when taking up an incentive. Therefore, a ban should lead to terms and conditions that are shorter and easier to read.
High value offers are often constructed by applying high wagering requirements which could have negative and disproportionate effects on vulnerable adults.
Regarding Option B, the main themes and comments in support of applying a limit were as follows:
Most of those who responded agreed that high wagering requirements are detrimental to consumers.
Most respondents representing the gambling industry strongly disagreed with a ban. They consider a limit would lead to offers being financially unviable for the operator. There is a concern that, by not applying some wagering requirements, organised groups will take advantage of free offers at a large scale and increase identity theft and/or bots obtaining 'free money'. Respondents stated that this could leave operators in a position where action designed to meet the licensing objective of protecting vulnerable people from harm could have a detrimental effect on the licensing objective to keep crime out of gambling.
Some operators expressed concern that a ban could lead to increased fraud and money laundering issues. This point was primarily linked to the previous point, that a ban, or limit of less than 10 times wagering requirements, would allow organised groups to take advantage at a large scale.
Respondents commented that limits will allow the market to remain competitive with less impact on smaller and/or medium operators, giving commercial freedom to provide varied promotions. A limit is also preferable to avoid proliferation of the illegal online market.
Some comments, including from a few customers, focused on the impact on customers, noting that they enjoy taking up offers and see a ban as a restriction of consumer choice.
Most consider a maximum of 10 times wagering requirements to be the lowest appropriate threshold. One operator provided a breakdown which showed that 75 percent of their offers apply within the 1 to 10 times wagering requirements. A trade association made specific points that only 10 times would suffice, due to little evidence base for 1 to 5 times wagering, and that anything less than 10 would be, in effect, a ban, leading to less consumer choice.
A few respondents commented that the impact of a cap on wagering requirements will also need to consider the Game Contribution Restrictions, also referred to as Weighting, which is applied to control how quickly a customer can play through a game. For example, a bonus might carry 10 times wagering requirements on all slots but will be weighted at 50 percent for blackjack and 30 percent for roulette. This means that if you have a £100 bonus with 10 times wagering requirement and you decide to play a casino game like roulette with a 30 percent weighting, each £1 you wager contributes 30 pence towards the wagering requirement.
Most operators commented that the implementation of any changes would take, on average, 6 months.
We have considered the comments and concerns raised by stakeholders in the consultation responses.
In relation to the concerns that a ban could lead to increased fraud and money laundering issues, respondents did not provide clear evidence to support this claim via consultation responses or via our post consultation engagement with industry. We have engaged with the industry, in the past, about mule accounts and risks to money laundering and terrorist financing, and alongside our review of casework and other intelligence sources, we did not find evidence to substantiate these claims. Therefore, we consider it to be low risk that a ban or low limits, could lead to increased fraud and money laundering within the sector.
Our engagement with gambling licensees has identified that low levels of wagering requirements are sometimes necessary as a means to prevent gamblers from taking away ‘free’ money which could have a commercial impact, such as a high cost to offering incentives without such mechanics in place. We consider this links to the points, made by some respondents, that some customers may be part of organised groups and use systems to enable them to collect large quantities of offers, in a short period of time. However, although we understand the impact of such action, we expect gambling licensees to have robust systems in place to undertake appropriate checks at registration and further Know Your Customer (KYC) checks to prevent this.
We understand the concerns about Games Weighting Contributions attached to wagering requirements and the impact this could have on how much a customer needs to gamble to meet the wagering requirements. There are many reasons why licensees choose to add weightings, primarily to strike a balance between customer engagement and limiting the licensees’ exposure to financial risk. Where weightings are applied, it could give customers the opportunity to experience wider games with the bonus. From the current evidence, we do not think it is necessary to review rules on weightings attached to wagering requirements at this time. We would expect any terms and conditions, including those relating to wagering requirements, to be clear and transparent to consumers. However, we will keep under review the impact of our proposals on consumers.
We recommend proceeding with Option B, to implement a maximum of up to 10 times wagering requirements within incentives. This means that any wagering requirements attached to incentives (such as bonuses) must not exceed 10 times the incentive amount. Our view is that this would meet the policy aims while maintaining a degree of consumer choice and mitigating the risk of displacement to the illegal online market.
In reaching our decision, we decided not to pursue a ban, and very low wagering requirements such as those set up to a maximum of 1 and 5 times, for the following reasons:
We consider this to be a proportionate response to the issues and risks identified in the consultation. Under Licence Condition 7.1.1 (Fair and open terms and practices), licensees are required to ensure terms and practices are fair, transparent, and not misleading. If we see poor behaviour and the emergence of particularly onerous terms and conditions attached to wagering requirements, particularly if the Games Weighting Contributions are changed to have a considerable impact on customers, we could take action and consider consulting on further changes, including the option to ban.
For the purposes of ensuring we use the correct terminology, we have made one minor change to the final wording to the Licence Conditions and Codes of Practice (LCCP) provision, which replaces ‘consumer’ with ‘customer’.
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.
a. Apply wagering requirements to incentives, which require customers to play through bonus funds, over a maximum of 10 times. A wagering requirement is where a customer is required to make wagers totalling a particular value for funds to become withdrawable.
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.
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.
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:
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:
We have considered the comments and concerns raised by stakeholders in the consultation responses.
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.
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.
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.
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.
b. include more than one type of gambling product (betting, casino, bingo, and lottery) within an incentive.
Licence Conditions and Codes of Practice (LCCP) Social Responsibility (SR) Code 5.1.1 (Rewards and Bonuses) sets out rules to ensure incentives are constructed in a socially responsible manner. We sought views on our proposal to make changes to the drafting and structure of LCCP SR Code to make it clearer and easier to understand.
We proposed to restructure it to set out what licensees must and must not do where they make such incentives available. We proposed to make minor changes relating to the tense and order of words, and to make the requirements regarding terms and conditions clearer. The proposed revisions also included the previous proposals on wagering requirements and mixing of products, so that it is clear how this would be presented if they were to be implemented.
We also consulted on the proposal to delete the current LCCP SR Code 5.1.1 1(b)(i) which currently states ‘neither the value nor amount of the benefit is dependent on the customer gambling for a pre-determined length of time or with a pre-determined frequency’. We consulted on new wording to make it explicit that licensees must ensure the design and structure of the incentive does not lead to excessive intensity of gambling which may risk customers experiencing harms associated with gambling.
To what extent do you agree with the new structure and proposed wording of LCCP SR Code 5.1.1, excluding views on proposed requirements on wagering requirements and mixing of products which are dealt with above? Please give your reasons, including any evidence.
Do you have any comments on the new wording of 2 (b) which replaces LCCP SR Code 5.1.1 1(b)(i) which states ‘neither the value nor amount of the benefit is dependent on the customer gambling for a pre-determined length of time or with a pre-determined frequency’.
Most respondents agreed with the need to make changes to the structure, wording and the policy intent of LCCP SR Code 5.1.1. The comments were as follows:
We have considered the comments and will proceed with proposed changes to the structure and minor wording changes to the LCCP SR Code provision.
We agree with industry representations that the proposed wording requiring licensees to ‘ensure the design and structure of the incentive does not lead to excessive intensity of gambling which may risk customers experiencing harms associated with gambling’ poses a number of issues, including the difficulty in defining the term ‘excessive intensity’.
We recognise that there is a diverse range of incentives available in the market which makes it challenging to develop further principles that meet the policy intent, via LCCP SR Code 5.1. The challenge has been to find suitable wording that better reflects what is, or is not, acceptable, distinguishing between the innocuous and harmful incentives. The acceptability of an incentive depends upon the context in which it is offered or accepted, and on its impact on the licensing objectives. At this stage, we do not think that the provision of licensee guidance alone on this topic would provide a viable alternative.
Taking into account consultation responses, we will not proceed with proposed drafting of the requirement on licensees to ensure incentives are constructed in a manner that does not ‘lead to excessive intensity’ of gambling. Although LCCP SR Code 5.1.1 does not currently state which incentives or mechanics are likely to be socially irresponsible, there are controls and requirements already in place, within the Gambling Commission’s regulatory framework and advertising regulations, designed to address the risk of gambling harms.
Given that respondents did not disagree with the deletion of the current LCCP SR Code 5.1.1 1(b)(i) which states ‘neither the value nor amount of the benefit is dependent on the customer gambling for a pre-determined length of time or with a pre-determined frequency’, we will proceed with deleting this requirement.
In relation to other points raised by respondents, our position is as follows:
Use of terminology ‘free’ within incentives – respondents were concerned that this implies that the offer is ‘free’, and claims that money can be won without risk. The Committee of Advertising Practice (CAP) has banned gambling licensees from presenting offers as entirely ‘risk free’ and have published guidance on the use of “free” claims in advertising (opens in new tab). While “free” claims in general are not prohibited, they must not be presented irresponsibly.
The Regulators’ Code to support the need for guidance - we take our duties to consider the Regulators’ Code seriously and will do so in the event we take steps to propose further changes to the provision or publish guidance.
This consultation sought to prioritise action on 2 mechanics (wagering requirements and mixing of products withing incentives), but this does not prevent us from prioritising other mechanics that may be of concern, which may lead to us consulting on further revisions to this, or other marketing codes, at a later stage. We will consider potential further policy development work based on the outcome of evaluation on the impact of the following:
We have made a few minor changes to current wording of LCCP SR Code 5.1.1, for example, changing ‘the’ to ‘an’, and deletion of plurals. These changes have been made to improve the grammar, which is reflected in the final wording.
Licensees must take into account the Commission’s guidance on high value customer incentives.
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.
The following applies where a licensee makes available to any customer, or potential customer, an incentive or reward scheme or other arrangement under which a customer may receive money, goods, services or any other advantage (including the discharge in whole or in part of any liability of his) (‘the benefit’).
Licensees must:
Licensees must not:
If a licensee makes available an incentive or reward scheme for customers, designated by the licensee as ‘high value, ‘VIP’ or equivalent, it must be offered in a manner which is consistent with the licensing objectives.
Licensees must take into account the Commission’s guidance on high value customer incentives.
The Gambling Commission works to assess progress towards the key commitments set out in our Corporate Strategy. This includes increasing our capacity to evaluate new requirements and policies, with particular focus on the commitments we are responsible for in the Gambling Act Review White Paper (opens in new tab)(white paper) and supporting efforts by government and others to evaluate the impact of the white paper reforms.
The Commission and Department for Culture, Media and Sport (DCMS) have jointly commissioned the National Centre for Social Research (NatCen) to deliver the evaluation. DCMS published an overview of the evaluation plan in December 2024 (opens in new tab) and we published an accompanying blog post. The approach designed, and currently being delivered by NatCen, addresses challenges identified by stakeholders responding to the Autumn 2023 consultation. This includes challenges around complexity, unintended consequences, and the need for inclusion and robustness. More details on how the evaluation responds to these challenges can be found in our consultation response published in February 2025.
The Socially Responsible Incentives policy is included in the scope of the evaluation. Research will take place over the coming months to understand the outcomes and impacts of the policy change. Research methods will include longitudinal consumer surveys with people who gamble; operator surveys; in depth interviews with operators and consumers; and tracking and monitoring. In addition, the Commission is seeking ways to complement the external evaluation with ongoing data collection to understand implementation and collect further data to understand outcomes and impacts.
One area we are actively exploring – alongside the Commission’s Data Innovation Hub - is quantification of changes to incentives before and after the policy change using data science approaches. This contributes to another commitment in our Corporate Strategy, to use data and analytics to make gambling regulation more effective. Further work on monitoring and evaluation will be completed in the coming months to better evidence the changes happening as a result of the policy. This is likely to include analysis of secondary data (information already held by the Commission) but may also extend to further small-scale qualitative research. There will be a focus on learning from the consultation process as well as understanding how the measures have been implemented by licensees.
We are committed to giving consideration to potential equalities impacts, having regard to the need to eliminate discrimination, advance equality of opportunity and foster good relations between those who share a protected characteristic and those who do not. Our position as a result of the initial assessment was set out in the consultation, which was that the Gambling Commission does not currently consider that the proposals set out in this incentives section of the consultation give rise to known negative impacts in the context of the policy objectives.
We invited views, evidence or information which might assist the Commission in considering any equalities impacts in the context of the proposals. We received a small number of responses to help inform our assessment of the equalities impacts of the proposals. The comments applied across all proposals for this topic and are as follows:
Two respondents provided comments on the need to maintain consumer freedom and choice to gamble, but did not point to how this could impact negatively on those who share a protected characteristic.
One respondent provided comments on the impact of gambling and incentives in relation to race, sex, and disability. Evidence was provided on how gambling harms could disproportionately affect BAME adults, female online gamblers, and those experiencing disabilities, including mental health impacts. The respondent commented that the policy proposals would have a positive impact on these groups. Consumers who are not already regularly participating in online gambling are unlikely to be affected by the policy, mitigating against possible over-representation of BAME adults, female online gamblers, including those experiencing disabilities and mental health impacts.
One respondent commented that young adults would be additionally impacted by gambling harms due to them being more vulnerable to receiving and taking up offers. In the government’s white paper, evidence showed that people aged 18 to 24 years old are generally more vulnerable to gambling-related harms than the wider population of young adults (see section 5.4 Protections for young adults) (opens in new tab), which was supported by evidence in our advice to government. The proposals are designed to protect all consumers, therefore young adults would not be adversely affected, but for whom the proposals would have additional benefits in terms of reducing the risk of gambling harm.
Having taken into account the consultation responses, our position remains the same, which is that our assessment is that the proposals do not present a negative impact on the protected characteristics stated within the Equality Act 2010, and they do not contribute towards unlawful discrimination, harassment or victimisation and/or other conduct prohibited by the Act.
We received a number of responses that provided information about implementation and estimates of the direct costs associated with implementing the proposals. These are as follows:
We have considered the impacts on business, to inform the Commission’s proposed position and recommendations. We have taken account of guidance to the Commission from the Regulatory Policy Committee about measuring the business impacts of our policy proposals. Overall, we consider any costs are proportionate and justifiable in terms of the benefits to consumers and in the context of the stated policy intent to ensure that incentives are constructed in a socially responsible manner and do not encourage excessive and harmful gambling.
In considering the implementation timeframe for the changes set out in this response document, we have considered the length of time needed to make these specific technical changes, and the sequencing and scheduling of other legislative and regulatory changes being implemented by government and the Commission. In doing so, we have taken into account feedback from industry stakeholders.
With that in mind, we have set an implementation date of 19 December 2025 for the changes set out in this document to come into effect.
Annex 1 lists organisations that consented to the publication of their name when responding to this consultation topic. All names of organisations have been presented as provided by the respondents that submitted the response.
Organisations and individuals representing organisations that consented to the publication of their name when responding to the consultation: