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Gambling Commission report focusing on research conducted into high value customer and VIP scheme monitoring
Published: 17 July 2025
Last updated: 17 July 2025
This version was printed or saved on: 20 July 2025
Online version: https://www.gamblingcommission.gov.uk/report/high-value-customer-and-vip-scheme-monitoring
In 2020, the Gambling Commission strengthened restrictions on VIP or High Value Customer (HVC) schemes to make sure they are not used to exploit gamblers1.
The initial impact on the reduction of HVC scheme members in 2021 was included in the Commission’s Advice to Government – Review of the Gambling Act 2005 document2, including an estimated reduction of 90 percent in the number of customers signed up to schemes. This report presents a further consideration of the impact of the restrictions to VIP or High Value Customer (HVC)3 schemes.
The evidence presented in this report indicates that there have been no significant changes to the prevalence or membership of HVC schemes since the 2021 review and did not identify any concerning trends regarding the manner in which existing schemes are operating. This report also outlines that there has been a reduction in Commission casework referencing HVC schemes or targeted incentivisation since the policy was introduced.
Through this exercise, we have increased our understanding of the way that HVC schemes are being operated and differences within the market; these insights now form part of the Commission’s considerations when conducting compliance reviews on this topic.
Amongst this sample of licensees, there has been no significant change in the proportion of respondents with a HVC or VIP scheme in 2024 (60 percent) compared to 2021 (55 percent). This remains lower than 2020, prior to the regulatory changes, where two thirds (67 percent) of respondents reported having an HVC or VIP scheme.
There is no growth in the number of customers enrolled on HVC or VIP schemes between 2021 to 2022 and 2023 to 2024; the number of customers on average remains at a much lower level than the pre-policy position.
The number of cases considered by the Commission where HVC or VIP schemes or inappropriate customer incentivisation was reported to be a potential factor has decreased significantly since the policy change.
An examination of the Commission’s contact centre data and independent third-party complaints data shows there is no widespread consumer concerns about HVC schemes being reported.
HVC or VIP schemes represent approximately 3 percent of overall operator Gross Gambling Yield (GGY) for the sample of 12 respondents who returned data in 2024.
Respondents with higher shares of GGY generated by HVC schemes (10 percent and above), were more likely to be non-remote casino operators. The 4 non-remote casinos reported a higher GGY from HVC schemes than remote operators and the trend shows increasing GGY from HVC scheme members for these non-remote casinos.
Respondents with larger operations (GGY £100 million and above) most commonly had HVC schemes accounting for less than 1 percent of their overall GGY.
All respondents reported that they had a Senior Executive (Personal Management Licence (PML) Holder) appointed to oversee and be held accountable for the operation of HVC or VIP schemes.
Respondents reported that financial risks for members of HVC schemes were specifically considered through independent checks or financial assessments, which were completed more frequently compared with non-HVC customers. Additional measures (for example, operator-imposed deposit limits) were also in place among many operators.
The majority of operators monitored additional markers of harm for HVC or VIP customers, as well as those that are monitored for all customers, and operators tended to check for previous self-exclusions through their onboarding processes.
The majority of operators had quarterly reviews in place to ensure information about their HVC or VIP customers was kept up to date, although in some cases other triggers or manual review processes meant this was even more frequent.
Some operators told us there were good structures in place to manage commercial conflicts of interest, including use of separate safer gambling teams, and oversight through governance structures.
The majority of operators told us they did not use affiliates or ‘introducers’ in promoting their HVC or VIP schemes.
While some operators have targets and incentives for staff in relation to growth of customer numbers, these are generally not linked to HVC or VIP schemes with the exception of 2 respondents who did so on a growth per quarter basis, or on the basis of membership-only and not related to spend.
The majority of respondents were not aware of any unintended consequences as a result of the change in policy.
The findings from this report will form considerations for ongoing compliance assessments, with particular relevance for the non-remote casino sector. Colleagues that consider casework will also continue to monitor for any changing trends in contributory factors, including the topic of HVC or VIP schemes.
1 Changes to the licence conditions and codes of practice on High Value Customers.
2 Advice to Government - Review of the Gambling Act 2005 .
3 Individuals whose gambling custom is of high commercial value to licensees are often referred to as Very Important Persons (VIPs), ‘high value customers (HVCs)’ or equivalent. These customers are often provided with enhanced customer service unavailable to the wider customer base.
In 2020, the Gambling Commission strengthened restrictions on VIP or High Value Customer (HVC) schemes to make sure they are not used to exploit gamblers1. The Gambling Act Review (GAR) White Paper included an action for the Commission to “continue to closely monitor practices around online VIP schemes to make sure they are not used to exploit at-risk gamblers.”2
In line with the Commission’s commitment to proportionate policy monitoring and evaluation, the Commission’s response document set out how this would be progressed: “we will measure their effectiveness through compliance assessments and monitoring the volume of enforcement casework related to HVCs from the point at which the requirements take effect.”
This report presents our findings with respect to the monitoring of HVC or VIP schemes. We do not limit our monitoring only to remote and/or online schemes, but broaden this out to consider the entirety of schemes falling under the licence conditions and guidance (that is to include non-remote operators). This report has the following structure:
1 Changes to the licence conditions and codes of practice on High Value Customers.
2 High stakes: gambling reform for the digital age - GOV.UK (opens in new tab)
Our approach to monitoring and evaluation of practices around High value Customer (HVC) or VIP schemes is theory-based. As recommended in the government’s Magenta Book (opens in new tab), we established a theoretical model of how we expect a policy change to affect a desired change. We often use a Theory of Change to this end, with the Theory of Change subsequently acting as a way to best guide data collection.
The Theory of Change reflects the position that – prior to the policy change – HVC schemes contributed to gambling-related harms by encouraging gambling beyond the means of some consumers and operated with insufficient personal accountability within some operators, contributing to practices that lacked openness. In response to this, the change in regulations was introduced in October 2020.
Assumptions included in the Theory of Change were that operators adopt compliant practices, for example, do not close or reduce schemes in name-only, or permit affiliates to circumvent the requirements.
Subject to those assumptions being accurate, the subsequent anticipated outcomes include:
It is these outcomes that the Theory of Change envisages will contribute to the end goals of HVC or VIP and at-risk customers being less likely to experience gambling-related harms, and operator practices in respect of HVC or VIP schemes being more consistent and open to scrutiny.
From the Theory of Change, and in response to the approach set out in the White Paper, we present 3 statements or hypotheses that we aimed to test. We explain each hypothesis in turn.
The original exercise led by the Gambling Commission’s compliance team in 2021 showed that many operators had closed their HVC or VIP schemes following the introduction of the new regulations. As reported in the Commission’s GAR Advice Paper, there was a reduction of approximately 90 percent of the number of customers on HVC or VIP schemes.
Further analysis of compliance responses (n=33)1 from 2021 reveals that 15 percent of operators that had a scheme in place prior to the regulatory change subsequently closed their scheme, and a third either greatly or significantly reduced their numbers. On average (before the changes) each operator reported over 1,000 customers enrolled on HVC or VIP schemes, which reduced significantly to under 100 customers after the changes were introduced. Many attributed the reduction in schemes, or numbers enrolled on schemes, to the change in regulation.
This report builds upon the 2021 exercise to explore the degree to which VIP or HVC schemes are associated with Gross Gambling Yield (GGY) amongst the sampled operators. The extent to which HVC or VIP schemes are currently offered in a market increasingly driven by remote activities is important: the Theory of Change includes an outcome linking the tightening of rules to a reduced reliance on HVC or VIP schemes as a share of GGY. We therefore collected data on the degree to which such schemes contribute to operator GGY to further understand market dynamics.
1 n= typically refers to the number of observations or individuals in a sample.
The rationale and premise of the policy change, as articulated in the original consultation (opens in new tab), was that there were 4 areas of consistent concern about operators’ use of High Value Customers (HVC) or VIP schemes:
Assessing and mitigating risk (knowing your customer) - Membership of a HVC or VIP scheme is conditional on robust ‘know your customer’ or due diligence checks. This had not been the case in a number of occasions. Common issues emerging from the Gambling Commission’s casework included failures to undertake appropriate initial and ongoing checks, or accepting limited or questionable source of funds evidence. Information on customer accounts had highlighted practices that aimed to increase customer spend to the exclusion of other considerations.
Accountability and/or oversight of HVC teams - Dedicated teams in a number of cases were focusing on operator commercial performance, often through isolation from other functions (for example, safer gambling or anti money laundering (AML)), leading to a lack of appropriate oversight and senior accountability, and breaching of internal policies, among other things.
Relationships within operators - There was evidence of unprofessional relationships between staff and customers, often leading to irresponsible, and on occasion exploitative, behaviour (for example, unsolicited engagement).
Incentivisation - Incentives offered via HVC schemes in several cases exacerbated at-risk behaviour, such as accelerating spend, cross-selling to other products, and placating customers when they were distressed or disgruntled following heavy losses.
The data exercise in 2021 provided some assurance, through self-reported information and examination of provided operator policies and procedures, that rules on HVC or VIP schemes were being applied (where schemes remained in place). The hypothesis we test therefore is the extent to which robust controls remain in place, where such schemes are offered.
A final hypothesis for this monitoring exercise to consider, is the possibility of unintended consequences that may have arisen from operator reactions to the tightening of rules.
While we cannot foresee all potential unintended consequences, our market monitoring work has flagged increases in the gross gambling yield (GGY) of some mid-tier operators. Whilst there is unlikely to be a single factor for market changes, one unintended consequence of the rule changes could be that high value customers have been displaced from larger to smaller operators.
Further exploration of potential unintended consequences might allow us to understand 2 underpinning assumptions articulated in the theory of change:
Finally, during the consultation for the rule changes, suggestions were made that an unintended consequence of the rule change may be that it is a motivator for some consumers to start gambling on the illegal market.
Triangulating sources of evidence, or not relying on a single data source, is considered good practice in understanding outcomes and impacts of any policy or intervention. To generate this report, we utilised 3 main data sources to evidence the hypotheses outlined previously: an industry data request; analysis of internal data from Gambling Commission enforcement casework; and an analysis of the Commission’s contact centre data and independent third-party complaints data. For each data source we outline our methodology and present the limitations associated with the monitoring work.
In 2021, data on High Value Customer (HVC) or VIP schemes was requested by the Commission from a sample of 33 operators. This exercise was conducted for compliance purposes and the data request provided evidence regarding operators’ use of HVC or VIP schemes. Data relating to the period before the policy change (pre-2020) as well as post policy change was requested, including data on the number of HVC or VIP schemes, customers enrolled, and self-reported compliance against the new controls in place.
For this additional monitoring exercise, we felt it was a proportionate method to re-issue the initial data request gathering more recent but consistent data on the current status of HVC or VIP schemes. We sampled to replicate, where possible, the characteristics of the operators responding previously. Around half a dozen operators subject to the previous data request are no longer operating. We therefore aimed to include as replacements as similar operators as possible, in terms of their overall gross gambling yield (GGY) and product offering. We added a number of additional questions to the data request but also retained many of the questions used previously.
The data collection fields are contained in the Appendix. The data request was made across a 4-week period between November and December 2024.
We seek to draw comparisons over time between schemes operated in 2021 with schemes operated in 2024, in terms of number of operators with schemes, customers enrolled, and self-reported compliance. In addition, we request new data regarding the GGY generated by each scheme, use of affiliates and incentivisation and to understand any unintended consequences of the new regulations.
The data request generated a mixture of quantitative and qualitative data. We use descriptive analysis to analyse change over time, and link the responses to the data request to other data held by the Commission to help contextualise figures (for example, calculating scheme generated GGY as a proportion of total GGY). We used content analysis to examine qualitative data.
For this aspect of the report, we conducted a content analysis exercise of Gambling Commission enforcement casework data. We manually analysed enforcement casework to establish:
This was a qualitative exercise, where we performed key word searches in order to objectively and subjectively understand the prevalence of HVC or VIP schemes as factors in enforcement casework. This involved a comparison of 2 time periods:
The key words related to HVC or VIP schemes that was used in the analysis were: VIP; High Value Customer; Very important person; HVC; loyalty; reward; incentive; priority.
Data collection and analysis was undertaken as follows:
2 members of staff looked at 1 year’s worth of data from each of the pre- and post-intervention periods.
Instances of the key words in casework were identified and tallied.
Cases were reviewed to establish whether it was considered that instances of gambling harm may have been caused by or contributed to by membership of a HVC or VIP scheme.
As well as moderation discussions, 10 cases from each member of staff were then randomly selected for the other staff member to sense check judgements to ensure consistency.
Please note that identification of the schemes as a potential contributory factor during this exercise does not mean that it was the sole aspect under investigation during the casework. It also does not mean that a breach was ultimately identified by colleagues in the Enforcement team or that any cases were necessarily sufficient to lead to further action.
Similar to the previous enforcement data analysis, we conducted content analysis on complaints data from 2 sources: the Gambling Commission’s Contact Centre; and data from Resolver - a free, independent issue resolution service.
Using key word searches (on the terms HVC, VIP, loyalty, priority) we identified potential complaints that might relate to HVC or VIP schemes. We then manually reviewed each complaint and made a judgement about whether or not the complaint was associated with the operation (or mis-operation) of a scheme. We tallied instances where there is likely to be an association and compared results across 2 time periods: 2021 and 2023.
For third-party data, we only look at a single time period: April 2023 to March 2024 and present a simple tally of the number of complaints associated with HVC or VIP schemes in the period.
An inherent limitation to the data request approach is that the exercise included a sample of gambling operators, rather than a census. Care was taken to include operators that offer a variety of products and have variations in reported gross gambling yield (GGY) but – as it is a sample – the findings may be misrepresentative and there may be outliers in the market that were not captured or considered.
The industry data request sample was kept as consistent as possible with the operators contacted during the 2021 exercise, to allow a direct comparison of changes between the time periods. However, some operators that were included in the earlier exercise are no longer trading. As far as possible, replacement operators were selected that offer the same range of gambling products and reported comparable GGY to the operator that was no longer contactable.
A limitation of the analysis of casework files is that the sample was selected based on the date that the cases were considered. The time-gap between the commencement of the gambling behaviour (which could occur over a prolonged period of time) and the case consideration was variable. Although most cases consider behaviour that occurred within the previous 12 months, sometimes the circumstances were not reported or identified until a significant period of time (multiple years) after the behaviour under investigation. As such, some cases considered in the post-implementation period relate to activity that occurred pre-implementation – it is the date of the behaviour that is considered most significant and has been recorded. However, the time lag for some cases may skew the dataset towards pre-implementation casework.
There are also risks relating to the accurate identification of cases where VIP or high value customer (HVC) schemes were a contributory factor. The dataset is qualitative in nature and compiled by different colleagues over a period of years. This risk was mitigated through the use of multiple keywords to identify potentially relevant cases.
Another limitation is that the inclusion of a keyword does not mean that a VIP or HVC scheme membership contributed to any harms that were reported – as an example, an individual may have been considered to be a VIP after reaching a certain expenditure threshold, but that status may be incidental to the behaviours being considered. To mitigate, each case containing one or multiple keywords was considered and assessed to make a judgement of whether VIP or HVC scheme membership was being alleged as a contributory factor. It was then for the investigation to determine whether there was a breach of regulations or not.
The data from the Gambling Commission’s Contact Centre and Resolver is limited to those who have actively engaged with those methods to complain about VIP or HVC schemes. The risk of falsely identifying calls – for example, a consumer complaining that they have not received VIP status – was mitigated through the review of each call, where possible, so these calls could be excluded.
There is also a limitation related to the number of complaints recorded where it is worth being aware that any changes could be due to variability in awareness of the complaints system, including any specific references in consumer forums, rather than changes in the issue itself.
We received 30 responses from operators. Overall, the data request captured information from operators representing approximately 40 percent of the overall gross gambling yield (GGY) in GB. The previous data request represented around 24 percent of total GGY. The number of respondents by GGY banding for the latest data request is shown in Table 1. The data shows an oversampling of operators with GGY of £100 million and above, whereas the proportion with a GGY of less than £5m is likely to be under-represented.
| GGY category | Operators | Total (percentage) |
|---|---|---|
| Less than £5 million | 3 | 10% |
| £10 million - £40 million | 8 | 27% |
| £40 million - 100 million | 8 | 27% |
| £100 million and above | 11 | 37% |
| Total | 30 | 100% |
The proportion of operators with High Value Customer (HVC) or VIP schemes has not changed significantly since 2021. 60 percent of operators reported currently operating a HVC or VIP scheme (n=30). This remains at the same level (or not significantly different) from 2021 where the proportion was 55 percent (n=33). This compares with the pre-policy position where two-thirds (67 percent, n=33) of operators had an HVC or VIP scheme.
Only 1 operator in this data collection exercise reported closing their HVC or VIP scheme due to the changing requirements introduced in 2020. No respondents offered bespoke incentives (for example, bonuses, hospitality days) to selected customers outside an HVC or VIP scheme.
The average HVC or VIP scheme had 90 customers enrolled in 2023 to 2024 (n=18). This is similar to the mean average following the policy change in 2021 (95, n=18). The median shows an increase from 36 following the policy change in 2021, to 66 in the latest year (see Table 2).
| 2021 data request | 2024 data request | ||||
|---|---|---|---|---|---|
| Pre-policy (n=22) | Post-policy (n=18) | 2021 to 2022 (n=17) | 2022 to 2023 (n=17) | 2023 to 2024 (n=18) | |
| Customers enrolled | 42,349 | 1,711 | 1,710 | 1,637 | 1,616 |
| Mean | 1,925.0 | 95.1 | 100.6 | 96.3 | 89.8 |
| Median | 166 | 35.5 | 66 | 77 | 66 |
| Maximum | 22,000 | 529 | 275 | 305 | 333 |
| Minimum | 7 | 2 | 11 | 3 | 1 |
12 of the 18 operators with High Value Customer (HVC) or VIP schemes in 2023 to 2024 provided GGY information as part of the data request. Collectively, the HVC or VIP scheme members accounted for £63 million of GGY (n=12). Aggregating data from each reporting operator and cross-referencing with regulatory returns data on the total GGY reported by these licensees, the GGY generated by HVC or VIP schemes represents 3 percent of total operator GGY in 2023 to 2024 (n=12). For 3 operators, their schemes accounted for less than 1 percent of their GGY while 3 operators ran schemes that represented over 10 percent of their GGY and - in one case - the proportion was 30 percent. See Table 3 for data on the distribution.
| GGY share (percentage) | Frequency |
|---|---|
| Above 10% | 3 |
| Between 5% and 10% | 0 |
| Between 3% and 5% | 3 |
| Between 1% and 3% | 3 |
| Less than 1% | 3 |
Schemes that account for less than 1 percent of GGY were exclusively distributed among the largest operators (£100 million and above GGY). Schemes that accounted for more than 10 percent of GGY were distributed across one smaller (£10 million to £40 million GGY), 1 medium (£40 million to £100 million GGY) and 1 larger operator (£100 million and above GGY). All respondents with a share of GGY of over 10 percent were non-remote casinos.
| Operator GGY | HCV schemes as a share of GGY (percentage) | |||
|---|---|---|---|---|
| Less than 1% | 1% to 3% | 3% to 5% | Over 10% | |
| £10 million to £40 million | 0 | 1 | 0 | 1 |
| £40 million to £100 million | 0 | 1 | 3 | 1 |
| £100 million and above | 3 | 1 | 0 | 1 |
| Total | 3 | 3 | 3 | 3 |
Following-on from the finding in Table 4, we also explored differences between different categories of operators and found that the non-remote casinos (n=4) have a higher GGY per HVC or VIP scheme compared with remote operators and that, furthermore, the GGY from HVC or VIP schemes grew significantly over the period for which data was collected (see Table 7). Non-remote casino GGY associated with HVC schemes more than doubled over the 3-year period, while remote operators saw a decline over the same period.
It should be noted that increased GGY from HVC or VIP schemes - or increased membership of the schemes – is not evidence of anything inappropriate or any breaches of the regulations. As an interesting trend, however, it is reflected in the report’s recommendations.
| Year | Land-based casinos (n=4) | Remote (n=8) | ||
|---|---|---|---|---|
| Total GGY (£) | Average GGY (£) | Total GGY (£) | Average GGY (£) | |
| 2021 to 2022 | £19,189,033 | £4,797,258 | £16,465,761 | £2,058,220 |
| 2022 to 2023 | £34,795,760 | £8,698,940 | £22,189,654 | £2,773,707 |
| 2023 to 2024 | £52,439,971 | £13,109,993 | £10,878,603 | £1,359,825 |
The data request included questions on operators’ self-reported compliance with High Value Customer (HVC) or VIP scheme rules and guidance. These questions were repeated from the data request in 2021. A summary of the responses follows. The Gambling Commission compliance team have reviewed the data returned by operators and have not identified any significant concerns regarding compliance that require further action.
Where operators had an HVC or VIP scheme currently in place (n=18), every operator reported they had a policy or procedures document governing the operation of their schemes. Similarly, all 18 operators reported their business had a Senior Executive (Personal Management Licence (PML) Holder) appointed to oversee and be held accountable for the operation of HVC schemes.
Operators were asked to outline how they can have confidence that customers are not subject to significantly higher levels of financial risk due to their membership of the scheme. All but 2 respondents reported conducting an enhanced application or onboarding process. Many noted that this included a financial vulnerability check, or assessment of a customer’s personal financial information. Many noted that ‘Know Your Customer’ checks were completed more periodically for HVC customers.
In addition, further measures were put in place by some operators to mitigate the risk, including operator-imposed deposit limits, loss limits, and daily and weekly financial 'backstop' limits. One operator noted benchmarking financial data against national statistics to generate and apply personalised thresholds while 2 operators reported the use of algorithms to detect changes in play intensity.
Around three-fifths of respondents said they monitored additional markers of harm over and above those established for all of their customers. Typically, a customer triggering markers of harm is managed by manual review by Safer Gambling or Due Diligence teams and in some cases the PML holder or steering committee. One operator assesses activity against imposed account limits.
Operators noted historic data is available to check for previous self-exclusions and this is usually done as part of the onboarding processes. This is often done alongside checks against GamStop and SENSE. A number of operators noted the level of sign off (by the PML, or other executive) needed to admit a customer with a previous self-exclusion including comprehensive record keeping, though not all operators reported having this process.
The majority of operators reported quarterly reviews of ‘Know Your Customer’ checks, with others reporting an annual frequency. Other triggers and manual review processes were in place for some operators which meant information could be more regularly updated.
Operators explained their data retention processes, which often included detailed HVC profiles and systems recording aggregated data. More detailed responses outlined the types of data held about their scheme members, which included details of the assessment process, the outcomes of regular reviews, incentives offered, and decision-making records.
In many cases, operators told us that safer gambling teams often held responsibilities or relationships with HVCs. There were also governance structures designed to ensure wider non-commercial interests were represented in decision-making. Some mentioned that staff were not incentivised in terms of HVC schemes. Not all operators provided a response about managing commercial conflicts of interest.
The majority of operators told us they didn’t use affiliates or ‘introducers’ in promoting their HVC scheme. Where this arrangement was in place, controls included internal compliance reviews, third party monitoring, and strict adherence to affiliate terms and conditions. Where introducers are used, in one operator, this is subject to senior vetting and approval. Another notes that files are maintained for introducers and regularly monitored.
While some operators have targets and incentives for staff in relation to growth of customers, these are not linked to HVC or VIP scheme expenditure; the majority report no incentivisation of staff. Of the 2 operators that directly incentivise staff in relation to HVC or VIP schemes, one qualified this by stating incentivisation is done on a growth per quarter basis, and the other stated that incentivisation is on the basis of membership only and not related to spend.
The majority of respondents were not aware of any unintended consequences as a result of the change in policy. 4 operators noted some displacement away from their business, including a potential shift to the illegal market. Reportedly, this was not solely attributable to the policy change around HVC or VIP schemes. One operator mentioned the potential for gambling affiliates targeting high value customers to shift their focus to begin promoting the illegal market as a result of the new regulations.
Through the process detailed in the methodology section, there were 46 cases with one or more of the 8 keywords that were assessed by the researchers as having VIP or High Value Customer (HVC) schemes as alleged contributory factors to the reported gambling behaviour of the consumer. The cases identified are shown in Table 6:
| Year considered | Cases identified |
|---|---|
| 2018 | 11 |
| 2019 | 33 |
| 2022 | 1 |
| 2023 | 1 |
| Total | 46 |
As outlined in the limitations section, there is a potential time-lag between the commencement of gambling activity of interest and the date that the casework is considered by the Gambling Commission. The earliest activity within these 46 cases occurred in 2011 (but was not reported until 2018), and some of the reported gambling interaction histories spanned multiple years. The 2 cases considered in 2022 and 2023 do relate to gambling behaviour that occurred in 2021 and 2022 respectively, a time period following the regulatory change.
Due to the confidential nature of casework, no further details about these incidents can be disclosed as to whether any allegations were upheld, and no updates about the progression of any investigations can be provided as this may be prejudicial to any ongoing investigations into the same.
It is clear that there has been a significant decrease in casework where HVC or VIP schemes are reported as potential contributory factors since the introduction of the new policies. Even permitting for a skew to pre-implementation cases caused by the time-lag, there is a significant decrease in allegations relating to HVC or VIP schemes within the casework pre-implementation (n=44) to the 2 years considered post-implementation (n=2). It is recommended that this source of information is monitored on an ongoing basis as a valuable resource to detect trends.
Additionally, the Commission's ongoing assessment of operators' compliance with regulatory requirements has not identified HVC or VIP schemes as an issue requiring specific thematic focus.
We undertook analysis of complaints data using a keyword search strategy. Between 2021 and 2023, a small number of complaints (fewer than 20; less than 0.2 percent of received calls) that were potentially linked to High Value Customer (HVC) or VIP schemes were received by the Gambling Commission’s contact centre. Using 4 keywords (HVC, VIP, loyalty, priority) we flagged complaints that potentially raised concerns about operators’ compliance with the Commission’s requirements on HVC or VIP schemes. There is no discernible trend in the data extracted (see Table 7).
| Year | Potential complaints associated with HVC or VIP schemes |
|---|---|
| 2021 | 0 |
| 2022 | 11 |
| 2023 | 2 |
| Total | 13 |
We conducted a similar analysis of data from Resolver - a free, independent issue resolution service. For the period April 2023 to March 2024, we noted 6 potential complaints related to the operation of HVC or VIP schemes. Together this evidence indicates that there were no widespread consumer issues with operators’ use of HVC or VIP schemes in the latest financial year (2023 to 2024).
Conclusions are set out for each of the 3 hypotheses that were established for the monitoring of High Value Customer (HVC) or VIP schemes, along with planned next steps.
The data gathered as part of our monitoring work suggests that there has been no growth in the number of operators with HVC or VIP schemes. Similarly, there is no evidence of growth in the number of customers enrolled on schemes; the number of customers on average remains significantly lower in 2024 compared with the number of customers enrolled before the policy change.
On average, VIP or HVC schemes account for a small proportion of the overall gross gambling yield (GGY) of an operator. However, this is typically higher for non-remote casinos who see greater returns from VIP or HVC schemes compared with remote operators, a trend which appears to be growing.
We found no clear evidence of widespread consumer concerns arising from HVC or VIP schemes from analysis of Gambling Commission casework, and complaints data as further explained previously.
Overall, it is likely that the market for VIP or HVC schemes remains ‘depressed’ compared with the pre-policy situation. The one exception might be for non-remote casino operators, which has seen some growth in GGY and membership of schemes over time. The small sample however means we can not be confident this is representative of all non-remote casino operators across the market.
Overall, scheme controls reported by operators appear robust - with appropriate management and internal personal responsibility, and regular monitoring of scheme members. We have also noted significant consistency in the reported approach to scheme management amongst the operators in the sample that have VIP or HVC schemes.
We have also observed a reduction in Commission casework where VIP or HVC schemes or inappropriate incentivisation is identified as an alleged contributory factor and included evidence that the operation of schemes is not a source of widespread consumer complaints. Although we do not have a method of monitoring whether VIP or HVC scheme members are experiencing gambling-related harm (the ‘end goal’ in the Theory of Change), these findings are a positive indication that instances of significant operational concern have reduced since the regulation was introduced in 2020.
We also note that there are some implementation areas outlined previously that may warrant some further monitoring in due course to confirm the intended outcomes and goals of the policy change are met. This includes in areas such as incentivisation of staff, managing commercial conflicts of interest, management of previously self-excluded customers, and those that reported a longer frequency of information review than others.
We asked respondents about potential unintended consequences of the tightening of VIP or HVC schemes. The majority of respondents were not aware of any unintended consequences as a result of the change in policy, and no common themes emerged from among those who did speculate upon potential unintended consequence.
It is recommended that:
High Value Customers or VIPs are customers identified as being of enough commercial value to warrant enhanced customer service unavailable to the wider customer base. Specifically, schemes that offer tailored or personalised incentives linked to high value spend or frequency of play. Such treatment may include, but is not restricted, to:
Please provide your operating (brand) name.*
Does your organisation currently operate a High Value Customer / VIP (or similar) scheme? [Yes, No]*
If Q2=No; Has your organisation operated a High Value Customer / VIP (or similar) scheme in the last three years (since 2021/22)?*
(If Yes to Q2:)
(If Q4=On or after 1st April 2024 )
(If Q4=Before 1st April 2024)
How many customers were enrolled on the scheme in the last three financial years: [2021/22; 2022/23; 2023/24]*
What share of your Gross Gambling Yield (GGY) was associated with customers on HVC schemes in the financial years: [2021/22; 2022/23; 2023/24]*
Do you have a HVC Customer Policy & Procedures document? If yes, would this be available on request? [Open text]
Do you have a Senior Executive (PML Holder) appointed to oversee and be accountable for the operation of HVC schemes? [Yes/no]
How do you establish that customers are not subject to significantly higher levels of financial risk due to their membership of the scheme? [Open text]**
Are there additional markers of harm considered, over and above what is collected for all customers, to identify potentially at risk HVC customers?**
How are customers managed when they hit these markers? [Open text]
What steps do you take to check whether a prospective HVC customer has previously self-excluded? [Open text]
How do you ensure that you have up-to-date details of HVC customers relating to identity, occupation, and source of funds? [Open text]
What records do you maintain detailing how your HVC customer schemes are operated? [Open text]
What additional controls have you put in place to mitigate the risk of commercial motivations conflicting with HVC customer compliance? [Open text]
If any staff roles Which staff roles in your business have targets and/or incentives related to retention of customers, or the growth of the customer base ? If so, please provide the number of Full Time Equivalents (FTE) per role [Open text]*
What controls do you have in place for third parties (affiliates) who might be promoting or advertising your HVC/VIP scheme? [Open text]*
Have there been any unintended consequences from the Commission’s change in policy regarding HVC/VIP schemes? [Open text]*
(All answering NO to Q2 and NO to Q3:)
Did you have a scheme previously but closed this due to the change in LCCP requirements? [Open text]*
If you had a scheme previously, do you have any evidence that customers moved to the unlicensed market? [Open text]*
Do you offer bespoke incentives (eg. bonuses, hospitality days) to selected customers? If so, please describe the form of the incentives?.' (Please note that this is not intended to include incentives that any customers can trigger automatically by meeting certain requirements)' [Open text]*
Which staff roles in your business have targets and/or incentives related to retention of customers, or the growth of the customer base? If so, please provide the number of Full Time Equivalents (FTE) per role [Open text]*
Are you aware of any unintended consequences from the Commission’s change in policy regarding HVC/VIP schemes? Please provide details. [Open text]*
Note: * denotes a new question for the 2024 data request, ** denotes altered question wording from the 2021 data request.