Report
High Value Customer and VIP Scheme Monitoring
Gambling Commission report focusing on research conducted into high value customer and VIP scheme monitoring
Appendix: Industry data request
Industry Data Request: Definition
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:
- Invitation to hospitality, events, dinners, or other enhanced services
- Personal account management and/or dedicated point of contact with the licensee
- Individualised bonuses, benefits, or gifts.
Question set
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:)
- When did this scheme come into operation?* [On or after 1st of April 2024; Before 1st April 2024]
(If Q4=On or after 1st April 2024 )
- How many customers are currently enrolled on the scheme?* [Then skip to Q8]
(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.
Previous sectionHigh Value Customer and VIP Scheme Monitoring - Conclusions and next steps
Last updated: 17 July 2025
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