Report
High Value Customer and VIP Scheme Monitoring
Gambling Commission report focusing on research conducted into high value customer and VIP scheme monitoring
Conclusions and next steps
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.
Hypothesis 1: The market for HVC or VIP schemes has remained depressed since rule tightening
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.
Hypothesis 2: Operators are using robust controls, where schemes are in place
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.
Hypothesis 3: There are no unintended consequences of introducing stricter rules on HVC schemes
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.
Next Steps
It is recommended that:
- considerations of operator VIP or HVC schemes continue to form part of ongoing compliance considerations, with particular relevance for the casino and/or non-remote sector
- administrators of the group overseeing casework continue to identify thematic trends and recommend a repeat or expanded review of VIP or HVC schemes to be conducted in the event of changes to these findings.
High Value Customer and VIP Scheme Monitoring - Other Sources of information Next section
High Value Customer and VIP Scheme Monitoring - Appendix
Last updated: 17 July 2025
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