Report
High Value Customer and VIP Scheme Monitoring
Gambling Commission report focusing on research conducted into high value customer and VIP scheme monitoring
Executive summary
Introduction
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.
Key Findings
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.
References
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.
Contents page Next section
High Value Customer and VIP Scheme Monitoring - Introduction
Last updated: 17 July 2025
Show updates to this content
No changes to show.