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Report

High Value Customer and VIP Scheme Monitoring

Gambling Commission report focusing on research conducted into high value customer and VIP scheme monitoring

Published
17 July 2025

Last updated
17 July 2025 - Changes

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Contents

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 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:

  • Theory of Change and Hypotheses to test
  • Methodologies and limitations
  • Operator survey findings
  • Casework analysis
  • Other sources of information
  • Conclusions and next steps
  • Appendix: Industry data question set.

References

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)

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High Value Customer and VIP Scheme Monitoring - Theory of Change and hypotheses to test
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