Report
High Value Customer and VIP Scheme Monitoring
Gambling Commission report focusing on research conducted into high value customer and VIP scheme monitoring
Hypothesis 3: Unintended consequences
There are no unintended consequences of introducing stricter rules on HVC schemes.
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:
- operators adopt compliant practices, for example, they do not close or reduce schemes in name-only, meaning that they continue to interact and incentivise customers as they did with a previous High Value Customer (HVC) or VIP scheme whilst officially closing their HVC or VIP scheme
- new rules are not circumvented through the use of affiliates and/or corporate group structures.
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.
Previous sectionHypothesis 2: Controls
Last updated: 17 July 2025
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