Report
High Value Customer and VIP Scheme Monitoring
Gambling Commission report focusing on research conducted into high value customer and VIP scheme monitoring
Limitations
Industry data request
An inherent limitation to the data request approach is that the exercise included a sample of gambling operators, rather than a census. Care was taken to include operators that offer a variety of products and have variations in reported gross gambling yield (GGY) but – as it is a sample – the findings may be misrepresentative and there may be outliers in the market that were not captured or considered.
The industry data request sample was kept as consistent as possible with the operators contacted during the 2021 exercise, to allow a direct comparison of changes between the time periods. However, some operators that were included in the earlier exercise are no longer trading. As far as possible, replacement operators were selected that offer the same range of gambling products and reported comparable GGY to the operator that was no longer contactable.
Casework
A limitation of the analysis of casework files is that the sample was selected based on the date that the cases were considered. The time-gap between the commencement of the gambling behaviour (which could occur over a prolonged period of time) and the case consideration was variable. Although most cases consider behaviour that occurred within the previous 12 months, sometimes the circumstances were not reported or identified until a significant period of time (multiple years) after the behaviour under investigation. As such, some cases considered in the post-implementation period relate to activity that occurred pre-implementation – it is the date of the behaviour that is considered most significant and has been recorded. However, the time lag for some cases may skew the dataset towards pre-implementation casework.
There are also risks relating to the accurate identification of cases where VIP or high value customer (HVC) schemes were a contributory factor. The dataset is qualitative in nature and compiled by different colleagues over a period of years. This risk was mitigated through the use of multiple keywords to identify potentially relevant cases.
Another limitation is that the inclusion of a keyword does not mean that a VIP or HVC scheme membership contributed to any harms that were reported – as an example, an individual may have been considered to be a VIP after reaching a certain expenditure threshold, but that status may be incidental to the behaviours being considered. To mitigate, each case containing one or multiple keywords was considered and assessed to make a judgement of whether VIP or HVC scheme membership was being alleged as a contributory factor. It was then for the investigation to determine whether there was a breach of regulations or not.
Complaints Data
The data from the Gambling Commission’s Contact Centre and Resolver is limited to those who have actively engaged with those methods to complain about VIP or HVC schemes. The risk of falsely identifying calls – for example, a consumer complaining that they have not received VIP status – was mitigated through the review of each call, where possible, so these calls could be excluded.
There is also a limitation related to the number of complaints recorded where it is worth being aware that any changes could be due to variability in awareness of the complaints system, including any specific references in consumer forums, rather than changes in the issue itself.
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Last updated: 17 July 2025
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