Report
High Value Customer and VIP Scheme Monitoring
Gambling Commission report focusing on research conducted into high value customer and VIP scheme monitoring
Methodologies
Triangulating sources of evidence, or not relying on a single data source, is considered good practice in understanding outcomes and impacts of any policy or intervention. To generate this report, we utilised 3 main data sources to evidence the hypotheses outlined previously: an industry data request; analysis of internal data from Gambling Commission enforcement casework; and an analysis of the Commission’s contact centre data and independent third-party complaints data. For each data source we outline our methodology and present the limitations associated with the monitoring work.
Industry data request
In 2021, data on High Value Customer (HVC) or VIP schemes was requested by the Commission from a sample of 33 operators. This exercise was conducted for compliance purposes and the data request provided evidence regarding operators’ use of HVC or VIP schemes. Data relating to the period before the policy change (pre-2020) as well as post policy change was requested, including data on the number of HVC or VIP schemes, customers enrolled, and self-reported compliance against the new controls in place.
For this additional monitoring exercise, we felt it was a proportionate method to re-issue the initial data request gathering more recent but consistent data on the current status of HVC or VIP schemes. We sampled to replicate, where possible, the characteristics of the operators responding previously. Around half a dozen operators subject to the previous data request are no longer operating. We therefore aimed to include as replacements as similar operators as possible, in terms of their overall gross gambling yield (GGY) and product offering. We added a number of additional questions to the data request but also retained many of the questions used previously.
The data collection fields are contained in the Appendix. The data request was made across a 4-week period between November and December 2024.
We seek to draw comparisons over time between schemes operated in 2021 with schemes operated in 2024, in terms of number of operators with schemes, customers enrolled, and self-reported compliance. In addition, we request new data regarding the GGY generated by each scheme, use of affiliates and incentivisation and to understand any unintended consequences of the new regulations.
The data request generated a mixture of quantitative and qualitative data. We use descriptive analysis to analyse change over time, and link the responses to the data request to other data held by the Commission to help contextualise figures (for example, calculating scheme generated GGY as a proportion of total GGY). We used content analysis to examine qualitative data.
Enforcement data
For this aspect of the report, we conducted a content analysis exercise of Gambling Commission enforcement casework data. We manually analysed enforcement casework to establish:
- the alleged association between VIP or HVC schemes and potential non-compliance with licensing requirements through examination of casework that had been escalated to the team for investigation
- the alleged role of HVC or VIP schemes in contributing to gambling harm in identified casework.
This was a qualitative exercise, where we performed key word searches in order to objectively and subjectively understand the prevalence of HVC or VIP schemes as factors in enforcement casework. This involved a comparison of 2 time periods:
- 2018 and 2019 (pre-intervention period)
- 2022 and 2023 (post intervention period).
The key words related to HVC or VIP schemes that was used in the analysis were: VIP; High Value Customer; Very important person; HVC; loyalty; reward; incentive; priority.
Data collection and analysis was undertaken as follows:
2 members of staff looked at 1 year’s worth of data from each of the pre- and post-intervention periods.
Instances of the key words in casework were identified and tallied.
Cases were reviewed to establish whether it was considered that instances of gambling harm may have been caused by or contributed to by membership of a HVC or VIP scheme.
As well as moderation discussions, 10 cases from each member of staff were then randomly selected for the other staff member to sense check judgements to ensure consistency.
Please note that identification of the schemes as a potential contributory factor during this exercise does not mean that it was the sole aspect under investigation during the casework. It also does not mean that a breach was ultimately identified by colleagues in the Enforcement team or that any cases were necessarily sufficient to lead to further action.
Complaints data analysis
Similar to the previous enforcement data analysis, we conducted content analysis on complaints data from 2 sources: the Gambling Commission’s Contact Centre; and data from Resolver - a free, independent issue resolution service.
Using key word searches (on the terms HVC, VIP, loyalty, priority) we identified potential complaints that might relate to HVC or VIP schemes. We then manually reviewed each complaint and made a judgement about whether or not the complaint was associated with the operation (or mis-operation) of a scheme. We tallied instances where there is likely to be an association and compared results across 2 time periods: 2021 and 2023.
For third-party data, we only look at a single time period: April 2023 to March 2024 and present a simple tally of the number of complaints associated with HVC or VIP schemes in the period.
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Last updated: 17 July 2025
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