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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

Theory of Change

Our approach to monitoring and evaluation of practices around High value Customer (HVC) or VIP schemes is theory-based. As recommended in the government’s Magenta Book (opens in new tab), we established a theoretical model of how we expect a policy change to affect a desired change. We often use a Theory of Change to this end, with the Theory of Change subsequently acting as a way to best guide data collection.

The Theory of Change reflects the position that – prior to the policy change – HVC schemes contributed to gambling-related harms by encouraging gambling beyond the means of some consumers and operated with insufficient personal accountability within some operators, contributing to practices that lacked openness. In response to this, the change in regulations was introduced in October 2020.

Assumptions included in the Theory of Change were that operators adopt compliant practices, for example, do not close or reduce schemes in name-only, or permit affiliates to circumvent the requirements.

Subject to those assumptions being accurate, the subsequent anticipated outcomes include:

  • improved treatment of high value customers (HVC) or VIPs, including improved levels and frequency of interactions which are more appropriately personalised for the individual due to improved audit trails and/or record-keeping and a rigorous standard of documentation being required as proof that an individual is a HVC or VIP
  • within operator structures, HVC or VIP teams are not isolated from regulatory compliance or anti money laundering (AML) teams
  • a reduction in HVC or VIP schemes as contributory factors in our Enforcement casework
  • a reduction in problematic HVC scheme membership, referring to the inappropriate incentivisation of customers through HVC schemes
  • operators report a reduced reliance on HVCs for large proportions of their gross gambling yield (GGY)
  • improved operator practices regarding HVC or VIP customers
  • increased personal accountability within operators for HVC schemes.

It is these outcomes that the Theory of Change envisages will contribute to the end goals of HVC or VIP and at-risk customers being less likely to experience gambling-related harms, and operator practices in respect of HVC or VIP schemes being more consistent and open to scrutiny.

From the Theory of Change, and in response to the approach set out in the White Paper, we present 3 statements or hypotheses that we aimed to test.  We explain each hypothesis in turn.

Next section
Hypothesis 1: The HVC market
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