Strategy
National Strategic Assessment 2020
This report sets out our latest assessment of the issues we face and the risks that gambling poses to consumers and the public
Proposal 1 - Ban or limit the use of wagering requirements
We consulted on 2 alternative options to address this issue:
- a proposal to ban wagering requirements applied to all bonus funds in promotional offers
- a proposal to set a cap on wagering requirements to all bonus funds applied to promotional offers. We consulted on 3 alternative thresholds:
- Wagering requirements set up to a maximum of 1 time.
- Wagering requirements set up to a maximum of 5 times.
- Wagering requirements set up to a maximum of 10 times.
Consultation questions
If one of these proposals were to be adopted, which do you prefer? Choose one of the following: Option A – ban wagering requirements, or Option B – cap wagering requirements.
To what extent do you agree with the proposed option A to ban wagering requirements? Please give your reasons, including any evidence.
To what extent do you agree with the proposed option B to cap wagering requirements? Please give your reasons for your answer.
If wagering requirements were to be capped, which threshold do you prefer? Please give your reasons, including any evidence.
Do you have any further comments on these proposals?
Do you have any comments about implementation issues, timelines and practicalities? Please provide an estimate, including any evidence, of the direct costs associated with implementing these proposals, identifying to which proposals the estimated costs relate.
Respondents’ views
Responses showed that, when asked which option is preferred, just over half agreed with a limit, while just under half agreed with a ban. A few respondents who supported a ban, also noted that, should a limit be introduced, no more than 1 times would be acceptable.
Regarding Option A, the main themes and comments in support of a ban were as follows:
Respondents representing charities and academic organisations, commented they agree with the evidence provided in the consultation document, that wagering requirements could lead to customers gambling excessively. A few respondents commented that although there is limited evidence on the impact of wagering requirements, there is evidence to support greater restrictions on marketing and advertising more generally. Some respondents provided comments and research to demonstrate a case to ban all new customer sign up offers and incentives more widely.
Respondents suggested that customers are unable to estimate the true economic value of an offer and very high wagering requirements lead to lower comprehension of how much is needed to bet when taking up an incentive. Therefore, a ban should lead to terms and conditions that are shorter and easier to read.
High value offers are often constructed by applying high wagering requirements which could have negative and disproportionate effects on vulnerable adults.
Regarding Option B, the main themes and comments in support of applying a limit were as follows:
Most of those who responded agreed that high wagering requirements are detrimental to consumers.
Most respondents representing the gambling industry strongly disagreed with a ban. They consider a limit would lead to offers being financially unviable for the operator. There is a concern that, by not applying some wagering requirements, organised groups will take advantage of free offers at a large scale and increase identity theft and/or bots obtaining 'free money'. Respondents stated that this could leave operators in a position where action designed to meet the licensing objective of protecting vulnerable people from harm could have a detrimental effect on the licensing objective to keep crime out of gambling.
Some operators expressed concern that a ban could lead to increased fraud and money laundering issues. This point was primarily linked to the previous point, that a ban, or limit of less than 10 times wagering requirements, would allow organised groups to take advantage at a large scale.
Respondents commented that limits will allow the market to remain competitive with less impact on smaller and/or medium operators, giving commercial freedom to provide varied promotions. A limit is also preferable to avoid proliferation of the illegal online market.
Some comments, including from a few customers, focused on the impact on customers, noting that they enjoy taking up offers and see a ban as a restriction of consumer choice.
Most consider a maximum of 10 times wagering requirements to be the lowest appropriate threshold. One operator provided a breakdown which showed that 75 percent of their offers apply within the 1 to 10 times wagering requirements. A trade association made specific points that only 10 times would suffice, due to little evidence base for 1 to 5 times wagering, and that anything less than 10 would be, in effect, a ban, leading to less consumer choice.
A few respondents commented that the impact of a cap on wagering requirements will also need to consider the Game Contribution Restrictions, also referred to as Weighting, which is applied to control how quickly a customer can play through a game. For example, a bonus might carry 10 times wagering requirements on all slots but will be weighted at 50 percent for blackjack and 30 percent for roulette. This means that if you have a £100 bonus with 10 times wagering requirement and you decide to play a casino game like roulette with a 30 percent weighting, each £1 you wager contributes 30 pence towards the wagering requirement.
Most operators commented that the implementation of any changes would take, on average, 6 months.
Our position
We have considered the comments and concerns raised by stakeholders in the consultation responses.
In relation to the concerns that a ban could lead to increased fraud and money laundering issues, respondents did not provide clear evidence to support this claim via consultation responses or via our post consultation engagement with industry. We have engaged with the industry, in the past, about mule accounts and risks to money laundering and terrorist financing, and alongside our review of casework and other intelligence sources, we did not find evidence to substantiate these claims. Therefore, we consider it to be low risk that a ban or low limits, could lead to increased fraud and money laundering within the sector.
Our engagement with gambling licensees has identified that low levels of wagering requirements are sometimes necessary as a means to prevent gamblers from taking away ‘free’ money which could have a commercial impact, such as a high cost to offering incentives without such mechanics in place. We consider this links to the points, made by some respondents, that some customers may be part of organised groups and use systems to enable them to collect large quantities of offers, in a short period of time. However, although we understand the impact of such action, we expect gambling licensees to have robust systems in place to undertake appropriate checks at registration and further Know Your Customer (KYC) checks to prevent this.
We understand the concerns about Games Weighting Contributions attached to wagering requirements and the impact this could have on how much a customer needs to gamble to meet the wagering requirements. There are many reasons why licensees choose to add weightings, primarily to strike a balance between customer engagement and limiting the licensees’ exposure to financial risk. Where weightings are applied, it could give customers the opportunity to experience wider games with the bonus. From the current evidence, we do not think it is necessary to review rules on weightings attached to wagering requirements at this time. We would expect any terms and conditions, including those relating to wagering requirements, to be clear and transparent to consumers. However, we will keep under review the impact of our proposals on consumers.
We recommend proceeding with Option B, to implement a maximum of up to 10 times wagering requirements within incentives. This means that any wagering requirements attached to incentives (such as bonuses) must not exceed 10 times the incentive amount. Our view is that this would meet the policy aims while maintaining a degree of consumer choice and mitigating the risk of displacement to the illegal online market.
In reaching our decision, we decided not to pursue a ban, and very low wagering requirements such as those set up to a maximum of 1 and 5 times, for the following reasons:
- gambling licensees are highly likely to introduce terms and conditions that prevent customers from cashing out bonuses, particularly in large and organised groups. These potential practices may have a worse impact on both customers and licensees, than having low wagering requirements
- customers look for high value promotional offers and there is a risk that some customers may be pushed to seek higher value offers in the online illegal market
- impact on competition, specifically on small to medium sized gambling licensees finding it difficult to compete with licensees that dominate market share, who can afford to give a high volume of generous offers
- there is limited evidence to justify 5 times over the 10 times wagering requirement
- a limit of 10 times will take out extreme levels as some licensees currently apply up to 60 times wagering requirements.
We consider this to be a proportionate response to the issues and risks identified in the consultation. Under Licence Condition 7.1.1 (Fair and open terms and practices), licensees are required to ensure terms and practices are fair, transparent, and not misleading. If we see poor behaviour and the emergence of particularly onerous terms and conditions attached to wagering requirements, particularly if the Games Weighting Contributions are changed to have a considerable impact on customers, we could take action and consider consulting on further changes, including the option to ban.
For the purposes of ensuring we use the correct terminology, we have made one minor change to the final wording to the Licence Conditions and Codes of Practice (LCCP) provision, which replaces ‘consumer’ with ‘customer’.
Final wording
This requirement will come into force on 19 December 2025.
Applies to: All licences (including ancillary remote licences), except gaming machine technical and software licences.
LCCP Social Responsibility Code 5.1.1 Rewards and Bonuses
- Licensees must not:
a. Apply wagering requirements to incentives, which require customers to play through bonus funds, over a maximum of 10 times. A wagering requirement is where a customer is required to make wagers totalling a particular value for funds to become withdrawable.
Last updated: 26 March 2025
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