UK LEGAL
New restrictions on bonuses and promotions
After consultation which began in Autumn 2023, the Gambling Commission has fi nally reached a decision regarding proposed limits on bonuses and promotions. Northridge Law’s Melanie Ellis reports.
T
he Gambling Commission has finally reached a decision regarding proposed limits on bonuses and promotions. The key outcome of this is that, from 19 December 2025, promotions with wagering requirements will be limited to 10x the bonus amount received.
WAGERING REQUIREMENTS The new restriction states that a licensee “Must not apply wagering requirements, which requires a customer to play through bonus funds, over a maximum of 10 times. A wagering requirement is a where a customer is required to make wagers totalling a particular value for funds to become withdrawable.” The new rule is limited to circumstances where the customer must play through bonus funds they have received, in order for funds to become withdrawable. This requirement would not prevent, for example, a bonus which required customers to play through their deposited funds 30 times before bonus funds would be deposited into their account. Nevertheless, the restrictions will serve to widen the gap between the incentives
32 APRIL 2025
that can be offered by licensed operators, and those promoted by their unlicensed competitors. While more knowledgeable customers may look to the small print and conclude that a £20 bonus with a 10x wagering requirement is more attractive than a £50 bonus with a 50x wagering requirement, many customers, including the most vulnerable, could be tempted to the black market as a result of these changes.
MIXED PRODUCTS
The other key change bans mixing of products within incentives. The new social responsibility code provision will state that licensees must not “include more than one type of gambling product (betting, casino, bingo, and lottery) within an incentive”. This will apply to both remote and land-based operators. An example of the type of offer that this rule will prevent is “bet £10 and get £20 free bets and £10 casino bonus”. The wording of the new provision is wide and operators should take note that it is also capable of preventing an offer such as “spend £20 at
the gaming tables and receive a free ticket for this evening’s raffl e”.
The rationale behind this new rule is that the Commission has “evidence to show that these [offers] can be problematic because they can lead to consumer confusion and likelihood of experiencing harm”. The evidence referred to includes data from the Health Survey for England (2018) which showed that a higher proportion of respondents who gambled on multiple products were classifi ed as problem gamblers, compared to those who gambled on just one product. In its consultation, the Commission also referenced evidence which demonstrated that bonus offers encouraged customers to take part in new forms of gambling.
What this evidence does not appear to show is causation – it may be the case (as the Commission seems to have concluded) that starting to gamble on multiple products increases the risk of a person experiencing problems with their gambling, however it may also be the case that those already experiencing problems with their gambling are more likely to seek out additional product
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