UK Gambling Commission Proposes Crackdown on VIP Schemes, Tightens AML Rules for Online Casinos
14 October 2026
The UK Gambling Commission has launched a significant crackdown on online VIP schemes, introducing stringent new rules aimed at curbing their potential for harm. Effective from 31 October 2020, the updated regulations stipulate that operators must now establish the affordability and sustainability of customers' gambling as part of their leisure spending before elevating them to VIP status, along with conducting ongoing checks for signs of potential gambling-related harm. A senior executive must oversee each scheme, with the Commission warning it could ban such programs altogether if they are not properly reformed.
The tightening of VIP scheme controls came in response to concerns that these high-value customer (HVC) programs were often granted to gamblers based on the volume of their spending, rather than a genuine assessment of their affordability or level of risk. According to the Commission, operators need to balance their commercial interests with their regulatory duty to protect vulnerable customers, many of whom may be at greater risk of experiencing gambling-related harm due to their high involvement.
The Commission first announced the proposed changes following a consultation process that received 81 written submissions between 19 June and 14 August 2020, before implementing them on 31 October that year. Operators must now gather up-to-date evidence relating to a VIP customer's identity, occupation, and source of funds. They are also required to keep these records updated and to continue conducting ongoing assessments on each individual for any signs of gambling-related harm.
Emsley Southern, chief executive of the UK Gambling Commission, said: "Our worry was operators were prioritising their bottom line above customers' interests when deciding who to elevate to VIP status. These serious new requirements ought to settle that. If firms can't or won't comply, we won't hesitate to ban HVC schemes altogether."
The Commission published a review in 2021 which found the number of consumers on HVC or VIP schemes reduced by around 90% after these rules were introduced. In its subsequent monitoring to the end of the 2023–2024 financial year, the Commission's latest report "High-Value Customer and VIP Scheme Monitoring" found that "HVC/VIP schemes did not appear widespread" and there had been "no indication of significant issues from consumers in relation to operators' use of these schemes."
Government gambling reforms launched in early 2024 said the Commission had "strengthened restrictions on online VIP schemes and introduced rules to prevent bonus offers and other marketing being targeted at those showing indicators of harm."
VIP Scheme Milestones, June 2020 to Date
- 19 June 2020: Commission launches consultation on new VIP scheme rules
- 14 August 2020: Consultation closes, with 81 responses
- 31 October 2020: New rules take effect
- 2021: Commission review finds around 90% reduction in HVC/VIP customers
- Latest monitoring to 2024 finds no evidence of widespread issues
VIP Operator Obligations
- Establish customer's ability to gamble affordably
- Gather and keep up-to-date identity, occupation and funding source info
- Conduct ongoing individual assessments for gambling-risk indicators
- Designate a responsible senior executive, accountable to the Commission
Looking forward, the Commission has stressed that it will not hesitate to use the explicit legislative lever in the Gambling Act to ban HVC schemes if operators fail to adequately address concerns. Despite this, the Commission found that the number of users on these schemes has increased in recent years, reaching 73,670 on 1 April 2024, from just 28,019 in 2018.
At the time of writing, Intertops, 888 Holdings, and Betfair were not among the 112 UK-licenced remote betting operators using HVC/VIP schemes in 2023–2024. Those that were accounted for 58% of the online gambling gross yield in 2022.
Scope to further strengthen rules?
The government review of gambling since its Act came into force in 2005 also suggested there may be further scope to strengthen the HVC/VIP rules. It found that operators "are not always conducting appropriate affordability checks" on prospective VIPs, "partly because they are designed to maximise financial gain at the expense of responsible gambling."
The Commission will continue monitoring the situation, with enforcement and the possibility of a complete scheme ban remaining on the table. For now, the strong safeguards now in place appear to have stemmed the risk of these privileges being granted to a greater number of consumers.
The story is ongoing: the Commission was reviewing the latest data it has on these schemes as of the date of publication, with a report due to be published later in the year.