Gambling Commission introduces ban on mixed product promotional offers and cap on wagering requirements

On 26 March 2025, the Gambling Commission published its response to its consultation on socially responsible incentives, confirming that it will introduce a ban on mixed product promotional offers and a cap on wagering requirements. Whilst the introduction of the cap may be somewhat of a relief for operators (given the Commission consulted on an outright ban), the prohibition on mixed product promotional offers has been criticised by some in the industry as potentially impacting smaller operators disproportionately and (as is argued in respect of many of the Commission’s tightening restrictions) driving customers to the black market.

Ban on mixed product promotional offers

The Commission’s consultation on incentives, published back in Autumn 2023 and forming part of its second set of White Paper-related consultations, sought to introduce proposals which, in the Commission’s words, were “designed to reduce the likelihood of customers experiencing negative effects, such as excessive or harmful gambling, because of taking up an incentive”.

One such proposal was to ban the mixing of product types (e.g. betting, bingo, casino, and lotteries) within promotional offers, with the Commission’s reasoning being that “the evidence shows that these can be problematic because they can lead to consumer confusion and likelihood of experiencing harm”.

In its response to the consultation, the Commission has now confirmed that it will proceed with the ban. From 19 December 2025 (by way of an amendment to social responsibility code provision 5.1.1 (SR 5.1.1) of the Licence Conditions and Codes of Practice) licensees will be prohibited from including “more than one type of gambling product (betting, casino, bingo, and lottery) within an incentive”.

The language of the addition to SR 5.1.1 is broad, though the Commission does provide some useful clarifications in the consultation response document:

• Firstly, it confirms that the aim of this proposal is to ban the mixing of products within an individual incentive or promotional offer, where terms are linked and shared.
• Secondly, in light of the new requirements to require opt-in to direct marketing on a per-product and per-channel basis, the Commission confirms that licensees will be permitted to send more than one offer on products via the same channel, according to the marketing preferences to which the customer has opted in. The Commission gives the example of a licensee sending bonus offers for betting and bonus offers for casino products within the same email to a customer that has opted-in to receiving marketing via email for both betting and casino.
• Finally, the Commission confirms that it does not consider the new restriction to affect incentives which allow the customer to select the product on which to use credits or bonus money. For example, an incentive which provides a customer with a £10 ‘credit’ to use as they wish on products is permitted. By analogy, a customer could not be granted a casino bonus and a free bet from the same incentive.

Cap on wagering requirements

Having come under scrutiny from the Competition and Markets Authority in its investigation into the remote gambling sector back in 2021, wagering requirements have been criticised by some as being inherently unfair - a means by which customers are drawn into wagering more in the hope of realising an attractive bonus. It is not, therefore, surprising that the Commission consulted on a complete ban on wagering requirements. Alongside this, it also consulted on the potential of introducing a cap on wagering requirements, proposing wagering requirements be limited to a maximum of 1 time, 5 times, or 10 times.

Operators will be relieved to hear that the Commission has now confirmed that a cap of 10 will be applied, rather than the outright ban or one of the lower limits. The Commission’s reasoning for its leniency here was partly that due to the risk of the black market (it states that “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”). It was also of the view that an outright ban or lower cap would have a greater impact on small to medium sized gambling licensees (who would find it difficult to compete with more dominant operators who can afford to give a high volume of generous offers), and that a limit of 10 times would still eliminate extreme levels (with the Commission noting that some operators apply wagering requirements of up to 60 times).

From 19 December 2025, as provided by an amendment to SR 5.1.1, licensees will be prohibited from applying “wagering requirements to incentives, which require customers to play through bonus funds, over a maximum of 10 times”. In SR 5.1.1, the Commission defines a wagering requirement as “where a customer is required to make wagers totalling a particular value for funds to become withdrawable”.

Other amendments to SR 5.1.1

Finally, the Commission also consulted on certain changes to the drafting and structure of SR 5.1.1 to make it clearer and easier to understand. These changes were mainly clarificatory in nature, save that they consulted on the deletion of the current SR Code 5.1.1(1)(b)(i) which states “neither the value nor amount of the benefit is dependent on the customer gambling for a pre-determined length of time or with a pre-determined frequency”. The Commission has decided to proceed with this deletion.

The Commission also consulted on new wording to make it explicit that licensees must ensure the design and structure of the incentive does not lead to excessive intensity of gambling which may risk customers experiencing harms associated with gambling. The Commission has decided against making this change stating that “although LCCP SR Code 5.1.1 does not currently state which incentives or mechanics are likely to be socially irresponsible, there are controls and requirements already in place, within the Gambling Commission’s regulatory framework and advertising regulations, designed to address the risk of gambling harms”. Further, it noted the difficulty in defining the term ‘excessive intensity’.

Along with the introduction of the ban on mixed product promotional offers and cap on wagering requirements, these changes will take effect on 15 December 2025.