The UK Gambling Commission (UKGC) has published an ‘impact report’ on High Value Customers (HVCs) since introducing regulatory changes in 2020/2021.
The regulator has maintained concerns about the management and incentivisation of members of ‘VIP schemes’ or ‘High Value Customer’ schemes dating back to 2021.
Following a consultation process coordinated with the Betting and Gaming Council (BGC), the Commission imposed new rules on the management and remit of VIP/HVC schemes used by licensed operators.
Headline measures included an outright restriction on VIP schemes being promoted to customers aged under-25. Furthermore, all operators had to appoint a senior executive to monitor and audit HVC schemes directly with the UKGC.
Technical requirements saw the VIP schemes adopt new ‘enhanced due diligence’ on source of funding and affordability checks. Operators must ensure that all VIP accounts are audited with records kept of customer wagers and activities to prevent compulsive gambling.
New rules were effective from October 2020, as the Commission warned about previous instances of AML failings related to VIP scheme management.
Presenting its report, the Commission cites: “The initial impact on the reduction of HVC scheme members in 2021 was included in the Commission’s Advice to Government – Review of the Gambling Act 2005 document, including an estimated reduction of 90% in the number of customers signed up to schemes.
“This report presents a further consideration of the impact of the restrictions to VIP or High Value Customer (HVC) schemes.”
Since the implementation of these rules, updated data from 2024 confirms that the number of operators running HVC schemes remains stable, and membership levels have not rebounded to pre-2020 levels.
Crucially, the number of enforcement cases where HVC schemes were identified as a contributory factor has significantly declined, signalling a major success in mitigating the consumer protection and compliance risks that originally prompted regulatory intervention.
Commenting on the findings, David Taylor, the Commission’s Head of Evidence and Evaluation, said: “The headline findings are that these schemes are no more commonplace now than they were in 2021 – after the regulatory change.
“The number of consumers in them has also remained consistent, and the data collected from operators indicates every HVC scheme now has a senior executive appointed to oversee and be held accountable for how the scheme is operated.”
The report also examined the economic relevance of HVC schemes. On average, such schemes now account for just 3% of Gross Gambling Yield (GGY) across the sample.
However, the Commission notes that non-remote casinos show a growing dependence on HVC customers, with HVC-generated GGY often exceeding 10% in this sector.
Taylor explained: “One sector in this exercise which seems to have a greater reliance on scheme members as a proportion of GGY is land-based casinos, which is in line with our expectations.
“The vast majority of customers in high-end casinos are high-net-worth individuals based overseas. This factor, in particular, may have led to the difference in GGY proportions compared to other sectors and it’s worth noting that this finding isn’t accompanied with any allegations of consumer harm.”
Positive Overall Impact & Change
The Commission deems the overall impact of its 2020–21 HVC policy as positive — achieving its primary goals of lowering risk and enhancing accountability. Nonetheless, it acknowledges that revisions may be warranted in light of the unique characteristics and reliance of the land-based sector on HVC clientele.
Taylor added a note of caution to audiences: “Whilst we remain mindful that this exercise is reasonably modest in scope, the findings indicate that the intended impact is being achieved. Although evaluation exercises like this will never be able to give total assurance, it does provide an indication that the regulatory objectives have been delivered and further changes are not currently required.”
On transparency, the report notes limitations of its evaluations, most notably that the analysis is based on a sample of operators rather than a full industry census. This means some outliers or emerging practices may not have been captured. Similarly, while the Commission reviewed complaints made through its Contact Centre and third-party channels, it cautions that low complaint volumes do not necessarily reflect the full consumer experience, as they may be influenced by public awareness or reporting mechanisms.
Looking ahead, the Commission confirms that the management and oversight of VIP and HVC schemes will remain under close review. Compliance teams will continue to monitor the sector, and “may recommend a future review if findings change significantly,” particularly in response to trends within the land-based sector or shifts in consumer protection outcomes.
