Casino VIP schemes: the rules

Many online casinos run VIP or “high value customer” schemes, with a personal account manager, tailored bonuses, gifts or invitations to events. In Great Britain these schemes are allowed, but the Gambling Commission expects operators to run strict checks first and to put a customer’s welfare ahead of their spending. Here is what the rules say, and what you can expect if you are invited.

Why VIP schemes are treated differently

The Commission says (opens in a new tab) its casework found that the way some VIP schemes were run acted as a barrier to identifying people who were experiencing harm. Its high value customers guidance (opens in a new tab) explains why. These customers bring operators a disproportionate share of revenue, which creates a risk of commercial motives clashing with the duty to protect customers. They also gamble more often, spend more, or both.

The guidance sits under the rewards and bonuses code (social responsibility code 5.1.1), which applies to every licence and is a condition of holding one. It says that if a licensee offers incentives or reward schemes to customers it designates as “high value”, VIP or equivalent, they must be offered in a way that is consistent with the licensing objectives and takes account of the Commission’s guidance.

What counts as a VIP scheme

There is no single legal definition of a high value customer. It depends on each operator’s business. The guidance covers customers who get enhanced service that is not available to everyone else, in the form of tailored or personalised incentives linked to high spend or frequent play. Examples include:

• invitations to hospitality, events or dinners
• a personal account manager or dedicated contact
• individual bonuses, benefits or gifts.

It does not cover ordinary promotions offered to large numbers of customers, or prize draws open to the wider customer base.

Checks before you are offered VIP status

According to the guidance on reward programmes (opens in a new tab), an operator should be able to show it has made three kinds of check before making anyone a VIP:

• Affordability: that your spending is affordable and sustainable as part of your leisure spending.
• Safer gambling: whether there is any evidence of gambling harm, or a heightened risk linked to vulnerability.
• Enhanced due diligence: up-to-date evidence of your identity, occupation and source of funds. That means where the money you gamble with actually comes from, not an estimate of what you might earn.

Operators are told to be cautious about money from an unplanned windfall, such as a big win, a redundancy payment or an inheritance. The people who carry out the checks should be kept separate from the staff who manage VIP relationships. If you cannot or will not provide the information needed, you should not be treated as eligible for VIP incentives.

If you have self-excluded in the past, the guidance says operators should treat that as a significant factor, and that the cases where it is appropriate to give you VIP incentives are limited. Where it does happen, a senior licence holder should sign it off, and mandatory deposit or spending limits are expected as a minimum.

These checks sit alongside the general financial risk checks that apply to all customers.

Ongoing reviews

• A VIP’s account should be reviewed at least quarterly, and more often if the risk changes.
• A review should cover every account you hold with that operator and its related group licensees, whatever the brand.
• If you fail a check, VIP status should be suspended immediately until the risk has been dealt with.
• Operators should act to restrict or end personalised incentives if your play goes beyond your usual habits with no explanation.
• Each programme should have a named senior person accountable for it, normally a personal management licence holder, and a full audit trail should be kept.

How incentives may and may not be used

The guidance expects operators to be able to show that their VIP incentives:

• do not encourage chasing losses, spending excessive time or money, or gambling more and more often
• are not timed to coincide with heavy play or significant losses
• are proportionate to your spending and to the operator’s affordability and vulnerability assessment
• do not push you to gamble excessively to reach or keep a VIP tier.

Staff should not be incentivised or paid based on a customer’s losses, spend or activity. Account managers must not exploit a vulnerability they learn about, and contact should stay professional rather than becoming that of a friend or confidant. Life events such as bereavement, losing income, a windfall or a relationship breakdown can make someone more vulnerable, and operators are expected to take them into account. Operators are also responsible for affiliates they use to recruit or manage VIPs.

A separate rule applies to every online customer, VIP or not. Under the Commission’s customer interaction code (social responsibility code 3.4.3), an operator that identifies strong indicators of harm must stop marketing to that customer and prevent them taking up new bonus offers. It must also act on those indicators in a timely way through automated processes, which can include blocking deposits. Our account guide explains how customer interaction works.

The industry code of conduct described by the Commission also includes a commitment to restrict access to VIP schemes for 18 to 24-year-olds.

Your choices as a VIP

• The guidance says VIPs should be offered an active choice about setting account limits. You can set deposit limits and reality checks whatever your status.
• You can ask to leave a VIP programme at any time. The operator should comply promptly and stop personalised incentives immediately.
• You can turn off marketing by product and channel in your account.
• Any bonus you are offered is still subject to the 10x wagering cap.

If a VIP manager’s contact is making it harder to cut down, consider self-exclusion through GAMSTOP. The National Gambling Helpline is free on 0808 8020 133 in England and Scotland; in Wales, the NHS All-Wales Gambling Helpline is 0808 2819 265.

If something goes wrong

If you think a VIP scheme was run in a way that ignored clear signs of harm, complain to the operator first and then, if needed, to its independent dispute resolution service. See how to complain to a UK online casino. The Gambling Commission does not decide individual complaints.