Cashless payment technologies in gambling premises

 Debit cards and contactless payments have risen in popularity. Advances in technology that enable payments via phone, watches and wristbands has coincided with a significant decline in the use of cash by consumers.

 Gambling businesses are keen to make sure that they can offer their customers the same level of choice in payment options as other sectors of the leisure industry. Several operators have sought advice and guidance from us on their specific proposals for cashless facilities.

 Whilst the developments in payment technology were not foreseen when the  [Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/contents )  and supporting regulations were drafted, the legislation does, in most respects, permit operators to innovate and make cashless forms of payment available. However, the legislation also provides some important consumer protection measures. These aim to reduce the risks of customers spending more on gambling than they might be able to afford, or exceeding their budgets for a gambling session. There are specific restrictions in relation to payments to use gaming machines detailed in the following information.

 We are supportive of innovation, as long as the way in which it is done is consistent with the licensing objectives. We expect operators to ensure they are mitigating and minimising the risks of gambling-related harm when they make new payment facilities available in their premises. Operators should also be leading the way on identifying how innovation in products and services can support innovation in protecting and empowering consumers.  The responsibility rests with operators to be able to demonstrate that their payment solutions have been designed and made available with player protection measures in place. We may consider taking regulatory action in individual cases if, for example, an operator was to increase the risk of harm to its customers without providing appropriate mitigations. We may also consider options such as changes to our  [Licence Conditions and Codes of Practice (LCCP)](/licensees-and-businesses/lccp/online)  or advising government, in order to strengthen controls where necessary.

##  Minimising gambling-related harm

##  Considerations for operators

##  Licence Conditions and Codes of Practice: cashless payment

##  Checklist of considerations

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 Last updated: 8 June 2021

 Show updates to this content  No changes to show.


We encourage operators to consider how they can gather data both before and after the implementation of any measure so that they can demonstrate the impact of control measures.


 Research has shown that individuals can frequently gamble more money than they intended during gambling sessions. This leads to them making impulsive decisions that override their initial intentions to allocate a set amount of money to gamble with. Easy access to additional funds in gambling premises can therefore be a risk factor for problem gambling.  [Key issues in product-based harm minimisation (opens in a new tab)](https://www.greo.ca/Modules/EvidenceCentre/Details/key-issues-in-product-based-harm-minimisation-examining-theory-evidence-and-pol)  by Parke A, Parke J and Blaszczynski, A, was published in December 2016, and is a summary of research evidence.

 Research also shows that non-cash payment methods in gambling can lead to consumers over-spending, as such methods require less thinking about the actual cost and affordability implications of a transaction compared to cash payments.

 It is for operators to consider how player protection and empowerment can be most effectively delivered in practice.

 They are best placed to assess which measures are:

* most effective in mitigating the risk of customers spending more on gambling than they might be able to afford
* which are most effective in enabling customers to retain control over their own gambling spend. Operators may need to take account of specific risks such as the layout of their premises or vulnerabilities for particular customers.

 As part of their assessments on how they can best mitigate harm, operators must consider how they can facilitate the following. While there is no evidence to suggest what the ideal duration of a break should be, wherever possible the customer should at least be required to cease gambling at, and physically leave, the machine, terminal or table at which they are situated. This provides some time away from the gambling facilities before they are able to access and use new funds. This is consistent with the mandatory conditions attached to all premises licences that any ATM is located in a place that requires customers to cease gambling and leave the gambling product in order to use it.

 In any circumstance where customers might be able to access new gambling funds with only a limited or no physical break from the gambling product (for example, where customers might be able to use a debit card to replenish an app-based digital gambling ‘wallet-), the operator must ensure that customers are otherwise provided a break from or an interruption in gambling before those funds can be used.

###  Customers should be required to take a break from gambling before they access and use new funds to continue gambling

 The purpose of the break or interruption in play is to reduce the risk of harm to players that could arise from them losing track of the time and money they have spent gambling. By interrupting their state of dissociation, a break in play can give customers an opportunity to evaluate their own gambling behaviours, and could therefore facilitate better control (see  [Operator-based approaches to harm minimisation in gambling (opens in a new tab)](https://www.begambleaware.org/media/1177/obhm-report-final-version.pdf )  , by Parke A, Parke J, Blaszczynski, A and Rigbye J, published by Gamble Aware in 2014). A break or interruption in play could therefore involve, for example, slowing the transactional process and providing delays before new funds are made available to the player for use; perhaps combined with informative messaging, so as to support the player-s control and awareness of their gambling spend.

 Operators should use these new opportunities to support innovation in the protection and empowerment of consumers. For example, cashless payment technology may assist operators in tracking their customers- play, allowing them to collect better data on their customers- gambling behaviour and therefore helping to inform an assessment of those who may be at risk of gambling-related harm.

 The new technologies may also assist in the provision of tailored responsible gambling information to customers, including transactional information on the sums of money they have spent or withdrawn; or the development of player-led controls to enable better self-management of the customer-s gambling (eg allowing customers to set their own spend or withdrawal limits).


Licence Conditions and Codes of Practice: cashless payment

 There are certain conditions and codes of practice that must be adhered to when providing cashless payment facilities. These include, for example, the need to implement effective policies and procedures for minimising certain risks to the licensing objectives; and provisions that limit the circumstances in which credit can be provided, or prevent credit cards being accepted (and where the Gambling Act does not otherwise prohibit or restrict any such facility).

##  Operators should refer to the LCCP for full details of the following relevant requirements:

 [The Gaming Machines (Circumstances of Use) Regulations 2007 (opens in a new tab)](https://www.legislation.gov.uk/uksi/2007/2319/contents/made)  provide prohibitions and restrictions on the use of debit and credit cards for payments to play machines, which are straightforward safeguards intended to prevent consumers from gambling more than they can afford via a card.

##  Specific matters in relation to gaming machine payments


Operators should refer to the LCCP for full details of the following relevant requirements:

* [Licence condition 5.1 – cash and cash equivalents, payment methods and services](/licensees-and-businesses/lccp/condition/5-1-1-cash-and-cash-equivalents)
* [Licence condition 6.1 – provision of credit by licensees and the use of credit cards](/licensees-and-businesses/lccp/condition/6-1-1-provision-of-credit)
* [Social responsibility code provision 3.7 – provision of credit](/licensees-and-businesses/lccp/condition/3-7-1-provision-of-credit)


Specific matters in relation to gaming machine payments

 Our view is that card payments that originate from contactless mobile payment systems such as Apple Pay, Android Pay or Samsung Pay should be regarded as the same as payments to use a gaming machine by means of a card itself. This is because the device used for such types of payment (eg a smartphone or watch) is essentially just a medium by which a contactless card payment is made (ie the debit card sat behind the payment system is charged directly and the customer-s bank account is debited; the same as for any payment where the debit card itself is used).

 Both contactless card and mobile payment system transactions can be completed quickly, and so the risks to the consumer are largely identical.

 The regulations also prescribe limits as to the amounts an individual can deposit onto a gaming machine in any single action, and separately the (non-refundable) amount a player can commit to play the machine. These measures were designed to ensure consumers make regular decisions as to how much money they wish to commit to play a machine, and they must be observed regardless of the means of payment. That is, whether the customer has inserted cash into the machine, or whether they have transferred funds from a debit card via indirect means, a TITO (ticket-in, ticket-out) method or an operator-provided app-based digital wallet, a customer must only be able to deposit and commit funds to the gaming machine-s meters in accordance with these limits.


 We welcome sight of novel product or concept developments before they are deployed in the market. We do not approve individual products, and the responsibility rests with operators to ensure that their developments are compliant and will help to deliver the licensing objectives of the Gambling Act. It is recommended that businesses obtain their own legal advice in this regard.

 To assist developers we have provided a broad checklist of items that we expect them to have considered before contacting us. The list is not exhaustive and must not be considered in isolation from the previous advice. It provides a basic list of key issues.

##  In respect of the cashless technology product or system you are developing, you should be able to fully explain:

##  There are also a variety of harm mitigation and consumer empowerment measures that you should consider. You should ask yourself:


In respect of the cashless technology product or system you are developing, you should be able to fully explain:

* How you will make sure that consumers are required to have a break from gambling before they are able to access and use new funds.
* How you have satisfied yourself that you will be compliant with the Gaming Machine (Circumstances of Use) Regulations in respect of the use of debit or credit cards, payment limits and committed payment limits.
* What anti-money laundering controls you have considered in designing your solution. For example, would a player be able to fund a gambling product via cash and then withdraw funds via an app or digital wallet?


There are also a variety of harm mitigation and consumer empowerment measures that you should consider. You should ask yourself:

* What information can your product provide to the consumer about their own gambling? For example, will consumers be able to access information on their transactional gambling history over certain periods of time?
* Are you able to provide tools that enable the user to manage their gambling? For example, can the consumer use the product to set limits on the amount of money they are able to deposit or spend over a certain period of time?
* What alerts would be triggered when a limit is reached? How will the limit-setting be made effective in terms of reducing the risk of gambling-related harm?
* Does the product allow for users to voluntarily stop themselves from using the product for gambling purposes for a period of time? Or provide a cooling off period period whereby the product cannot be used for gambling for a certain period of time?
* If the product or system is to be made available for use with different gambling products (including different categories of gaming machine), how will you ensure that your solution is adaptable and able to respond to the different nature of each gambling product and the associated risks or legal requirements?
* Does your solution enable you or a gambling operator to monitor customer behaviour. For example, the gambling spend or intensity of an individual customer) over a period of time?
* How can you prevent, or assist in the prevention of, underage gambling?


* [Cashless payment technologies in gambling premises](#)
* [Minimising gambling-related harm](#minimising-gambling-related-harm)
* [Licence Conditions and Codes of Practice: cashless payment](#licence-conditions-and-codes-of-practice-in-cashless-payment-technologies)
* [Checklist of considerations](#checklist-of-considerations)

 [Print this guide](#)


 From 1 January 2020 operators must direct their annual financial contribution for gambling research, prevention and treatment as required by  [Licence Conditions and Codes of Practice (LCCP) SR code 3.1.1](/licensees-and-businesses/lccp/condition/3-1-1-combating-problem-gambling)  to one or more of the organisations on the following list.

 The purpose of this list is to demonstrate to operators how to be compliant with the LCCP requirement to make annual financial contributions to research, prevention and treatment.

##  Operators must:

>  We will collate information about LCCP RET contributions and publish this information at least annually.
>
>

 Businesses can continue to donate funds to any organisation outside of the approved list, but such contributions will not be counted as LCCP RET contributions.

>  Organisations will continue to be able to submit information to us and be added to the list on an ongoing basis. You must inform us whenever any of your information changes.
>
>

 List of organisations for operator contributions |  Name of organisation  |  Category  |  Type of organisation  |
| --- | --- | --- |
|  Addiction Recovery Agency Ltd (Ara)  |  Prevention  Treatment  |  Charity  |
|  Beacon Counselling Trust  |  Prevention  Treatment  |  Charity  |
|  Betblocker  |  Prevention  |  Charity  |
|  Betknowmore UK  |  Research  Prevention  Treatment  |  Charity  |
|  Bet On Me  |  Treatment  |  Private Company  |
|  Better Change  |  Prevention  |  Community Interest Company  |
|  Bournemouth University  |  Research  |  University Research  |
|  Breakeven  |  Prevention  Treatment  |  Charity  |
|  Centre of Excellence in Responsible Gaming (CERG)  |  Research  |  Charity  |
|  Deal me out  |  Prevention  |  Community Interest Company  |
|  Epic Restart Foundation  |  Prevention  |  Charity  |
|  EPIC Risk Management  |  Prevention  |  Private Company  |
|  ESG Corporate Community Interest Company (trading as ESG Gaming)  |  Research  Prevention  |  Community Interest Company  |
|  GambleAware  |  Research  Prevention  Treatment  |  Charity  |
|  Gambling Harm UK  |  Prevention  |  Charity  |
|  Gambling Treatment and Research Clinic, University of Sydney  |  Research  |  Public Research University  |
|  GamCare  |  Prevention  Treatment  |  Charity  |
|  Gordon Moody Association  |  Treatment  |  Charity  |
|  International Center for Responsible Gaming (ICRG)  |  Research  Prevention  |  Charity  |
|  JC Foundation Trust  |  Prevention  |  Community Interest Company  |
|  Leon House Health & Wellbeing Ltd  |  Treatment  |  Private Company  |
|  Nowt Left to Lose  |  Prevention  |  Community Interest Company  |
|  Racing to School  |  Prevention  |  Charity  |
|  Red Card Gambling Support Project CIC  |  Prevention  |  Community Interest Company  |
|  Reframe Coaching  |  Prevention  |  Charity  |
|  Responsible Gambling Council (Canada)  |  Research  |  Charity  |
|  Sport in Mind  |  Prevention  Treatment  |  Charity  |
|  The Forward Trust  |  Treatment  |  Charity  |
|  The University of Liverpool  |  Research  |  University research  |
|  Young Gamers & Gamblers Education Trust (YGAM)  |  Research  Prevention  |  Charity  |

##  The process for organisations who wish to be on the list for annual LCCP RET contributions

##  Information requirements for approved organisations for RET contributions

##  LCCP RET contributions data – April 2021 to March 2022

##  LCCP RET contributions data – January 2020 to March 2021

##  Files


* make an annual financial contribution to each of research, prevention and treatment. Your annual financial contribution must be to organisations for the purposes of delivering research, prevention and treatment. Payments for paid for services should not be counted as LCCP RET contributions
* ensure that these donations go to one or more organisation on the following list
* ensure that they have no connection to the recipient organisation
* report information accurately in their annual or quarterly regulatory return to the Gambling Commission about the destination(s) of their payment and the amounts that have been contributed. This includes ensuring that there is no duplication of data across multiple licences.


The process for organisations who wish to be on the list for annual LCCP RET contributions

 Gambling businesses are required to make an annual financial contribution to organisations which deliver or support research into the prevention and treatment of gambling-related harms, harm prevention approaches and treatment for those harmed by gambling (RET contributions). We do not specify an amount which may be contributed as this could be seen as imposing a levy, which is a power reserved for Parliament.

>  Being on the LCCP RET list is not a guarantee of receiving any financial RET contributions.
>
>

 We maintain a list to demonstrate to operators how to be compliant with the LCCP requirement to make financial contributions. It ensures that if businesses make contributions to organisations which work in other areas unconnected to reducing gambling harms in Britain, these amounts will not be considered compliant or published in the figures on LCCP RET contributions. Businesses can continue to donate funds to any organisation outside of the LCCP RET list, the only change is that such contributions will not be counted as LCCP RET contributions.

 Organisations seeking to be on the list of organisations to which gambling businesses may direct their RET contributions should provide information to the Commission to help us assess their suitability. This will include working to reduce gambling harms in Britain, and the need for independent oversight or regulation for all organisations. It will also include:

* in the case of research: the commissioning of research that is of general benefit, not solely or mainly for the purposes of informing the organisation-s other work
* in the case of treatment: a connection to the existing National Gambling Treatment Service and/or existing NHS England, Scotland or Wales mental health or addiction services.

 There is no cost for working with the Commission to be on the list, but we recommend that organisations read  [the guidance on expectations and the procedure for removal](/licensees-and-businesses/guide/lccp-ret-list-procedure-and-guidance-for-removal-of-organisations)  before submitting the  [LCCP RET Information form](#71RYGqUXTWmc0ZL4lXZaeq)  .


Information requirements for approved organisations for RET contributions

Approved organisations for RET contributions are required to send us quarterly returns listing the financial contributions they have received from operating licence holders. Returns consist of a templated MS Excel Open XML format spreadsheet, a blank copy of which is sent to approved organisations after their approval. Completed spreadsheets are to be submitted to  [retdata@gamblingcommission.gov.uk](mailto:retdata@gamblingcommission.gov.uk)  within 28 days of the end of each UK financial quarter.


 The data table below shows the data that has been reported to us from organisations on the LCCP RET list on contributions received during the period April 2021 to March 2022. The table covers 12 months of data.

 LCCP RET contributions data – April 2021 to March 2022 |  Recipient  |  April to June 2021  |  July to September 2021  |  October to December 2021  |  January to March 2022  |
| --- | --- | --- | --- | --- |
|  Action against Gambling Harms  |  0.00  |  0.00  |  2,500.00  |  1,500.00  |
|  Betblocker  |  5,000.00  |  0.00  |  10,000.00  |  6,394.00  |
|  Betknowmore UK  |  36,500.00  |  91,600.00  |  25,000.00  |  35,750.00  |
|  Deal me out  |  0.00  |  1,600.00  |  26,600.00  |  64,650.00  |
|  EPIC Risk Management  |  166,950.00  |  58,200.00  |  200,934.00  |  58,200.00  |
|  ESG Corporate Community Interest Company (trading as ESG Gaming)  |  0.00  |  0.00  |  0.00  |  34,884.00  |
|  GambleAware  |  2,245,445.00  |  5,821,140.00  |  2,416,342.00  |  24,219,897.00  |
|  GamCare  |  479,056.00  |  451,521.00  |  895,708.00  |  0.00  |
|  Gordon Moody Association  |  51,445.00  |  93,732.00  |  255,281.00  |  300,196.00  |
|  Leon House Health and Wellbeing Ltd  |  100,000.00  |  121,000.00  |  24,400.00  |  0.00  |
|  Red Card Gambling Support Project CIC  |  0.00  |  0.00  |  10,000.00  |  0.00  |
|  Responsible Gambling Council (Canada)  |  0.00  |  0.00  |  0.00  |  5,947.00  |
|  Sport in Mind  |  0.00  |  0.00  |  250.00  |  0.00  |
|  Young Gamer and Gamblers Education Trust (YGAM)  |  43,902.00  |  427,781.00  |  420,438.00  |  525,015.00  |
|  Total  |  3,128,298.00  |  7,066,574.00  |  4,287,453.00  |  25,252,433.00  |


 The data table shows the data that has been reported to us from organisations on the LCCP RET list on contributions received during the period January 2020 to March 2021. The table covers 15 months of data spanning two financial years.

 LCCP RET contributions data – January 2020 to March 2021 |  Recipient  |  January to March 2020  |  April to June 2020  |  July to September 2020  |  October to December 2020  |  January to March 2021  |
| --- | --- | --- | --- | --- | --- |
|  Action against Gambling Harms  |  0.00  |  0.00  |  500,000.00  |  0.00  |  0.00  |
|  Addiction Recovery Agency Ltd (Ara)  |  0.00  |  0.00  |  311,200.00  |  0.00  |  0.00  |
|  Betblocker  |  5,500.00  |  32,250.00  |  50,000.00  |  10,000.00  |  20,957.88  |
|  Betknowmore UK  |  0.00  |  0.00  |  54,320.00  |  46,832.19  |  130,669.31  |
|  EPIC Risk Management  |  0.00  |  51,250.00  |  57,500.00  |  156,750.00  |  108,750.00  |
|  GambleAware  |  4,074,507.55  |  1,940,985.25  |  692,508.98  |  2,552,392.59  |  14,544,811.10  |
|  GamCare  |  0.00  |  0.00  |  0.00  |  0.00  |  544,204.53  |
|  Gordon Moody Association  |  124,845.22  |  129,543.35  |  72,067.84  |  283,383.53  |  183,959.33  |
|  Leon House Health and Wellbeing Ltd  |  0.00  |  0.00  |  31,500.00  |  100,000.00  |  0.00  |
|  Red Card Gambling Support Project CIC  |  0.00  |  0.00  |  0.00  |  11,000.00  |  0.00  |
|  Sport in Mind  |  0.00  |  0.00  |  0.00  |  250.00  |  1,130.00  |
|  Young Gamers & Gamblers Education Trust (YGAM)  |  220,000.26  |  801,789.40  |  579,120.96  |  546,308.00  |  1,095,319.02  |
|  Total  |  4,424,853.03  |  2,955,818.00  |  2,348,217.78  |  3,706,916.31  |  16,629,801.17  |


 Some files may not be accessible for users of assistive technology. If you require a copy of the file in an accessible format  [contact us](/forms/formatrequest)  with details of what you require. It would help us to know what technology you use and the required format.

 **PDF Files**  Some PDF files cannot be displayed in a browser, you will see a message saying 'Please wait...'. If you see this message, you will need to download the file and open it in  [Adobe Acrobat Reader (opens in a new tab)](https://get.adobe.com/reader/)  .

 [LCCP-RET-Information-Form\_May 2022

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---

 Last updated: 11 April 2023

 Show updates to this content  Removed 'Action against Gambling Harms' from the list.

 Added 'Nowt Left to Lose' and 'Centre of Excellence in Responsible Gaming (CERG)' to the list.


* [List of organisations for operator contributions](#)
* [The process for organisations who wish to be on the list for annual LCCP RET contributions](#the-process-for-organisations-who-wish-to-be-on-the-list-for-annual-lccp-ret)
* [LCCP RET contributions data – April 2021 to March 2022](#lccp-ret-contributions-data-april-2021-to-march-2022)
* [LCCP RET contributions data – January 2020 to March 2021](#lccp-ret-contributions-data-january-2020-to-march-2021)

 [Print this guide](#)


 If you interact with customers you must provide the option of self-exclusion for those who would like to take steps to stop gambling.

 [LCCP: Section 3.5 social responsibility code and ordinary code](/licensees-and-businesses/lccp/condition/3-5-2-non-remote-ordinary-code)


How to help your customers when they want to self-exclude

 Entering into a self-exclusion is a significant step, and you should do what you can to ensure that the individual understands what it means. For example, that it is a commitment not to attempt to gamble for a minimum period of six months. Generally speaking, it is considered that this length of self-exclusion is necessary to enable an individual to deal with their problem gambling behaviour.

 However, a customer who has decided to take the step of self-excluding should be able to do so immediately and should not be required to wait.

 The customer should be offered the opportunity to speak to someone appropriate about self-exclusion, in some circumstances this may not be possible immediately. However, arrangements should be made as soon as possible, and if a customer is certain that they wish to self-exclude and does not wish to wait until they have spoken to a suitably trained and experienced member of staff, then they should be able to do so at once.

---

 Last updated: 18 June 2021

 Show updates to this content  No changes to show.


Regulatory settlements applied for socially responsible purposes

 When the Commission takes regulatory action against a gambling operator, an outcome of that action can include a payment in lieu of the financial penalty the Commission might otherwise impose for breach of a licence condition. This is set in accordance with the  [Statement of Principles for Determining Financial Penalties](/policy/statement-of-principles-for-determining-financial-penalties)  .

 We publish the details of those enforcement cases and regulatory settlements on our news page. For more information, see our approach to  [regulating the gambling industry](/about-us/what-we-do)  .

 A regulatory settlement can include payment to an organisation for socially responsible purposes.


Information about destinations of regulatory settlements to be applied for socially responsible purposes

 The Commission reviews proposals for destinations of regulatory settlements.

 Projects that have been approved since March 2019 are listed on our  [destinations of regulatory settlements to be applied for socially responsible purposes](/licensees-and-businesses/page/destinations-of-regulatory-settlements-to-be-applied-for-socially)  page.


Under the terms of a settlement, there is to be no publicity or benefit for the operator in connection with the regulatory settlement.


Information for proposals for destinations of regulatory settlements

>  Submissions for regulatory settlement funding are currently closed.
>
>

 We recommend you review  [our guidance for submitting a proposal for regulatory settlement funding](/guidance/guidance-for-submitting-a-proposal-for-regulatory-settlement-funding)  before making a submission, and be aware of our deadlines.

 If you want to know more about the group that will make the decisions about these proposals, review the  [Social Responsibility Funds Group Terms of Reference](/licensees-and-businesses/guide/social-responsibility-funds-group-terms-of-reference)  .


 Some files may not be accessible for users of assistive technology. If you require a copy of the file in an accessible format  [contact us](/forms/formatrequest)  with details of what you require. It would help us to know what technology you use and the required format.

 **PDF Files**  Some PDF files cannot be displayed in a browser, you will see a message saying 'Please wait...'. If you see this message, you will need to download the file and open it in  [Adobe Acrobat Reader (opens in a new tab)](https://get.adobe.com/reader/)  .

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---

 Last updated: 15 December 2022

 Show updates to this content  Callout added to indicate that proposals are now closed.


3.5.6 - Multi-operator non-remote SR code

 Applies to:

 All non-remote casino, bingo and betting licences (except in respect of the provision of facilities for betting in reliance on a track premises licence) and holders of gaming machine general operating licences for adult gaming centres

 **Social responsibility code**  Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator-s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.

1. Licensees must offer customers with whom they enter into a self-exclusion agreement in respect of facilities for any kind of gambling offered by them at licensed gambling premises the ability to self-exclude from facilities for the same kind of gambling offered in their locality by any other holder of an operating licence to whom this provision applies, by participating in one or more available multi-operator self-exclusion schemes.


3.4.1 - Premises-based customer interaction

 Applies to:

 All non-remote licences (except non-remote lottery, gaming machine technical, gambling software and host licences); only the following remote licences – ancillary remote bingo, ancillary remote casino, ancillary remote betting, remote general betting limited, and remote betting intermediary (trading rooms only).

 **Social responsibility code**  Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator-s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.

1. Licensees must interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling. This must include:

- identifying customers who may be at risk of or experiencing harms associated with gambling.
- interacting with customers who may be at risk of or experiencing harms associated with gambling.
- understanding the impact of the interaction on the customer, and the effectiveness of the Licensee-s actions and approach.

- Licensees must take into account the Commission-s guidance on customer interaction.


Customer interaction: formal guidance for premises-based operators

>  This guidance applies to premises-based operators and is currently in effect.
>
>

>  This is an HTML version of this guidance. You can also view or download the  [original customer interaction guidance for premises-based operators (PDF)](#4ae78UgfVJADGplhwuPC56)  published in July 2019.
>
>

 Premises-based licensees are required to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, as set out in  [Social Responsibility Code Provision 3.4.1](/licensees-and-businesses/lccp/condition/3-4-1-customer-interaction)  of the Licence Conditions and Codes of Practice (LCCP).

 A requirement to LCCP with effect from 31 October 2019 (as amended 12 September 2022) requires premises-based licensees to take into account the Commission-s guidance on customer interaction. This guidance is structured along the three key outcomes operators are expected to meet.

 These are, to:

* **identify**
* interact
* evaluate .

 This guidance sets out why customer interaction is a requirement, makes our expectations clear, and suggests ways you could meet them. This includes learnings from research and some ways that gambling operators have found worked for them and their customers.


 The purpose of this guidance is to share knowledge based on research, current practice and lessons learned in order to support licensees in determining how they can meet the outcomes. It sets out why customer interaction is important and makes our expectations clear. Not all of the content of the guidance will be relevant to all operators, but licensees must take it into account and be able to demonstrate how they have done so.

 Following the guidance is no guarantee that all customers experiencing or at risk of harm will be identified. The guidance is not the only source of information which operators should use to help them develop their own processes, and licensees should also keep up to date with published research and other sources.


 For compliance and enforcement purposes, we will expect licensees to demonstrate how their policies, procedures and practices meet the required outcomes. This can be through implementing relevant parts of the guidance or demonstrating how and why implementing alternative solutions equally meet the outcomes.

 Our understanding of gambling harms and how they manifest is constantly evolving, so for the purposes of raising standards, protecting consumer interests, and preventing harm to consumers, we will update and re-issue guidance where new evidence or risks emerge which may have a meaningful impact on how the outcomes can be met.

##  Identifying the right customers

##  Understanding the impact of gambling harms

##  Using the right indicators for your business

##  Affordability and a customer-s personal circumstances

##  Vulnerability

##  Spotting harmful gambling

##  The role of staff

##  Identify: questions to consider

##  Interacting with the customer

##  Offering help and support

##  The role of staff

##  Keeping records

##  Interact: questions to consider

##  Evaluate

##  Understanding the impact of individual interactions

##  Evaluating the effectiveness of the approach

##  The role of staff

##  Evaluate: questions to consider

##  Files


 You need to know:

* the types of markers and behaviours that could indicate harm relevant to online gambling, and
* how to spot when those indicators should trigger an interaction.

 You need to put together what you know about the customer, with the relevant indicators of harm, to decide whether you need to interact. More knowledge about what to look for, with effective processes for monitoring customer behaviour, can mean quicker and better-informed decisions.

 Some indicators of harm, such as high staking behaviour, can look similar to VIP and high-value customer activity. Even if you think the customer can afford it, they may still be experiencing gambling harms. Your enhanced contact with your VIPs means you have many opportunities to get to know them well and make better informed decisions.

###  Identify

 We expect you to: * Use a range of indicators relevant to your business that you can observe and monitor. Do not rely on financial indicators alone. Where trigger points or thresholds are used, they should be realistic, and remember that not every customer who is experiencing or at risk of harm will trigger every indicator.
* Monitor customer activity and behaviour so that you are able to interact early and quickly. Invest in appropriate systems and staff to manage your customer interaction process effectively.
* Make sure your process keeps pace with any increase in demand – through general growth or seasonal, promotional or other variations which might mean you are busier than usual.
* Train your staff to know their roles and responsibilities, and ensure they are supported and given the tools and skills they need to be able to act promptly when they spot or are alerted to indicators of harm, including those among your VIP and monitored customers.
* Ensure that your customers are not put at any greater risk of harm as a result of your premises being busier or quieter than usual. You need to protect your customers regardless of these factors.
* Think about the protection of new customers – you know less about them, so you may not know what their regular gambling pattern looks like. This means that alternative measures must be applied.
* Take safer gambling seriously for all customers including VIPs and not let commercial considerations override customer protection.
* Make meaningful records of all interactions with customers. Make these records available to staff and use them to aid decision-making. This should also take place in circumstances where an interaction has been ruled out. For example, because the customer is displaying signs of agitation.
* Even if you think your sector is 'lower risk', all forms of gambling present risks and you should understand the prevalence of gambling harms for the type of gambling products you offer and implement appropriate processes.
* Actively promote tools such as voluntary machine alerts, and ensure all your customers have access to information about safer gambling and the support available.


Understanding the impact of gambling harms

 In 2018 the Gambling Commission published research (Wardle et al 2018) on understanding the full range of gambling harms and the impact this can have on society. This research defined gambling harms as the ‘adverse impacts from gambling on the health and wellbeing of individuals, families, communities and society-. This can include loss of employment, debt and crime – gambling harms can also have detrimental impacts on physical and mental health and relationships, and at its worst, gambling can contribute to loss of life through suicide.

 Gambling harms cannot be solely measured in terms of finance and resources. This is why we expect you to use a range of indicators in order to identify customers who may be experiencing harms.


Using the right indicators for your business

 Change compared with previous gambling activity is a general trigger for customer interaction. Building up your knowledge of your regular customers is key to helping you spot changes in their behaviour.

 You should use a range of indicators. This is not an exhaustive list, but your indicators should include the following.

###  Time indicators

 Amount of time spent gambling, visit frequency or length of stay on the premises, leaving and then returning to the premises.

###  Spend

 Amount and frequency of deposits, large losses, using multiple or more expensive payment methods, declined payments, appearing to spend more than they originally intended.

###  Behaviour or appearance

 Such as signs of distress, agitation, or changes which could be an indication that gambling is having a negative impact on a customer-s wellbeing.

###  Use of gambling management tools

 Previous self-exclusions or previous customer interactions, or playing through machine alerts.

###  Customer-led contact

 Information or hints from the customer, frequent complaints about not winning, or talking about the negative impacts of their gambling.

###  Play indicators

 chasing losses, erratic betting patterns and gambling on higher risk products, or unusual markets or outcomes on which the customer is unlikely to have been able to make an informed choice. People who bet in-play may place a higher number of bets in a shorter time period than people who bet in other ways, as  [in-play betting](/licensees-and-businesses/guide/in-play-or-in-running-betting)  offers more opportunities to bet.

###  A ‘big win- or a windfall

 Research (Parke and Parke 2017) shows high staking following a win could hide or even lead to harmful behaviour. Suddenly having more money than usual can lead to increasing staking, which can lead to harms not associated with wealth or resources.


Affordability and a customer-s personal circumstances

 Historically, gambling operators have not systematically considered customer affordability when developing their customer interaction policies. Many have used deposit or loss thresholds as a main or sole prompt for a customer interaction, but these have often been set at levels that were inappropriately high, in comparison to the average amount of money that the majority of people have available to spend on leisure activities.

 This has led to a number of examples of customers spending more than they could afford, and this not being identified sufficiently early, as seen in much of the Commission-s compliance and enforcement casework since 2017.

 Operators should aim to identify those experiencing or at risk of harm and intervene to try to reduce harm at the earliest opportunity. Reliance on deposit or loss thresholds that are set too high will result in failing to detect some customers who may be experiencing significant harms associated with their gambling. It is therefore imperative that threshold levels are set appropriately.

 Open source data exists which can help operators assess affordability for their British customer base and improve their risk assessment for customer interactions. Thresholds should be realistic, based on average available income for your customers. This should include the Office of National Statistics (ONS) publications on levels of household income. See the  [ONS information on personal and household finances (opens in new tab)](https://www.ons.gov.uk/peoplepopulationandcommunity/personalandhouseholdfinances)  .

 In considering these thresholds, you should be aware of the difference between ‘disposable income- and ‘discretionary income- which refers to the amount left after living costs are taken into account, but it does still include many other unavoidable costs. Most people would consider it harmful if they were spending a significant amount of their discretionary income on gambling.


 Life events or changes to an individual customer-s circumstances may mean that a person becomes more or less vulnerable to experiencing gambling harms. Those circumstances could include bereavement, loss of income or other factors, as follows. It will not always be obvious or clear to an operator when such events have occurred, but knowing your customers, and ensuring staff ask questions when there are potential signs of vulnerability, will help to determine whether those individual circumstances present an increased risk.

 As part of ‘know your customer- and developing customer interaction policies and procedures, operators should consider the factors that might make an individual more vulnerable to experiencing gambling related harms.

 Factors include:

* **personal and demographic**  - if the individual is experiencing poor physical or mental health, physical or cognitive impairment, suffering side effects from a brain injury or medication or has an addiction
* **situational**  - if the individual is experiencing financial difficulties, is homeless, is suffering from domestic or financial abuse, has caring responsibilities, experiences a life change or sudden change in circumstances
* **behavioural**  - if an individual has a higher than standard level of trust or high appetite for risk
* **market-related**  - if an individual is engaged in an activity which is highly complex; that they have a lack of knowledge and/or experience of the market
* **access**  - if an individual has difficulty accessing information because of poor literacy or numeracy skills, knowledge, dyslexia.

 We have seen examples through our casework of customers who should have received some interaction but did not, including customers who were particularly vulnerable, and more susceptible to experiencing gambling harms.


 How you monitor activity depends on your business. For some very small operators, manual monitoring may work. Larger operators will need comprehensive systems, which could include a mix of automated and manual processes and should draw on all available sources of data to give a comprehensive picture of the customer-s gambling.

 Options for spotting harmful gambling include:

* Reports on activity where relevant, for example from observation or loyalty carded play, particularly if the play is linked to online play
* Sharing of information by staff about concerns
* Customer interaction forms, day diary with flags
* Utilising back office systems and alerts where they exist.

 The right information can mean better and quicker decisions. The customer interaction records you keep should give staff a more complete picture of the customer-s previous activity, which will help to inform decisions.

 Your customers should not be at more risk because your premises are either busier or quieter than usual. You should ensure you have appropriate levels of well-trained staff on duty to meet the licensing objectives.

 Because VIP customers can also experience harm, it is good practice to carry out a safer gambling check when upgrading customers to VIP status and keep this under review. You should also use these opportunities to carry out checks for Anti-Money Laundering (AML). This could also help you to support customers who have had major wins.


 It is important that all staff receive training so that they are aware of the signs that could indicate that a customer may be experiencing harms associated with gambling.

 This is not an exhaustive list, but you should ensure that:

* Staff are trained to identify the signs of harm and refer back to documents that include the types of behaviour that may trigger customer interaction at an appropriate moment. Staff should know how to escalate a situation if they are unsure or require support.
* Staff understand how indicators of harm could be displayed differently in VIP or ‘high-value- customers and know how to spot the signs.
* As a minimum, staff receive training at induction as well as refresher training.


 These include:

* Are you curious about your customers?
* Are your indicators relevant to your gambling facilities and customers?
* How do you decide the right level of your thresholds?
* Do all appropriate staff have access to customer interaction records?
* How do you assess the risks posed by new and unfamiliar customers?
* Is staff training on customer interaction meaningful and engaging?
* Do you take into account all relevant information and act quickly?
* Does the structure and layout of your premises help or hinder identifying customers you need to interact with?
* Do you have any blind spots which mean that you are unable to monitor all customer activity?
* Is spend monitored across different products for individual customers?
* Do you offer the same level of protection for all your customers, no matter how long they have been a customer, or whether they are VIPs?


 When you are concerned that a customer may be experiencing harm, acting early and quickly could help stop or prevent the harm worsening. It is important in a premises environment that you interact with the customer in a timely manner whilst the opportunity presents itself.

 For some customers, making them aware of why you are concerned may be enough to prompt them to think and make a change. Some customers will need more support or advice.

 Your interactions should have an outcome. Knowing what impact your interaction has had will help you support the customer and help to keep improving your approach. To achieve this, it is vital to keep good records and make them available to staff to inform decisions.

###  Interact

 We expect you to: * Be curious, and if you spot behaviour or vulnerabilities that could indicate harm, to act on it.
* Ensure your staff have access to the information and support they need, such as customer interaction records, so that they are able to make decisions about how to interact and can do so discreetly.
* Interact in a way that is appropriate to the severity of the potential harm. You should trial and evaluate different approaches to achieve this.  **Importantly, this may include refusing service or ending the business relationship.**
* Think about what information you should give the customer to help them understand why you are interacting with them, such as describing the type of behaviour they display or practical help or support where appropriate.

 In gambling premises, many of your interactions are likely to be face-to-face, so it is important for staff to be prepared in advance of carrying out a customer interaction.

 You should consider:

* What do you need to know from the customer and what do you already know about them?
* What information do you want to give them?
* How many times have you already interacted with the customer?
* What outcome do you want to achieve?
* Is the customer behaving in a way which might inhibit an interaction at this point?

###  A customer interaction has three parts

 These are:

1. Observation – behaviour or activity you have spotted or something the customer tells you.
2. Action – contact to prompt the customer to think about their gambling, for you to find out more, and an opportunity for you to offer information or support.
3. Outcome – what you or the customer did next. In some cases, you may need to monitor the customer-s gambling to spot any change which may prompt further action.


 Encourage customers to think about their gambling. Their responses will help you work out the right kind of help and support to offer.

 You will need to direct some customers to information about safer gambling and/or suggest appropriate gambling management tools. You might need to signpost them to sources of help and specialist support from organisations which deal with advice and treatment for problem gambling.

 You must also make information about safer gambling readily available to customers, as well as information about problem gambling.

 You will need to interact with some customers a number of times. Your records of previous interactions with customers will help you decide how to provide the right help and support.

 Feedback from consumers shows that they often respond better to being informed about their behaviour and why, rather than being “told” what to do. But for some customers, and particularly if the behaviour continues to cause concern, you may need to take a more proactive approach. In some cases, you may need to take action for the customer, which could mean refusing service.


 You should ensure that your staff:

* understand the types of interaction that could take place and how to interact appropriately. For example, they may only need a brief intervention.
* know the type of help or support to offer, such as information, signposting customers to specialist support or the gambling management tools which are available. These may be the minimum required under the LCCP or tools you offer which go beyond minimum requirements.
* know the circumstances and process for refusing service to customers, such as requesting a customer to leave or barring a customer.
* understand their respective responsibilities and who is designated to carry out customer interactions, if only certain staff members are authorised to interact.
* are advised how to deal with situations where customers demonstrate signs of agitation, distress, intimidation, aggression or other behaviours that may inhibit customer interaction, and what to do if the interaction does not take place at that time.

 Whilst training on the legislative framework is important, staff also need to be trained on the skills and techniques they need to help them carry out customer interactions.


 Good record keeping allows you to demonstrate when and why you have interacted with customers and helps with ongoing monitoring of customers.

 You should:

* Keep records of all customer interactions and, where an interaction has been ruled out, the reasons for this. Where an interaction has taken place at a later date, this should also be recorded.
* Make use of all relevant sources of information to guide and deliver effective customer interactions, including your records of previous interactions.

 Good records should include:

* the behaviour or activity before the interaction.
* the change in behaviour or prompt for the interaction.
* how you interacted and what was said or done, for example advice or suggestions to help the customer manage their gambling, or to take a break from their gambling, and
* what happened next.

 You should also record situations where an interaction was prompted but did not take place, and how you followed that up.

 In some cases, you will need to monitor the customer-s gambling to spot behaviours which could indicate further harm.


* Where concerns arise, are you able to intervene early and engage with a customer at the right time?
* How do you ensure your staff are prepared and able to carry out interactions?
* Are your staff able to carry out customer interactions discreetly?
* Are your staff aware of and trained to carry out different levels of interaction?
* Have you allocated the right level and kind of resources to be able to interact with customers effectively when you have concerns?


 By evaluate, we mean to understand impact and effectiveness in two ways:

* did an individual customer interaction have a positive outcome for the customer, and
* does your overall approach to customer interaction work?

 To help with the latter, the Advisory Board for Safer Gambling published an evaluation protocol in 2016 for the industry to use when designing evaluations.

>  Find out more about the  [National Strategy to Reduce Gambling Harms](/about-us/reducing-gambling-harms)  , including the  [evaluation protocol](/strategy/national-strategy-to-reduce-gambling-harms/evaluation-gambling-commission-actions)  and further research on gambling-related harms.
>
>

###  Evaluate

 We expect you to: * Understand the impact of individual interactions on a consumer-s behaviour and whether, or what, further action is needed.
* Evaluate the effectiveness of your approach by trialling and measuring impact.
* Embed lessons learned and best practice across the business and collaborate to share across the industry.


Understanding the impact of individual interactions

 In this context, by impact we mean a change in the customer-s gambling activity which could be attributed to the interaction. An important part of this is whether the customer has understood the information or advice you gave.

 Not every customer who receives an interaction will require active follow up, but many will. In these cases, follow up activity should be proportionate to the severity or extent of the harm being displayed. This approach will help you target your resources where they are most needed.

 Understanding the impact of the interaction on the customer includes being able to look at and compare:

* the behaviour before the interaction.
* the change in behaviour or prompt for the interaction.
* how you interacted – what was said or done, and
* what happened next.

 Some ways to work out impact include:

* Did the customer start using gambling management tools independently or following your advice?
* If you use email, did the customer click through to safer gambling information from your tracked links?
* Was there a positive change in behaviour? Did the customer-s gambling seem to change after the interaction?
* You could also follow up and ask the customer whether they found the interaction helpful or not.
* Is there a need for further or follow up action?

 You may already quality assure individual customer interactions by spot- checking records. As well as checking that customers are getting the right support, this can also identify staff development needs and highlight good practice that you can share across your business and across the industry.


Evaluating the effectiveness of the approach

 Records of interactions can provide useful evidence of what types of indicators, methods of interacting and options for providing support work well for customers. They will help to inform an evaluation of the effectiveness of your overall approach to customer interaction. Good evaluation helps you to understand which aspects of your approach are the most effective at identifying the right customers, and the types of tools or support that work well to help customers manage their gambling in a way that works for them.

 The following measures could help to work out whether your approach is working well:

* Customer retention.
* Reduction in complaints.
* The appropriate number of customer interactions in relation to the size of your customer base or footfall, and the type of gambling you offer, as follows.

 You should know and understand the prevalence of at-risk gambling among your customer base. A starting point is the  [combined health surveys](/news/article/gambling-commission-publishes-latest-combined-health-survey)  of England, Scotland and Wales (Gambling Commission 2018). This data is broken down to gambling activity type, and by region.

 However, rates will vary significantly between geographical areas and localities, and research shows that problem gambling rates in urban areas are likely to be higher than the national average. Further information on this topic can be found in the Research Report Problem Gambling in Leeds (Kenyon et al 2016). When looking at the potential percentage of your customers who may be experiencing harm, remember to consider the percentage of gamblers participating in that activity and not the percentage of the adult population.

 Currently the only industry-wide quantitative measure of identifying and interacting with customers who may be experiencing harms associated with gambling is data on the numbers of customers who received an interaction, submitted to the Commission as part of regulatory returns. We have clarified the definitions in regulatory returns to offer guidance on what should be included in a customer interaction (incident) log and make clearer what should be recorded.

 Your log should include as a minimum:

* the identity or other identifier of the customer involved
* the behaviour or activity that prompted the interaction
* the advice or support given, and
* the outcome of the interaction.

 Keeping your policies and procedures under review and up to date by taking into account research and industry best practice will help you to identify customers you should be interacting with, which will help you target your resources where they are most needed, in ways which may lead to better outcomes.

 You should also review your internal controls following the publication of a regulatory settlement, to address any similar weaknesses which could exist in your own processes.


 Your staff have an important role to play to understand whether your approach works.

 As a minimum, you should:

* Ensure that records of all customer interactions are made by staff and used to aid decision making. Such records should be used for evaluation purposes, for example, dip sampling for quality assurance purposes. Or, to assess whether a customer changed their behaviour as the result of an interaction.
* Train staff to recognise when follow-up activity to an interaction is required.
* Ensure that staff use customer interaction records as a decision-making tool.
* Ensure that staff are properly supported in carrying out effective interventions.


* Do you know how many of your customers may be experiencing some level of harm associated with gambling?
* How do you know you are delivering positive outcomes for your customers?
* How could you improve on your policies and procedures?
* How could you share your good practice with the industry?


 Some files may not be accessible for users of assistive technology. If you require a copy of the file in an accessible format  [contact us](/forms/formatrequest)  with details of what you require. It would help us to know what technology you use and the required format.

 **PDF Files**  Some PDF files cannot be displayed in a browser, you will see a message saying 'Please wait...'. If you see this message, you will need to download the file and open it in  [Adobe Acrobat Reader (opens in a new tab)](https://get.adobe.com/reader/)  .

 [Customer Interaction Formal Guidance: Non Remote (July 2019)

 application/pdf PDF 299.5 kB](//assets.ctfassets.net/j16ev64qyf6l/4ae78UgfVJADGplhwuPC56/b38fcc3699189658ab8b19da18627718/Customer-Interaction-Formal-Guidance-Non-Remote-July-2019.pdf)

---

 Last updated: 12 September 2022

 Show updates to this content * Callout added to the beginning of the guide.


* [Customer interaction: formal guidance for premises-based operators](#)
* [Identifying the right customers](#non-remote-identifying-the-right-customers)
* [Understanding the impact of gambling harms](#understanding-the-impact-of-gambling-harms)
* [Using the right indicators for your business](#non-remote-using-the-right-indicators-for-your-business)
* [Affordability and a customer-s personal circumstances](#affordability-and-a-customers-personal-circumstances)
* [Vulnerability](#non-remote-vulnerability)
* [Spotting harmful gambling](#non-remote-spotting-harmful-gambling)
* [Interacting with the customer](#non-remote-interacting-with-the-customer)
* [Offering help and support](#non-remote-offering-help-and-support)
* [Keeping records](#non-remote-keeping-records)
* [Evaluate](#non-remote-evaluate)
* [Understanding the impact of individual interactions](#non-remote-understanding-the-impact-of-individual-interactions)
* [Evaluating the effectiveness of the approach](#non-remote-evaluating-the-effectiveness-of-the-approach)

 [Print this guide](#)


3.4.2 - Customer interaction – lotteries

 Applies to:

 All lottery licences

 **Social responsibility code**  Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator-s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.

1. Licensees who are non-commercial societies or external lottery managers must:
	1. set an upper limit on the value of lottery tickets which may be sold to a person, whether as part of a single transaction or over a period of time, without customer interaction;
	2. maintain records of all instances of customer interaction pursuant to (a) above and, in each case, whether purchase of tickets beyond the limits set was then permitted; and
	3. ensure such records are made available to the Commission for inspection on request and retained for at least three years from the date of any lottery to which they relate.


 Applies to:

 All remote licences, except any remote lottery licence the holder of which does not provide facilities for participation in instant win or high frequency lotteries  [1](#343-1)  , remote gaming machine technical, gambling software, host, ancillary remote bingo, ancillary remote casino, ancillary remote betting, remote betting intermediary (trading rooms only) and remote general betting limited licences.

 **Social responsibility code**  Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator-s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.

 In effect dates:

* in paragraph 1, the words ‘as explained in the Commission-s guidance (see paragraph 2)-; and the entirety of requirements 2 and 3 are not yet in effect
* paragraph 10 will come into effect on 12 February 2023
* the remainder of Social Responsibility Code Provision 3.4.3 is in effect from 12 September 2022.
1. Licensees must implement effective customer interaction systems and processes in a way which minimises the risk of customers experiencing harms associated with gambling. These systems and processes must embed the three elements of customer interaction – identify, act and evaluate – and which reflect that customer interaction is an ongoing process as explained in the Commission-s guidance (see paragraph 2).
2. Licensees must take into account the Commission-s guidance on customer interaction for remote operators as published and revised from time to time (‘the Guidance-).
3. Licensees must consider the factors that might make a customer more vulnerable to experiencing gambling harms and implement systems and processes to take appropriate and timely action where indicators of vulnerability are identified. Licensees must take account of the Commission-s approach to vulnerability as set out in the Commission-s Guidance.
4. Licensees must have in place effective systems and processes to monitor customer activity to identify harm or potential harm associated with gambling, from the point when an account is opened.
5. Licensees must use a range of indicators relevant to their customer and the nature of the gambling facilities provided in order to identify harm or potential harm associated with gambling. These must include:

	* a. customer spend
	* b. patterns of spend
	* c. time spent gambling
	* d. gambling behaviour indicators
	* e. customer-led contact
	* f. use of gambling management tools
	* g. account indicators.
6. In accordance with SR Code Provision 1.1.2, licensees are responsible for ensuring compliance with the requirements. In particular, if the licensee contracts with third party business-to-business providers to offer any aspect of the licensee-s business related to the licensed activities, the licensee is responsible for ensuring that systems and processes are in place to monitor the activity on the account for each of the indicators in paragraph 5 (a-g) and in a timely way as set out in paragraphs 7 and 8.
7. A licensee-s systems and processes for customer interaction must flag indicators of risk of harm in a timely manner for manual intervention, and feed into automated processes as required by paragraph 11.
8. Licensees must take appropriate action in a timely manner when they have identified the risk of harm.
9. Licensees must tailor the type of action they take based on the number and level of indicators of harm exhibited. This must include, but not be limited to, systems and processes which deliver:

	* a. tailored action at lower levels of indicators of harm which seeks to minimise future harm
	* b. increasing action where earlier stages have not had the impact required
	* c. strong or stronger action as the immediate next step in cases where that is appropriate, rather than increasing action gradually
	* d. reducing or preventing marketing or the take-up of new bonus offers where appropriate
	* e. ending the business relationship where necessary.
10. Licensees must prevent marketing and the take up of new bonus offers where strong indicators of harm, as defined within the licensee-s processes, have been identified.
11. Licensees must ensure that strong indicators of harm, as defined within the licensee-s processes, are acted on in a timely manner by implementing automated processes. Where such automated processes are applied, the licensee must manually review their operation in each individual customer-s case and the licensee must allow the customer the opportunity to contest any automated decision which affects them.
12. Licensees must implement processes to understand the impact of individual interactions and actions on a customer-s behaviour, the continued risk of harm and therefore whether and, if so, what further action is needed.
13. Licensees must take all reasonable steps to evaluate the effectiveness of their overall approach, for example by trialling and measuring impact, and be able to demonstrate to the Commission the outcomes of their evaluation.
14. Licensees must take account of problem gambling rates for the relevant gambling activity as published by the Commission  [2](#343-2)  , in order to check whether the number of customer interactions is, at a minimum, in line with this level. For the avoidance of doubt, this provision is not intended to mandate the outcome of those customer interactions.
##  References


 1  A high frequency lottery is a lottery in which any draw takes place less than one hour after a draw in a previous lottery promoted on behalf of the same non-commercial society or local authority or as part of the same multiple lottery scheme.
 2  [Problem gambling rates for the relevant gambling activities](https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/the-importance-of-interacting-with-customers#problem gambling rates)  are available on our website.


Customer interaction: formal guidance for remote gambling operators

>  This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022.
>  Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this  [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update)  . The  [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance)  is not in effect and is subject to further consultation. Operators are not required to take it into account.
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>  This is a HTML version of this guidance. You can also view or download the  [previous customer interaction guidance for remote operators (PDF)](#joicGBiBnXbw03f7S9HVr)  published in July 2019.
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 All licensees are required to interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling, as set out in  [Social Responsibility Code Provision 3.4.1](/licensees-and-businesses/lccp/condition/3-4-1-customer-interaction)  of the Licence Conditions and Codes of Practice (LCCP).

 A requirement to LCCP with effect from 31 October 2019 requires licensees to take into account the Commission-s guidance on customer interaction. This guidance is structured along the three key outcomes operators will be expected to meet.

 These are, to:

* **identify**
* interact
* evaluate .

 This guidance sets out why customer interaction is a requirement, makes our expectations clear, and suggests ways you could meet them. This includes learnings from research and some ways that gambling operators have found worked for them and their customers.

###  How to use this guidance

 The purpose of this guidance is to share knowledge based on research, current practice and lessons learned in order to support licensees in determining how they can meet the outcomes. It sets out why customer interaction is important and makes our expectations clear. Not all of the content of the guidance will be relevant to all operators, but licensees must take it into account and be able to demonstrate how they have done so.

 Following the guidance is no guarantee that all customers experiencing or at risk of harm will be identified. The guidance is not the only source of information which operators should use to help them develop their own processes, and licensees should also keep up to date with published research and other sources.

###  How we will use this guidance

 For compliance and enforcement purposes, we will expect licensees to demonstrate how their policies, procedures and practices meet the required outcomes. This can be through implementing relevant parts of the guidance or demonstrating how and why implementing alternative solutions equally meet the outcomes.

 Our understanding of gambling harms and how they manifest is constantly evolving, so for the purposes of raising standards, protecting consumer interests, and preventing harm to consumers, we will update and re-issue guidance where new evidence or risks emerge which may have a meaningful impact on how the outcomes can be met.


 Some files may not be accessible for users of assistive technology. If you require a copy of the file in an accessible format  [contact us](/forms/formatrequest)  with details of what you require. It would help us to know what technology you use and the required format.

 **PDF Files**  Some PDF files cannot be displayed in a browser, you will see a message saying 'Please wait...'. If you see this message, you will need to download the file and open it in  [Adobe Acrobat Reader (opens in a new tab)](https://get.adobe.com/reader/)  .

 [Customer Interaction Formal Guidance: Remote operators (July 2019 - no longer in effect)

 application/pdf PDF 371.0 kB](//assets.ctfassets.net/j16ev64qyf6l/joicGBiBnXbw03f7S9HVr/c9f171d593d38d1cbb98eb254b2e4e3c/Customer_Interaction_Formal_Guidance_Remote_operators__July_2019_-_no_longer_in_effect_.pdf) [Next page
 Identifying the right customers](/licensees-and-businesses/guide/page/identifying-the-right-customers)

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 Last updated: 15 September 2022

 Show updates to this content * Information in the callout at the beginning of the guidance has been updated.
* The guidance PDF has also been updated with the same information.


 Applies to:

 All non-remote casino licences

 **Social responsibility code**  Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator-s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.

1. Licensees must have and put into effect policies and procedures designed to prevent underage gambling, and monitor the effectiveness of these.
2. Licensees must ensure that their policies and procedures take account of the structure and layout of their gambling premises.
3. Licensees must designate one or more supervisors for each casino entrance.
4. A supervisor-s responsibilities include ensuring compliance with this section of the code.
5. A supervisor must implement the following procedures:

- checking the age of customers who appear to be, or are suspected of being, underage
- refusing entry to anyone unable to produce an acceptable form of identification, ie one which:
	1. contains a photograph from which the individual can be identified
	2. states the individual-s date of birth
	3. is valid
	4. is legible and shows no signs of tampering or reproduction
- taking action when there are unlawful attempts to enter the premises, including removing anyone who appears to be underage and cannot produce an acceptable form of identification.

- Licensees must not deliberately provide facilities for gambling in such a way as to appeal particularly to children or young people, for example by reflecting or being associated with youth culture.
- In premises restricted to adults, service must be refused in any circumstances where any adult is accompanied by a child or young person.
- Licensees must take all reasonable steps to ensure that all staff understand their responsibilities for preventing underage gambling. This must include appropriate training which must cover all relevant prohibitions against inviting children or young persons to gamble or to enter gambling premises, and the legal requirements on returning stakes and not paying prizes to underage customers.
- Licensees must conduct test purchasing or take part in collective test purchasing programmes as a means of providing reasonable assurance that they have effective policies and procedures to prevent underage gambling, and must provide their test purchase results to the Commission, in such a form or manner as the Commission may from time to time specify.

>  Read additional  [guidance on the information requirements](/guidance/lccp-Information-requirements/guidance-to-operators-on-display-of-licensed-status-other-information-requirements-test-purchase-results)  contained within this section.
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 We welcome sight of novel product or concept developments before they are deployed in the market. We do not approve individual products, and the responsibility rests with operators to ensure that their developments are compliant and will help to deliver the licensing objectives of the Gambling Act. It is recommended that businesses obtain their own legal advice in this regard.

 To assist developers we have provided a broad checklist of items that we expect them to have considered before contacting us. The list is not exhaustive and must not be considered in isolation from the previous advice. It provides a basic list of key issues.

##  In respect of the cashless technology product or system you are developing, you should be able to fully explain:

##  There are also a variety of harm mitigation and consumer empowerment measures that you should consider. You should ask yourself:

 [Previous page
 Licence Conditions and Codes of Practice: cashless payment](/licensees-and-businesses/guide/page/licence-conditions-and-codes-of-practice-in-cashless-payment-technologies)

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 Last updated: 7 June 2021

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* How you will make sure that consumers are required to have a break from gambling before they are able to access and use new funds.
* How you have satisfied yourself that you will be compliant with the Gaming Machine (Circumstances of Use) Regulations in respect of the use of debit or credit cards, payment limits and committed payment limits.
* What anti-money laundering controls you have considered in designing your solution. For example, would a player be able to fund a gambling product via cash and then withdraw funds via an app or digital wallet?


* What information can your product provide to the consumer about their own gambling? For example, will consumers be able to access information on their transactional gambling history over certain periods of time?
* Are you able to provide tools that enable the user to manage their gambling? For example, can the consumer use the product to set limits on the amount of money they are able to deposit or spend over a certain period of time?
* What alerts would be triggered when a limit is reached? How will the limit-setting be made effective in terms of reducing the risk of gambling-related harm?
* Does the product allow for users to voluntarily stop themselves from using the product for gambling purposes for a period of time? Or provide a cooling off period period whereby the product cannot be used for gambling for a certain period of time?
* If the product or system is to be made available for use with different gambling products (including different categories of gaming machine), how will you ensure that your solution is adaptable and able to respond to the different nature of each gambling product and the associated risks or legal requirements?
* Does your solution enable you or a gambling operator to monitor customer behaviour. For example, the gambling spend or intensity of an individual customer) over a period of time?
* How can you prevent, or assist in the prevention of, underage gambling?


Compliance with safer gambling requirements

 See the following pages:

* [Transparency with consumers- do they know who they're participating against?](/licensees-and-businesses/page/customers-knowledge-of-who-they-are-participating-against)
* [Advertising and marketing](/licensees-and-businesses/guide/advertising-marketing-rules-and-regulations)
* [Appropriate licensed environments](/licensees-and-businesses/page/gaming-machines-in-gambling-premises)
* [Cashless payments](/licensees-and-businesses/guide/cashless-payment-technologies-in-gambling-premises)
* [Contribution to research, education and treatment](/licensees-and-businesses/guide/list-of-organisations-for-operator-contributions)
* [The importance of interacting with customers](/licensees-and-businesses/page/the-importance-of-interacting-with-customers)
* [Fair and transparent terms and practices](/licensees-and-businesses/guide/fair-and-transparent-terms-and-practices)
* [Local area risk assessments](/licensees-and-businesses/guide/local-area-risk-assessments)
* [Preventing underage gambling](/licensees-and-businesses/page/prevent-underage-gambling)
* [Self-exclusion](/licensees-and-businesses/page/self-exclusion-in-social-responsibility)
* [Destinations of regulatory settlements to be applied for socially responsible purposes](/licensees-and-businesses/page/regulatory-settlements-applied-for-socially-responsible-purposes)

 [Previous page
 Social responsibility](/licensees-and-businesses/guide/social-responsibility)  [Next page
 Licence conditions and codes of practice (LCCP)](/licensees-and-businesses/guide/page/licence-conditions-and-codes-of-practice-lccp)

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 Last updated: 4 January 2023

 Show updates to this content  'Information to players' removed from list as this webpage has been retired.


 You should comply with the  [Gambling industry code for socially responsible advertising (opens in a new tab)](https://bettingandgamingcouncil.com/members/igrg)  which is administered by the Industry Group for Responsible Gambling (IGRG).

 This code is designed to supplement the CAP and BCAP codes by providing minimum industry standards in a limited number of related areas.

 [Previous page
 Advertising and marketing rules and regulations](/licensees-and-businesses/guide/advertising-marketing-rules-and-regulations)  [Next page
 Gambling and lotteries ads of strong appeal to under 18s](/licensees-and-businesses/guide/page/gambling-ads-of-particular-appeal-to-under-18s)

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 Last updated: 9 August 2021

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Gambling and lotteries ads of strong appeal to under 18s

 The CAP Code requires that marketing communications for gambling must not be likely to be of strong appeal to children or young persons, especially by reflecting or being associated with youth culture, particularly if they are generally available to view by them ('freely accessible'). Read more about  [how the ASA views this type of content (opens in a new tab)](https://www.asa.org.uk/news/particularly-appealing-guidance-for-gambling-operators-not-children.html )  .

 You need to take care with the use of imagery, wording and characters used in marketing communications. Ads must not include a person or character whose example is likely to be followed by those aged under 18 years or who has a strong appeal to those aged under 18, such as sports people and celebrities.

 To support your compliance with the advertising rules, CAP-s guidance,  [Gambling and lotteries advertising: protecting under-18s (opens in a new tab)](https://www.asa.org.uk/resource/protecting-children-and-young-people-gambling-guidance-2022.html)  , was released in April 2022.

 [Previous page
 Gambling industry code for socially responsible advertising](/licensees-and-businesses/guide/page/gambling-industry-code-for-socially-responsible-advertising)  [Next page
 Advertising and sponsorship in sport](/licensees-and-businesses/guide/page/advertising-and-sponsorship-in-sport)

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 Last updated: 10 November 2022

 Show updates to this content  Following an audit the 'Gambling and lotteries advertising: protecting under-18s' link has been updated.


 When agreeing commercial deals with sports clubs, we expect you to ensure that all parties are aware of, and compliant with, the relevant advertising and sponsorship rules and regulations.

 These rules and regulations include:

* provisions contained within  [LCCP](/licensees-and-businesses/lccp/online)
* the UK Advertising Codes
* the Gambling Industry Code for Socially Responsible Advertising
* sport governing body rules.

###  In particular, the following codes should be adhered to

 The UK Advertising Codes contain strict rules on the content, targeting and placement of gambling adverts. For example, licensees should ensure that their brand is not being promoted via the junior sections of clubs- websites.

 The Gambling Industry Code for Socially Responsible Advertising requires that licensees do not allow their logos or other promotional material to appear on any commercial merchandising, (for example replica shirts), which is designed for use by children.

 The European Sponsorship Association and the Football Association require that in the case of teams comprising players all under the age of 18, that gambling logos do not appear on any item of kit or clothing.

 [Previous page
 Gambling and lotteries ads of strong appeal to under 18s](/licensees-and-businesses/guide/page/gambling-ads-of-particular-appeal-to-under-18s)  [Next page
 Young people in marketing material](/licensees-and-businesses/guide/page/young-people-in-marketing-material)

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 Last updated: 28 September 2022

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>  For the purposes of these rules, children are those who are 15 and under, and young persons are people of 16 or 17.
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 As a general rule, marketing communications for gambling must not include a child or a young person. No one who is, or seems to be, under 25 years old may be featured gambling or playing a significant role.

 Individuals who are, or seem to be under 25 years old (18-24 years old) may be featured playing a significant role  **only**  in marketing communications that appear in a place where a bet can be placed directly through a transactional facility; for instance, a gambling operator-s premises or own website.

 In all other instances, including social media, under 25s must not feature.

 CAP has published the outcome of a consultation on a proposal to amend the Gambling section of the CAP Code.  [CAP Gambling Consultation Regulatory Statement: Betting websites featuring individuals under the age of 25 (opens in a new tab)](https://www.asa.org.uk/news/gambling-section-of-cap-code-amended-following-consultation.html )  .

 [Previous page
 Advertising and sponsorship in sport](/licensees-and-businesses/guide/page/advertising-and-sponsorship-in-sport)  [Next page
 Open and transparent marketing](/licensees-and-businesses/guide/page/open-and-transparent-marketing)

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 Last updated: 28 September 2022

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 The following codes are relevant to this section:

 [LCCP: Social responsibility code 5.1.9 (Other marketing requirements)](/licensees-and-businesses/lccp/condition/5-1-9-other-marketing-requirements)  [LCCP: Social responsibility code 5.1.11 (Direct electronic marketing consent)](/licensees-and-businesses/lccp/condition/5-1-11-direct-electronic-marketing-consent)

 You must ensure that your marketing communications do not mislead consumers.

 All significant terms and conditions which are likely to affect a consumer-s understanding of a marketing promotion must be prominently displayed within the advertisement and positioned close to the headline offer on all relevant landing webpages and sign-up webpages (or equivalent) for that promotion, unless the advertisement is so small that it is impossible to do so.

 Significant conditions must be clear, timely, intelligible, unambiguous, non-misleading and transparent. The terms and conditions of each marketing incentive must be made available for the full duration of the promotion.

>  If the significant conditions are not displayed with sufficient prominence, the ad will be seen as misleading.
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 We encourage you to refer to CAP's guidance on  [Gambling ads: free bets and bonuses (opens in a new tab)](https://www.asa.org.uk/news/hedge-your-bets-new-guidance-on-free-bets-and-bonuses.html )  and and to the  [Competition and Markets Authority principles (opens in a new tab)](https://www.gov.uk/government/publications/cma-prioritisation-principles)  to ensure that all significant terms and conditions relating to promotions are presented in an accessible, clear and transparent way.

>  Unless expressly permitted by law consumers must not be contacted with direct electronic marketing without their informed and specific consent.
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 Whenever a consumer is contacted they must be provided with an opportunity to withdraw consent. If consent is withdrawn then you must, as soon as practicable, ensure the consumer is not contacted with electronic marketing unless the consumer consents again, and you must be able to provide evidence which shows that consent.

 LCCP 5.1.11 broadly reflects the relevant requirements of the Privacy and Electronic Communications Regulations (PECR), which are enforced by the Information Commissioner-s Office (ICO). Relevant guidance can be found on the  [ICO-s website (opens in a new tab)](https://ico.org.uk/)  :

* electronic and telephone marketing
* guidance on direct marketing
* direct marketing checklist
* guidance on cookies.

 [Previous page
 Young people in marketing material](/licensees-and-businesses/guide/page/young-people-in-marketing-material)  [Next page
 Responsible placement of digital adverts](/licensees-and-businesses/guide/page/responsible-placement-of-digital-adverts)

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 Last updated: 28 September 2022

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 The following code is relevant to this section:

 [LCCP: Licence condition 16.1.1 (Responsible placement of digital adverts)](/licensees-and-businesses/lccp/condition/16-1-1-responsible-placement-of-digital-adverts)

 You must ensure that you do not place digital advertisements on websites providing unauthorised access to copyrighted content and must take all reasonable steps to ensure that third parties with whom you contract do similar.

 The  [Infringing Website List (IWL) (opens in new tab)](https://www.iabuk.com/policy/infringing-website-list-iwl)  , owned by the City of London Police-s Intellectual Property Crime Unit (PIPCU), is an online portal containing an up-to-date list of copyright infringing sites. The aim of the IWL is that advertisers, agencies and other intermediaries can voluntarily decide to stop advert placement on these illegal websites.

 We'd encourage you to to sign up to access the IWL. For more information and to request access, email:  [PIPCUIWL@cityoflondon.pnn.police.uk](mailto:PIPCUIWL@cityoflondon.pnn.police.uk)

 [Previous page
 Open and transparent marketing](/licensees-and-businesses/guide/page/open-and-transparent-marketing)  [Next page
 Sponsorship of British sporting clubs by gambling operators](/licensees-and-businesses/guide/page/sponsorship-of-british-sporting-clubs-by-gambling-operators)

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 Last updated: 28 September 2022

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Sponsorship of British sporting clubs by gambling operators

 A number of British sports clubs have sponsorship deals with gambling operators. Sports sponsorship falls within the definition of advertising in  [Section 327(2)(a) of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/327)  . Such sponsorship deals must comply with the gambling industry code for socially responsible advertising including with regard to the branding of children-s replica kits.

##  The gambling industry code for socially responsible advertising (the industry code) covers this issue and states at paragraph 33 that:

 [Previous page
 Responsible placement of digital adverts](/licensees-and-businesses/guide/page/responsible-placement-of-digital-adverts)

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 Last updated: 28 September 2022

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The gambling industry code for socially responsible advertising (the industry code) covers this issue and states at paragraph 33 that:

The advertising of adult-only gambling products or product suppliers should never be targeted at children. This applies equally to sponsorship and this code requires that gambling operators will not allow their logos or other promotional material to appear on any commercial merchandising which is designed for use by children.  A clear example of this would be the use of logos on children-s sports shirts which in future would not be permitted under the terms of this code. Children-s shirts and other merchandise will be defined as those that do not attract VAT.


5.1.6 - Compliance with advertising codes

 Applies to:

 All licences, except lottery licences

 **Social responsibility code**  Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator-s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution.

1. All marketing of gambling products and services must be undertaken in a socially responsible manner.
2. In particular, Licensees must comply with the advertising codes of practice issued by the Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP) as applicable. For media not explicitly covered, licensees should have regard to the principles included in these codes of practice as if they were explicitly covered.
3. The restriction on allowing people who are, or seem to be, under 25 years old (ie: those in the 18-24 age bracket) to appear in marketing communications need not be applied in the case of non-remote point of sale advertising material, provided that the images used depict the sporting or other activity that may be gambled on and not the activity of gambling itself and do not breach any other aspect of the advertising codes.


Managing criminal risk - bonus and promotional offers

>  You must have robust ID verification procedures in order to prevent underage gambling, enforce self-exclusions and confirm customers' identities.
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 Verification must be conducted at  [appropriate points in time](/news/article/commission-urges-operators-to-review-when-customer-identity-checks-are-made)  and not simply at point of withdrawal. It should also play a significant role in preventing individual consumers from gambling through third party accounts held in the names of family members, friends or other acquaintances.

 Bonus and promotional offers must only be made available in a manner which is consistent with the licensing objectives, which includes a responsibility to prevent such offers from being exploited criminally for potential financial gain.

 If the industry can-t appropriately manage the criminal risks presented by bonus and promotional offers, we will consider whether regulatory intervention is required. For example, we could consider introducing a condition to restrict the use of bonus and promotional offers which are designed to induce and encourage gambling (via  [section 81 of the Gambling Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/81)  ).

 We have also informed the public of  [checks they can do to stay safe](/public-and-players/page/checks-you-can-do-to-stay-safe)  when opening online gambling accounts.

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 Last updated: 29 April 2021

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