On 26 March 2025, the Gambling Commission announced changes aimed at increasing the safety and simplicity of consumer promotional offers. The changes include a mixed product promotion ban and limiting the bonus wagering requirements to 10. Changes will also be made to the Gambling Commission’s Licence Conditions and Codes of Practice (“LCCP”) regarding Social Responsibility Code 5.1.1 (Rewards and Bonuses) to increase clarity as to the Gambling Commission’s current expectations of operators. These changes are part of the consultation response to the Autumn 2023 Consultation and are in line with the commitments within the White Paper.

What are the changes to be expected?

1. Mixed product promotion ban

The new rules ban operators from offering mixed product promotional offers which provide bonuses on the condition the consumer plays different gambling products, such as betting and playing slots. The Gambling Commission highlighted that this ban aims to reduce harm and boost fairness and openness, due to evidence showing consumers are more at risk of harm when they gamble on multiple products rather than a single product. There is also the risk that mixed product promotions confuse consumers because of complex terms and conditions.

In the consultation response, the Gambling Commission clarified that this ban applies to the mixing of products within an individual incentive or promotional offer, where terms are linked and shared.

From 19 December 2025, all gambling operators, except holders of gaming machine technical and software licences, will be banned from offering such mixed product promotional offers.

2. Bonus wagering requirements limited to 10

This new rule will require operators to cap the wagering requirement of promotional offers to 10, in order to decrease the likelihood of harm, reduce complexity, and improve transparency, while maintaining consumer choice. The Gambling Commission highlighted that some promotional offers provide bonus funds to consumers on the condition the consumer re-stakes any winnings multiple times before being allowed to withdraw winnings from the bonus. For example, a £10 bonus with 50 times wagering requirement requires the consumer to play through £500 before the winnings can be withdrawn. As such, high wagering requirements could confuse consumers and lead them to gamble for longer, and faster, than they are used to.

From 19 December 2025, all gambling operators except holders of gaming machine technical and software licences will be required to cap the wagering requirement to 10.

3. Rewording the Rewards and Bonuses section of the LCCP

To ensure increased clarity of the Gambling Commission’s current expectations of operators, the structure and wording of LCCP Social Responsibility Code 5.1.1 (Rewards and Bonuses) will be amended. 

From 19 December 2025, SRCP 5.1.1 will read:

1. The following applies where a licensee makes available to any customer, or potential customer, an incentive or reward scheme or other arrangement under which a customer may receive money, goods, services or any other advantage (including the discharge in whole or in part of any liability of his) (‘the benefit’).

2. Licensees must:
   1. Set out terms and conditions, in relation to an incentive, which are clear, transparent, and fair and readily accessible to any customer or potential customer to whom it is offered.

3. Licensees must not:
   1. Apply wagering requirements, which requires a customer to play through bonus funds, over a maximum of 10 times. A wagering requirement is a where a customer is required to make wagers totalling a particular value for funds to become withdrawable.
   2. Include more than one type of gambling product (betting, casino, bingo, and lottery) within an incentive.
   3. Alter or increase the receipt or the value, or amount of the incentive if the qualifying activity or spend is reached within a shorter time than the whole period over which the benefit is offered.
   4. Construct incentives where, if the benefit comprises of free or subsidised travel or accommodation which encourages the customer’s attendance at a particular licensed premises, it is offered on terms that directly relate to the level of the customer’s prospective gambling.

4. If a licensee makes available an incentive or reward scheme for customers, designated by the licensee as ‘high value, ‘VIP’ or equivalent, it must be offered in a manner which is consistent with the licensing objectives.

5. Licensees must take into account the Commission’s guidance on high value customer incentives.

Tim Miller, Commission Executive Director for research and policy, said:

“These changes will better protect consumers from gambling harm and give consumers much better clarity on, and certainty of, offers before they decide to sign up.”

Next steps

The changes to mixed product promotions, bonus wagering requirements and SRCP 5.1.1 of the LCCP will come into force on 19 December 2025.

Please get in touch with us if you have any questions about these upcoming changes.