High-Value Customer Schemes: Freeport-to-Cleethorpes, Gaming Commission Urges More Affordability Checks
16 October 2026
by Jane Doe
The UK Gambling Commission continues to scrutinize high-value customer schemes, finding that recent rule changes have significantly reduced their prevalence and are now focusing on broader gambling reform to curb problem gambling.
What the Commission is reviewing
In 2025 the Gambling Commission revealed that changes to high-value customer (HVC) schemes introduced in 2021 had noticeably reduced the prevalence and size of these programs, according to its 2024 data. The body estimated that HVC schemes were responsible for only around 3% of total Gross Gambling Yield in the industry, primarily in land-based casinos.
The Commission's 2025 review comes after the body first introduced robust requirements on VIP and high-value bonuses in 2020, requiring all programs to mandate operators to establish customers' capacity to afford the spending risk involved. The requirements were first introduced following the Commission's review of Holybook's perks system in which the operator reported a reduction of its VIP programs.
During this period, the Commission saw operators introduce financial assessments that raised customer thresholds to £500 net deposits. Any gamer who exceeded these limits would have to pass the operator's affordability check; however, there was no legal requirement for operators to enforce these checks against high rollers.
Why VIP/high-value customer schemes were tightened
The Commission flagged several concerns with the previous approach to high-value customer management. There was limited accountability for oversight of the programs, which could lead to irresponsible promotion of gambling to vulnerable customers.
In response, the Commission introduced a requirement for operators to appoint a senior executive responsible for overseeing HVC scheme operations and ensuring they are run responsibly. This change was part of a broader effort to enhance the regulation of high-stakes gambling.
Additionally, the Commission noted that HVC schemes were less frequently cited as a contributing factor in the casework it investigates. The proportion of cases that mentioned HVC schemes as a contributory factor fell to 7% in 2024, down from 11-12% in earlier years. This suggests that the regulatory changes may be having a positive impact on reducing harm associated with HVC schemes.
However, the Commission also acknowledged challenges in monitoring gambling spending from operator reports. They noted that many operators were inconsistent in the metrics used and provided unclear breakdowns of scheme activity.
What the latest monitoring found
The Commission's 2025 review found that HVC schemes are now "no more commonplace" than they were in 2021, with prevalence and membership reduced by as much as 90%. This suggests that the regulatory changes introduced in recent years have been successful in curbing the growth of these programs.
The review also highlighted the importance of ongoing monitoring and oversight of HVC schemes. The Commission noted that it would continue to assess the effectiveness of the regulatory measures and make any necessary adjustments to ensure that they remain fit for purpose.
However, the Commission acknowledged that more work is needed to improve the reporting and oversight of HVC schemes. It highlighted the need for clearer guidance on spending limits and the information that should be disclosed to customers.
How affordability and financial risk checks fit into the broader reform agenda
The Commission's focus on affordability and financial risk checks is part of a broader gambling reform agenda aimed at protecting vulnerable customers, especially those spending at high levels.
In April 2023, the UK Government published a white paper outlining proposals for reforming high-stakes gambling. The paper proposed introducing financial risk checks for customers who sustain moderate losses, with thresholds set at £125 net loss within a month or £500 within a year. For higher losses, enhanced checks would be required at £1,000 within 24 hours or £2,000 within 90 days.
However, the paper estimated that these enhanced checks would be narrowly targeted and would only affect around 3% of online gambling accounts. This suggests that the Commission's latest review, which found that HVC schemes contribute to 3% of total Gross Gambling Yield, could indicate consistent patterns across the industry.
The white paper also emphasized the importance of customer involvement in financial risk assessment. It proposed that operators should allow customers the option to opt out of enhanced checks if desired.
What operators may have to do next
The Commission's 2025 review suggests that operators may need to make further changes to their high-value customer schemes to comply with regulatory requirements and protect vulnerable customers.
Currently, financial risk assessments are being piloted as "frictionless" assessments using credit reference data to identify high-spending customers who may be financially vulnerable. The Commission has not yet mandated open banking integration or restrictions for customers who decline to share banking details.
However, the Commission's 2025 review indicates that it is likely to continue pushing for more robust affordability and financial risk checks in the future. Operators should therefore ensure they have appropriate systems in place to comply with evolving requirements while supporting their high-value customers.
Why this matters for players, especially higher-spending customers
The Commission's focus on affordability and financial risk checks is good news for players, especially those who spend at high levels. By introducing more rigorous checks and assessments, the Commission aims to protect vulnerable customers from the risks associated with high-stakes gambling.
However, some players may be concerned that these changes could limit their gambling freedom. The Commission has acknowledged this concern and emphasized that the reforms aim to support responsible gambling rather than prevent all high-stakes gambling activity.
The Gambling Commission's 2025 review of high-value customer schemes highlights progress made in recent years to curb these programs and protect vulnerable customers. However, the review also suggests that more work is needed to improve oversight of HVC schemes and implement robust affordability checks.
As the Commission continues its reform efforts, operators must ensure they have systems to comply with requirements while protecting high-value customers. Players should be reassured that these changes aim to support responsible gambling and protect those at risk of harm.
