UKGC won’t make any changes to VIP and HVC schemes for now
July 19, 2025

UKGC won’t make any changes to VIP and HVC schemes for now

The UK Gambling Commission (UKGC) has published the results of an updated exercise which looks at the ongoing impact of policy change related to VIP or High Value Customer (HVC) schemes.

In a blog post, the UKGC’s Head of Evidence Assurance and Evaluation, David Taylor, detailed that such VIP and HVC schemes were “no more commonplace” in 2024 than they were in 2021 after the regulatory change, which changed how an operator can make a customer a VIP so that they wouldn’t be used to exploit gamblers.

Operators can only make customers VIPs now once they have checked that their spending is affordable and sustainable as part of their leisure spend; assessed if there is evidence of gambling-related harm or heightened risk linked to vulnerability; make sure they have up to date identity, occupation and source of funds evidence; and continue to verify information provided and conduct ongoing gambling harm checks on each individual.

Individuals at operators are also made personally accountable for the scheme’s management via a senior executive who holds a personal management licence. 

In response to the High Value Customer and VIP Scheme Monitoring Report‘s publication, Taylor noted that the report, based on 2024 data, followed a similar process to the report from 2021, so the results can be considered comparable.

However, it was added that the new report “benefits from the addition of further questions and a consideration of whether HVC or ’VIP’ schemes are referenced in Commission casework”.

Land-based casinos

Alongside the fact that the schemes are no more commonplace than they were previously, the number of people in such schemes has remained consistent, with every HVC scheme having a senior executive appointed to oversee operations as well.

The report also found that HVC schemes were “less often assessed as being a contributory factor in issues under investigation within Commission casework”.

The UKGC calculated the proportion of gross gambling yield which is produced by HVC schemes in the sample as being around 3%.

Yet, there was a significant difference between operators and sectors, with land-based casinos having “a greater reliance on scheme members as a proportion of GGY”.

The Commission did acknowledge that staff supervision and interventions can help provide gambling harm support when necessary, and that the vast majority of customers in high-end casinos are high-net-worth individuals based overseas.

Taylor stated: “This factor, in particular, may have led to the difference in GGY proportions compared to other sectors and it’s worth noting that this finding isn’t accompanied with any allegations of consumer harm, but it is something that can be factored into the Commission’s assessment work.”

Outlook

In his closing comments, Taylor noted that while the intended impact of the VIP and HVC scheme changes is being accomplished, it’s important to remember that the exercise was “reasonably modest in scope”. 

“Limitations are detailed in the report and include details about the sample of operators and how this is intended to provide a relatively high-level overview of the policy’s effectiveness. It’s also worth noting that the impact of this policy is also influenced by other changes to regulatory requirements on topics such as customer interaction, for example.”

Taylor concluded that, for now, no additional changes will be made to VIP and HVC schemes, but the UKGC is still ready to step in when required.

“Although evaluation exercises like this will never be able to give total assurance, it does provide an indication that the regulatory objectives have been delivered and further changes are not currently required. 

“Where operators fail to meet requirements, we will continue to take action.”

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