On the back of its latest consultation response, the Gambling Commission (the “Commission”) has announced a number of new rules aimed at increasing the safety and simplicity of consumer promotional offers.

These new rules, which will come into force on 19 December 2025, address mixed product promotions, bonus wagering requirements, and the wording of the Licence Conditions and Codes of Practice (“LCCP”) Social Responsibility (“SR") Code.

Background

On 26 March 2025, the Commission published its latest consultation response in relation to its Autumn 2023 consultation into changes to the LCCP and Remote Gambling and Software Technical Standards.

The response sets out the Commission’s position in relation to socially responsible incentives and the 3 proposals raised by the consultation, namely:

1. An outright ban or limits on the use of wagering requirements;
2. An outright ban on including multiple gambling products within a single incentive; and
3. Changes to SR Code 5.1.1 (Rewards and Bonuses) to make the structure and wording clearer.

Having considered the consultation responses, the Commission has confirmed the changes to be implemented as follows, with each change coming into force on 19 December 2025.

Bonus Wagering Requirements

Promotional offers which are contingent on consumers re-staking winnings multiple times before being allowed to withdraw winnings will now be limited to 10 re-stakes.

In coming to this decision, the Commission noted that capping the wagering requirement to 10 decreases the likelihood of harm, reduces complexity, and improves transparency while maintaining consumer choice.

Interestingly, respondents raised concerns that a ban or low limits on bonus wagering requirements could lead to increased fraud and money laundering issues. However, the Commission considered that the risk here was low.

Instead, the Commission made its decision to cap at 10 rather than implement an outright ban or lower threshold on the basis that (amongst other reasons):

• Customers look for high value promotional offers and there’s a risk that some customers may be pushed to seek higher value offers in the online illegal market were an outright ban or lower limit implemented;
• Small to medium sized gambling licensees find it difficult to compete with licensees with dominant market shares who can afford to give a high volume of generous offers, and limiting the wagering requirements at this level would enable these smaller licensees to remain competitive; and 
• A limit of 10 times will take out extreme levels applied by some licensees at present (there are currently some licensees applying up to 60 times wagering requirements).

Mixed Product Promotions

Promotional offers which provide bonuses on the condition that a consumer plays multiple different products (e.g. betting and playing slots) will be banned once the requirements come into force. This follows the Commission’s earlier decision to require operators to obtain consent to marketing on a channel and product basis, effectively banning the ability to cross-promote products unless the player has actively consented to this.  

Specifically, changes to the LCCP SR Code will prevent Licensees from including more than one type of gambling product within a single incentive.

The Commission based this decision on research which has found that consumers are more at risk of harm when they gamble on multiple products rather than a single product, and also that mixed product promotions confuse consumers due to added complexity in different terms and conditions.

The Commission also provided clarification on the term “incentive” by stating that it covers activities that encourage a person to gamble, covering the range of inducements made available by licensees (also described as promotional offers).

LCCP SR Code 5.1.1

Lastly, the Commission has changed the structure and wording in the LCCP SR Code 5.1.1 (Rewards and Bonuses).

The incoming changes are intended to make this part of the LCCP SR Code clearer and easier to understand.

In its response, the Commission highlighted some of the challenges involved in re-drafting this section. In particular, the Commission noted that the diverse range of incentives available in the market made it challenging to find suitable wording that better reflects what is, or isn’t, acceptable, whilst distinguishing between innocuous and harmful incentives.

Further, the Commission decided not to proceed with a proposed amendment which required licensees to “ensure the design and structure of the incentive does not lead to excessive intensity of gambling which may risk customers experiencing harms associated with gambling”. The reason behind omitting this change was that the wording posed a number of issues, including difficulty in defining the term “excessive intensity”.

Final Comments

The latest changes continue to build on successive policies which have been implemented to tackle gambling related harms, and come shortly after the changes to financial limit tools which come into force on 31 October 2025 were recently confirmed (for more information on these measures, see our article here).

The changes to promotional offers is another compliance matter for operators to consider carefully. Whilst these changes will not be in force long before the end of this year, operators should use that time to assess their current promotional strategy and consider any amendments which may be required to achieve compliance by 19 December 2025. Whilst an outright ban will not be implemented, allowing operators to realise the benefit of using these promotional offers, background work will be required to ensure that systems are capable of aligning with the new wagering limits. 

It is likely that additional consultation responses which are made available between now and the end of this year will require operators to take further steps to achieve compliance, so operators should begin the process to implement the latest raft of changes as soon as possible.