Industry reaction to Gambling Commission’s “safer and simpler” bonusing measures

During a year of regulatory change for the UK gambling industry that has seen the introduction of a statutory levy, stake limits for online slots, and requirements to prompt players to set deposit limits, the Gambling Commission (GC) yesterday, 26 March, unveiled a new set of safety measures around bonusing for operators to adhere to from late 2025.

One such measure will be banning operators from offering bonuses that apply to more than one vertical, in a potentially damaging move to cross-sell strategies for UK operators.  

Defined by the GC as “mixed product promotional offers”, operators will no longer be able combine verticals like sports betting and casino bonuses into a single offer. For instance, get 10 free spins with your bet on The Grand National.

Regarding this change, a GC statement said: “The evidence shows that these can be problematic because they can lead to consumer confusion and likelihood of experiencing harm.” 

Although operators will only be able to promote offers for one vertical, they will be permitted to include multiple products within a vertical, such as including scratch cards and raffles in a lottery bonus.  

Furthermore, the regulator has introduced a 10x limit on bonus wagering requirements.

This means customers will only have to re-stake their bonus winnings a maximum of 10 times before it can be withdrawn.  

The changes will be applied to the Social Responsibility Code 5.1.1 (Rewards and Bonuses) found within the Licence Conditions and Codes of Practice (LCCP). 

Both changes will come into effect in the UK on 19 December 2025.

EGR spoke to several industry insiders to ascertain the implications the new rules for operators and players, as well as whether this all plays into the hands of the black market.

Melanie Ellis, partner at Northridge Law 

“The cap on wagering requirements, while higher than other options being contemplated (which included a complete ban on wagering requirements), is still significant. It will inevitably reduce the attractiveness of bonuses that can be offered by licensed operators, given the increased likelihood that a customer will be able to complete a 10x wagering requirement.   

“Unlicensed operators will continue to offer bonuses which on the face of it look very attractive, but in the small print customers will find they must complete much higher wagering requirements, with 30x or 50x being fairly typical.   

“For this reason, I believe it will become increasingly challenging for legitimate licensed operators to compete with the black market, particularly when it comes to the smaller or newer brands looking to increase their market share with new customer offers.” 

“It is good news that the GC decided not to proceed with proposed new wording to make it ‘explicit that licensees must 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 GC thankfully realised that it was impossible to accurately define ‘excessive intensity’, taking note of comments in consultation responses that this would have allowed for wide discretion in the interpretation of this rule, on the one hand by operators but also by GC officials when conducting compliance assessments and enforcement activity.” 

Richard Williams, partner at Keystone Law 

“It’s encouraging that the GC has listened to respondents and will not be proceeding with a new licence condition prohibiting incentives that would “lead to excessive intensity” of gambling.  It’s important that licence conditions are clear and unambiguous, and this wording would not have been clear as excessive was not defined.  

LCCP 5.1.1 will be modified in relation to wagering and cross-selling as originally planned. The 10x wagering limit before winnings from play with bonus funds can be withdrawn is sensible from a consumer perspective, as this will provide clarity and will avoid complaints. Some operators have already moved away from imposing wagering requirements on play with bonus funds, and maybe the GC could have gone further.”   

“Operators who have previously relied on high wagering requirements to reduce their financial exposure to bonus offers will now have to think again. Restrictions on cross-selling of gambling products will hit some operators hard, as we will no longer see offers such as the ‘place a £5 bet and get 20 free spins’ promotions, as bonuses must relate to the type of gambling product the offer relates to.   

“This will remove the ability for operators to cross-sell slots to betting customers who wouldn’t normally play slots games. This measure will have a fairly significant impact on operators who use bonuses to migrate customers to other (often more risky) types of gambling. 

“Marketing teams will need to take note. Although there is a nine-month lead in time, in practice it would be sensible to introduce these changes now.”   

Chris Elliot, partner at Wiggin 

“The consultation response was broadly in line with what was expected, though will impose yet further restrictions on operators, and in particular their ability to cross-sell other products (which is of particular importance to some business models).  

“The proposals were opposed as unnecessary and disproportionate by many industry stakeholders, and so the outcome will generally be seen as a blow to the industry, even if not as onerous as they might have been. Marketing teams will need to adapt promotion mechanics to fit the new rules by the deadline of 19 December 2025. 

“The primary driver behind the application of wagering requirements on promotions is to control financial exposure and deter so-called ‘bonus abuse’ by those who seek only to extract value from promotions.”

“The consultation response acknowledges the existence of organised groups who seek to systematically exploit promotions for this reason, and points to this as one reason why a complete ban on wagering requirements (or a cap set at a lower level than 10x) would likely incentivise bonus abuse at even greater scale, which ultimately will have a negative impact on both licensees and genuine customers.  

“The GC essentially points to this as a ‘operator problem’ by reinforcing its expectations that operators should robust KYC checks to prevent this, though there is only so much an operator can do to detect when customers are deliberately circumventing these checks to exploit these bonuses. 

“In concluding 10x as the appropriate cap, the GC appears to accept that more generous promotions will likely be offered by black-market operators, but appears to accept the risk of displacement to the black market as justified by the harm prevention policies these measures seek to pursue.” 

Nick Arron, partner at Poppleston Allen

“The new rules are not as significant as changes regarding opting into and out of marketing, which the GC have already announced, and which come into effect in May 2025.

“The GC didn’t go as far as they could have in respect of wagering requirements – they consulted as far as banning them entirely – so this isn’t the worst-case scenario. With these rules, the GC has most likely found a balance between transparency and fairness for the customer and flexibility for operators on promotions.

“There has always been something uncomfortable about large re-wagering requirements, and at times it felt like the customer was almost being misled.”

“In terms of the impact on operators, their bonuses will be limited, but this is one of the less intrusive changes we’ve seen since the advent of the white paper.

“I also don’t take this as a sign that marketing and promotions will continue to get tougher from here on out. The GC could have gone further, banning wagering altogether, or limiting re-wagering one or five times, but instead have allowed up to 10. Fairer and more transparent terms are generally good for all.”

Martyn Hannah, managing director of Comparasino.com  

“Capping wagering requirements at 10x is a great move by the GC and something that I have been calling for them to do for a while now. For players, this means they will get to keep more of their bonus winnings as they won’t have to complete frankly predatory wagering requirements first. 

“In my experience, most players don’t even understand what wagering requirements are, let alone how they work and how to complete them. This often leads to dissatisfaction when they sign up to a new online casino and claim the welcome bonus. This can see them leave the brand pretty quickly. 

“Of course, without such a high wagering requirement to complete, the player will have a much better experience and likely seem them stick with the casino for longer. 

“The immediate impact on operators might be a little less positive and could see many have to rethink their acquisition bonuses, which will no doubt mean a further reduction in the value of the promotion offered to players. 

“That said, there are some great examples of casinos that have done away with wagering requirements entirely and have built large and loyal player bases as a result – PlayOJO being the obvious example here. 

“Overall, I’d say this is a positive for players and the UK market, but it will likely hit some operators harder than other and may ultimately put even more of a squeeze on margins at a time when the viability of the UK market is being questioned by some.”