Great Britain’s Gambling Commission has published fresh guidance about new rules on promotions, warning operators not to mix two types of gambling within the same offer.
The measure, effectively banning cross-selling promotions between verticals, was announced in March. The measure was planned for December, but an update from the commission has said it would come into effect on 19 January.
An earlier consultation said the new rule would not affect incentives allowing customers to select the product on which to use credits or bonus money on an unrestricted basis. But questions remained unanswered at the time.
Clarification on mixing rules for promotional offers
In a blog post published on 12 December, the GC confirmed both the initial customer activity and reward or prize in the promotion must refer to the same type of gambling. This is unless the offer is to be unrestricted.
In the case of the latter, the GC said: “The important point to note is that the customer must have full freedom of choice in which product category (betting, bingo, casino, lottery) to use their credits or bonus money – it must not be restricted in any way by the operator.”
If, for example, the offer said “spend” £5 on any product to receive a credit or bonus, this would be compliant as it is completely open for the customer.
However, other bonus offers must be specific to one vertical. In no circumstances should there be crossover between verticals. The regulator gave an example of betting money on sports to receive free spins, or spending money on casino games to secure a free sports bet. Both would be deemed to be in breach of the amended regulations.
The commission added that certain offers must be product-specific and not the choice of players. It gave the example of betting £5 on sports to get £10 credit for use on any product.
Gambling Commission bonusing examples
The operator provided the following examples to clarify its position on the new bonusing measure:
| Example of offer | Compliant Yes or No | Rationale |
|---|---|---|
| Bet £5 and get £10 free bet | Yes | This does not mix product types between the initial customer activity and the prize |
| Spend £5 on casino products and get 20 free spins | Yes | This does not mix product types between the initial customer activity and the prize as both are part of the casino category |
| Bet £5 to get 20 free spins | No | This type of offer clearly mixes product types. The offer is inviting the customer to participate in one type of gambling activity (betting), to get a prize from a different product category (casino product spins) |
| Bet £5 and get a £5 free bet and 20 free spins. | No | This type of offer mixes product types. The prize is comprised of mixed products, such as a free bet and casino product spins |
| Bet £5 to get £10 credit or bonus to be used on all products available. | No | The exception allows licensees to offer a bonus where it’s the customer’s choice as to which product category they choose for their reward. Licensees can specify participation in the gambling activity in order to qualify for the prize |
| Spend £10 on any licensed product of your choice and get £5 free bet. | No | While the customer gets a choice on which qualifying activity to participate in (spending £10), the customer does not have a choice of the prize or reward with the operator dictating the product category and limiting this to betting only |
| Spend £10 on any licensed product of your choice and get £10 credit or bonus to spend on your choice. | Yes | This would be compliant because it’s the customer’s choice as to which product category they choose to play, and which prize or reward they choose, and it is not stipulated or limited by the operator |
| Deposit £5 (not linked to participation of a product category) and get £5 credit or bonus of any licensed product | Yes | This would be compliant because it’s the customer’s choice as to which product category they choose to play and which prize or reward they choose, and it is not stipulated or limited by the operator |
| Log on to the app and play and enter the daily free reward game which gives you the opportunity to win £1 free bet, 5 free spins, or £10 cash | No | The new provision applies irrespective of whether a stake on the product category is required or not in order to receive the reward. The prize gives an opportunity to win a range of mixed products which are stipulated by the operator which means this offer would be non-compliant. There is not full or unrestricted consumer choice as to which product they can win as a prize or reward |
| Log on to the app and play and enter the daily free reward game which gives you the opportunity to win £1 free bet, £5 free bet, £10 free bet, £100 cash, or other non-gambling prizes | Yes | The new provision applies irrespective of whether a stake on the product category is required or not to receive the reward. The prize gives an opportunity to win a number of denominations in one licensed product category, so is compliant |
Warning over free-to-play promotional games
The new rule would also limit free-to-play games within operator apps. Licensees will no longer be able to offer free games that allow players to win bonuses across different verticals. Any such bonus would need to be restricted to one product.
“The provision applies irrespective of whether a stake on the product category is required or not in order to receive the reward,” said Pradeep Rajania, senior policy manager at the commission. “The prize gives an opportunity to win a range of mixed products which are stipulated by the operator which means this offer would be non-compliant.
“The important point to note is that the customer must have full freedom of choice in which product category to use their credits or bonus money – it must not be restricted in any way by the operator.”
The new rules on promotions and offers will come into effect on 19 January.