UK Gambling Commission Strengthens Customer Interaction Requirements for Licensed Operators

The UK Gambling Commission updated its customer interaction requirements for licensed operators during 2023, increasing expectations for operators to identify and respond to customers at risk of gambling harm at an earlier stage than previously required.

The UKGC's updated guidance set out that operators must use available data — including account activity patterns, betting behaviour, and any direct customer communications — to identify customers showing indicators associated with gambling harm. These indicators include sustained losses over time, increased deposit frequency, unsuccessful attempts to set limits or close accounts, and patterns of play characteristic of problem gambling, including chasing losses and extended unbroken sessions.

The updated requirements placed greater emphasis on operators taking proportionate action when at-risk indicators are identified, rather than waiting for customers to self-identify as having a problem. The UKGC made clear that operators who could not demonstrate a documented, data-driven, and consistently applied customer interaction programme would face the risk of licence review and enforcement action.

The updated guidance followed a series of high-profile enforcement cases in which the UKGC imposed significant financial penalties — totalling hundreds of millions of pounds across multiple operators in 2022 and 2023 — for failures in customer interaction, anti-money laundering controls, and responsible gambling practices. The enforcement record demonstrated the UKGC's willingness to use its full regulatory toolkit against operators with inadequate player protection frameworks.

The updated customer interaction requirements form part of the broader regulatory reform programme running in parallel with the Government's Gambling Act Review, which published its White Paper proposals in April 2023.