UK Regulator Draws Line on Cross-Product Gambling Incentives

UK Regulator Draws Line on Cross-Product Gambling Incentives

The British Gambling Commission has issued detailed guidance on a forthcoming change to the rules governing bonuses and rewards, offering operators greater clarity ahead of the January 1 implementation date. The update addresses how incentives may be structured under revised social responsibility provisions, with a particular focus on ending the practice of linking promotions across different types of gambling products.

From the start of the new year, licensed operators will be required to comply with updated provisions within the Licence Conditions and Codes of Practice. At the centre of the change is a restriction on what the regulator refers to as cross-product incentives. In simple terms, a single promotional offer must no longer involve more than one category of gambling activity. Betting, casino games, bingo, and lottery products must each stand alone within the structure of an incentive.

The Commission’s intervention follows years of concern about increasingly complex bonus mechanics, particularly in online environments where multiple gambling verticals are available within the same platform. Promotional offers have often been designed to encourage movement between products, sometimes within a single session. The regulator has now taken the view that these structures can blur boundaries and reduce transparency, especially for customers who may not fully understand how an incentive operates.

Under the revised rules, promotions that keep qualifying activity and rewards within the same category will remain permitted. A betting-related offer that results in a betting-related reward continues to fall within acceptable parameters. The same applies to casino or bingo incentives that do not extend beyond their own product type. The issue, according to the Commission, arises when participation in one category becomes the gateway to another.

The regulator has provided specific examples to illustrate where the line is drawn. An offer that requires a sports bet in return for another betting credit remains compliant. However, a promotion that links a bet to free spins on casino games will no longer be allowed. The distinction is based not on the value of the incentive, but on whether it combines different forms of gambling into a single promotional pathway.

One area where the Commission has sought to avoid confusion is the treatment of bonuses that appear flexible on the surface. Incentives that grant customers a set amount of bonus credit, which can be used freely across the operator’s full range of products, are still permitted. The key condition is that the operator must not restrict or guide the customer’s choice in any way. If the decision on where to use the credit rests entirely with the customer, the incentive remains within the rules.

By contrast, where an incentive is tied to a specific activity, the reward must remain within that same category. The Commission has stressed that operators cannot require engagement with one product to unlock access to another. This applies regardless of whether a stake is involved. Even promotions that do not require customers to wager money are covered by the new provisions.

This point is particularly relevant to free-to-play features and daily reward games, which have become common tools for customer engagement. The regulator has clarified that such games will be considered non-compliant if they offer rewards that span multiple gambling products. A free daily game that gives access to both betting and casino products, even without requiring a stake, would breach the new rules. Only rewards confined to a single category will be allowed.

The Commission’s guidance suggests a deliberate effort to focus on how promotions function in practice rather than how they are presented in marketing terms. Offers that appear optional or chance-based do not escape scrutiny if their outcome introduces cross-product access determined by the operator. The structure of the reward, rather than the language used to promote it, is what determines compliance.

Senior policy manager Pradeep Rajania has emphasised that the revised Code applies consistently across all scenarios. He has stated that the presence or absence of a stake does not change the underlying principle. If a prize leads to participation in different gambling categories selected by the operator, it will fall outside the permitted framework. According to Rajania, genuine freedom of choice is only present when customers are not directed toward specific products through the design of an incentive.

The January changes form part of a broader regulatory trend aimed at simplifying gambling offers and reducing the potential for harm associated with complex promotional mechanics. By limiting incentives to single product categories, the Commission appears to be seeking clearer boundaries between different forms of gambling. This approach places greater responsibility on operators to ensure that promotions are straightforward and transparent.