UK Gambling Commission Says 2020 VIP Rules Slash Scheme Membership 90% But Vigorously Monitors for Harm

21 September 2026

The UK Gambling Commission has already tightened VIP rules and is still monitoring whether the 2020 reforms are working.

What triggered the reforms:

The Commission’s findings that VIP schemes could encourage gambling-related harm and create conflicts between compliance and commercial incentives triggered the 2020 reforms. The Commission’s consultation identified concern that high-value-customer (HVC) schemes could create a conflict between short-term commercial objectives and regulatory compliance.

What the 2020 rules require:

The 2020 rules require operators to assess affordability, check for evidence of gambling-related harm or heightened vulnerability, keep identity, occupation, and source-of-funds evidence up to date, and conduct ongoing gambling-harm checks before making a customer a VIP.

The new guidance also made a senior executive holding a Personal Management License (PML) accountable for overseeing each VIP scheme.

Evidence of impact:

The reported 90% reduction in VIP-scheme customers and the Commission’s continued monitoring work show 2020's reform's impact. In its monitoring, the Commission found an estimated 90% cut in HVC scheme membership by 2021 compared with pre-reform levels.

The government also stated that the Commission’s stricter VIP rules accounted for 90% of the reduction in the schemes.

Why stricter rules remain under discussion:

Despite the reform’s impact: consecutive concerns remain, including incentives for staff, commercial conflicts, handling self-excluded users, and information review frequency. In its monitoring, the Commission noted ongoing compliance concerns in areas.

Regulatory significance:

The Commission’s broader safer-gambling objective and its licensing requirements explain why the regulator is keeping a close watch on how operators implement the new VIP rules. If a licensee can’t provide effective due diligence, senior oversight, clear accountability, and a culture of responsibility, the regulator says they shouldn’t be running VIP schemes.