Gambling Commission Clarifies Ban on Cross-Product Bonus Offers
The UK Gambling Commission has specified which mixed-product bonus and reward offers will be banned from January 1 under new LCCP provisions.
LISTEN TO THIS ARTICLE:The regulator has published practical examples to explain a change to the Licence Conditions and Codes of Practice (LCCP), Social Responsibility Code 5.1.1(3b), that prohibits gambling licence holders from tying incentives to more than one product vertical. The rule – effective from January 1 – means operators cannot require customers to play across different categories such as sports betting, casino, bingo or lottery to access a single reward.
Under the clarified guidance, incentives that grant customers a bonus which they may use on any product without restriction remain permissible. For instance, a flat £10 bonus that the player can spend freely across all product types would be allowed, so long as the operator does not limit which categories are selectable. By contrast, offers that condition participation in product X to receive product Y, or that funnel players into a mix of specific products determined by the operator, will be judged non-compliant.
The Commission provided practical examples to illustrate the distinction. A promotion stating "Bet £5 to get a £5 free bet" is compliant because both stake and reward sit in the same vertical (betting). However, an offer such as "Bet £5 and receive 20 free spins" would be prohibited because it links a wagering requirement in one vertical to a prize in another. Similarly, free-to-play in-app games that award prizes redeemable across casino and betting will no longer be permitted; daily prize games must restrict awards to a single product category to meet the Code.
Pradeep Rajania, senior policy manager at the Gambling Commission, said: "The 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. 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."
Related: UK Gambling Commission Lays Out Guidelines for New Levies
What Incentives Will Be Allowed?
The regulator's examples make clear that offers fall into three broad buckets: unrestricted choice incentives, single-category incentives and mixed-product incentives. Unrestricted choice incentives – where a bonus is provided with no operator-imposed limits on how it may be used – will survive the change. Single-category offers that require activity and deliver rewards within the same vertical will also remain lawful. Mixed-product incentives, including cross-vertical prize pools and bundled rewards that steer customers between product types, are the primary targets of the ban.
Operators will need to review common marketing mechanics such as welcome packages, loyalty schemes, daily reward wheels and in-app free-to-play promotions. Any mechanic that effectively mandates play in multiple verticals or ties rewards to participation in a specific alternative product will require redesign or cessation. The Commission has underlined that the mere absence of a monetary stake does not make an incentive compliant: a free daily draw that awards mixed-product access would still breach the Code if the prizes are tied to multiple verticals.
An industry compliance specialist commented: "This change forces operators to think in product-category silos for incentives. From a player-protection perspective, the logic is to reduce cross-selling pressures that may move vulnerable customers into other forms of gambling. Operators will need to update promo terms, CRM flows and app logic to ensure offers are clearly limited to a single vertical or are genuinely unrestricted in use."
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Enforcement and Operator Readiness
The Commission said it will monitor compliance after January 1 and expects licence holders to have updated policies, marketing materials and technical systems ahead of the deadline. Enforcement action for breaches can include formal regulatory steps under the LCCP, and the regulator has indicated it will take a risk-based approach when assessing promotional activity and complaints.
Smaller operators and third-party marketing affiliates face particular implementation challenges, given legacy product integrations and bundled promotion mechanics. The regulator has encouraged firms to seek legal and compliance advice and to document the steps taken to align offers with the new Code so they can demonstrate good-faith compliance if reviewed.
For customers, the change is intended to make promotions more transparent and to preserve consumer choice over how bonuses are spent. For operators, the shift will likely trigger a round of product and marketing redesigns ahead of the new year as the industry adapts to stricter cross-selling boundaries.
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