The Gambling Commission has issued further explanation on how new limits on gambling incentives will be enforced, as operators prepare for changes due to take effect in January. The updated guidance focuses on preventing promotional offers that link different gambling products within a single incentive, a practice the regulator has moved to prohibit under revised Licence Conditions and Codes of Practice.
The changes form part of a wider update to the Social Responsibility Code and were confirmed earlier this year. While the core rule has remained unchanged, the Commission has now published additional clarification intended to address uncertainty around how certain offers, including free-to-play features and credit-based bonuses, should be structured.
Implementation timeline and regulatory intent
According to the Commission, the new provisions will come into force on 19 January. From that date, licensees must ensure that incentives do not include more than one type of gambling product within the same offer. This applies across betting, casino, bingo, and lottery products, including promotions where qualifying conditions and rewards are linked or shared.
The regulator has stressed that the restriction is designed to apply broadly. Promotional structures covered by the rule include free bets, free spins, sign-up offers, and daily reward mechanics. It also applies regardless of whether a customer is required to place a wager or simply complete a non-gambling activity, such as logging into an app.
By setting out more detailed explanations ahead of implementation, the Commission aims to ensure that operators understand how the rule will be interpreted in practice and avoid designing incentives that fail to meet the updated standard.
Matching qualifying activity and reward
Central to the new requirement is the relationship between the action required of the customer and the reward they receive. The Commission has confirmed that when an incentive requires participation in a specific gambling category, the reward must fall within that same category.
Offers that remain within a single product type are considered compliant. For example, betting activity that results in a betting-related reward, or casino play that unlocks casino-based benefits, does not raise regulatory concerns under the revised code.
Problems arise when promotions cross product boundaries. An incentive that asks customers to place sports bets in order to receive free spins, or to play casino games to unlock a free bet, would breach the rules. The Commission has stated that incentives structured in this way mix product types and are therefore not permitted.
This approach also applies where rewards themselves combine multiple products within one offer. Where a prize consists of more than one gambling category, the incentive will not comply with the new provisions.
Unrestricted choice and credit-based bonuses
The Commission has acknowledged an exception for incentives that provide customers with genuine freedom of choice. Where bonus money or credits can be used across all licensed product categories on an unrestricted basis, the ban on mixing products does not apply.
In such cases, customers must be able to decide independently which product category they wish to use their reward on. As the regulator explained: “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.”
While operators may require participation in a specific gambling activity to qualify for the reward, they must not limit how the bonus can be redeemed. If the operator dictates the product category for the reward, the incentive will fall outside the permitted exception.
The Commission has also noted that where certain games are excluded within a product category, those exclusions must be clearly stated and easy for customers to find within the terms and conditions.
Free-to-play games and app-based rewards
The guidance also addresses free-to-play reward games offered within gambling apps. Under the updated rules, licensees will no longer be able to operate free games that offer prizes spanning multiple gambling categories.
Senior policy manager Pradeep Rajania addressed this point directly, stating: “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.”
He also reiterated the importance of customer autonomy when bonus credits are offered, adding: “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.”
Daily reward games that limit prizes to a single product category remain acceptable under the revised code.
The Commission has emphasised that it will not provide advance approval for specific incentives and that operators should assess their promotions carefully ahead of January. The examples published alongside the guidance are intended to support compliance but do not represent an exhaustive list.
Source:
Socially responsible incentives: what operators need to know, gamblingcommission.gov.uk, 12. December 2025
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