Where once a small number of high-rollers could sustain operator revenues, their presence has been drastically reduced, regulation has been tightened and their influence has been reduced. New data from the 2024 High Value and VIP Programs Monitoring Executive Summary shows that both membership numbers and revenue levels are far lower than before the reforms.

Five years later, the question now is not “whether the rectification is effective” but “whether the industry can maintain the status quo”.

How VIP programs in the gaming industry will change after 2020

The shift began with a round of regulatory changes in October 2020. The new rules came into effect on October 31, 2020, following a six-month transition period. In consultation with the Betting and Gaming Council, the UKGC introduced mandatory affordability checks, source of funds

 verification and financial vulnerability assessments. Customers under the age of 25 are prohibited from joining the VIP scheme, and operators must appoint a senior manager with a personal management license to oversee all VIP activities.

By placing accountability on individual executives, the reforms aligned personal risk with operational risk for the first time. Since then, the UKGC has expanded its supervisory focus to include a broader review of financial risk and piloted a new accountability mechanism based on VIP supervisory principles.

Membership dropped by 95%, and revenue structure was reshaped

The 2025 monitoring report details the dramatic drop in participation. According to operator survey data in the 2025 executive summary, there were 42,349 VIP customers across 22 operators in 2019–20. By 2023–24, that number had fallen to 1,616 across 18 companies. On a per-operator basis, participation in the VIP scheme fell by 95%, with the average number of VIP customers falling from 1,924.95 to 89.77.

The same trend is seen in Gross Gambling Yield (GGY). Across the 12 operators surveyed, VIP customers now only contribute around 3% of GGY. For the larger online operators with GGY of more than £100 million, this proportion is often even less than 1% (sample size n=5).

However, while traditional options are shrinking, new areas are emerging. Industry observers warn that crypto casinos, skin betting platforms and white label networks are trying to innovate on the fringes of VIP incentive models, and regulation has not yet fully caught up with these changes. They are reaching high-rollers in new ways, but lack the regulatory scrutiny that traditional VIP systems have experienced.

However, while traditional options are shrinking, new areas are emerging. Industry observers warn that crypto casinos, skin betting platforms and white label networks are trying to innovate on the fringes of VIP incentive models, and regulation has not yet fully caught up with these changes. They are reaching high-rollers in new ways, but lack the regulatory scrutiny that traditional VIP systems have experienced.

“ These schemes are no more common today than they are in 2021 ,” said David Taylor, head of evidence assurance and evaluation at the UKGC.

The data suggests the industry has recalibrated, but it remains uncertain whether this stability will last as new incentives emerge.

Land-based casinos still rely on high-value customers

While online operators have significantly scaled back VIP programs, brick-and-mortar casinos still rely heavily on them, with three of the four non-remote venues surveyed saying HVC programs contributed more than 10% of revenue.

This is not a failure of reform, but a reflection of the different business models’ reliance on personalized services and high-roller customers. High-end casinos often serve international visitors, many of whom are high-net-worth individuals with clear risk profiles. These players still enjoy customized services, but are now also subject to stricter regulatory scrutiny.

To reinforce this, the UKGC recently introduced stricter fine guidelines, effective from 10 October 2025, which will more closely link fines to the operator’s GGY to increase the deterrent effect of non-compliance.

Operators turn to more secure VIP management methods

There is no guesswork anymore. Data shows that operators have substantially restructured, rather than merely cosmetically overhauled, VIP programs in the gaming industry. All active programs are overseen by senior executives with personal licenses. Most operators review VIP financial data quarterly, monitor additional risk indicators, and detect behavioral changes through algorithmic triggers.

Customer recruitment methods have also matured. Most companies no longer use agents or introducers to acquire high-value customers. Employee incentives have basically been decoupled from VIP consumption, and only two operators still have non-consumption targets related to membership growth.

Fewer complaints, clearer cases

UKGC’s handling of cases also reflects an overall cultural shift. VIP schemes are now rarely the cause of non-compliance. Consumer complaints have fallen and feedback from third parties has not shown recurring concerns about HVC behaviour.

This is in stark contrast to the industry just a few years ago, when VIP-related errors accounted for 70% of enforcement cases in 2018–19. Today, VIP schemes are more of a background detail than a source of problems.

What regulators are looking at next

The UKGC said that no new policies are needed at present, but the focus is gradually shifting to the next stage. For example, the degree of reliance on physical casinos is still under observation, especially in the context of their unique operating model and the high proportion of HVC revenue.

In addition, broader contextual factors are also emerging. The rise of crypto casinos, the prevalence of skin gambling, and aggressive white label strategies are bringing new risks beyond the traditional VIP structure. These contents will be included in the implementation supervision of the

 Gambling Law White Paper, which is expected to guide the next stage of UK gambling reform.

The importance of this reform and its future direction

The VIP overhaul is more than just a rule change, it is a balance - putting consumer protection above short-term profits. Today's gaming VIP schemes are smaller, slower and safer. The reforms have reshaped the incentive structure and forced a fundamental reboot of the VIP business culture. By 2025, VIP-related issues accounted for less than 0.5% of UKGC enforcement cases, a stark contrast to the pre-reform era.

As new risks emerge, the real test will be whether the industry can maintain restraint and whether the current regulatory framework is flexible enough to meet the challenges. The next stage of the challenge may not be enforcement, but evolution. The UK remains a benchmark for global gambling regulatory reform, and its experience is continuing to reshape the design, regulation and reasonableness of VIP programs.

Key figures and timeline

October 2020

The VIP reforms, which were introduced following consultation with the Betting and Gaming Commission, include mandatory affordability checks, a ban on customers under 25 and a requirement for executives to be held accountable through a personal management licence.

October 31, 2020

The VIP program reform was officially implemented and the six-month transition period ended.

2019–2020 (pre-reform baseline)

GGY from VIP: The exact amount has not been disclosed, but UKGC considers it "quite substantial"

2023–24 annual reporting period

Among large online operators, VIP GGY accounts for usually<1%

Revenue change (2022–2024)

Law enforcement background

Before the reform, 70% of UKGC enforcement cases involved VIP mistakes

By 2025, VIP-related cases will account for<0.5%

Update on penalty mechanism