Licensees are reminded that the changes to Social Responsibility Code Provision (“SRCP”) 5.1.1  came into effect today, 19 January 2026. The changes apply to all licences (including ancillary licences), except gaming machine technical and software licences.

Summary of changes

Further to the Gambling Commission’s Autumn 2023 consultation response, the new promotional rules, as outlined in our previous blog, resulted in three main changes that came into effect today:

1. Mixed product promotion ban.
2. Bonus wagering requirements limited to 10.
3. Rewording SRCP 5.1.1 Rewards and Bonuses section of the Licence Conditions and Codes of Practice to read:

Social Responsibility Code 5.1.1 Rewards and Bonuses

 1.   The following applies where a licensee makes available to any customer, or potential customer, an incentive or reward scheme or other arrangement under which a customer may receive money, goods, services or any other advantage (including the discharge in whole or in part of any liability of his) (‘the benefit’).

 2.  Licensees must:

a.   Set out terms and conditions, in relation to an incentive, which are clear, transparent, and fair and readily accessible to any customer or potential customer to whom it was offered.

3.  Licensees must not:

a.   Apply wagering requirements, which requires a customer to play through bonus funds, over a maximum of 10 times. A wagering requirement is where a customer is required to make wagers totalling a particular value for funds to become withdrawable.

b.   Include more than one type of gambling product (betting, casino, bingo, and lottery) within an incentive.

c.   Alter or increase the receipt or the value, or amount of the incentive if the qualifying activity or spend is reached within a shorter time than the whole period over which the benefit is offered.

d.   Construct incentives where, if the benefit comprises of free or subsidised travel or accommodation which encourages the customer’s attendance at a particular licensed premises, it is offered on terms that directly relate to the level of the customer’s prospective gambling.

Guidance on compliant product promotions

The Gambling Commission’s blog ‘Socially responsible incentives: what operators need to know’ published on 12 December 2025 includes helpful guidance on acceptable forms of product promotions following the Gambling Commission’s ban on mixed product promotions that came into force today. In summary, the following are examples of compliant and non-compliant product promotions:

Examples of compliant promotions

• • Promotions that do not mix product types between the initial customer activity and the prize. For example, ‘Bet £5 and get a £10 free bet’.
  • Promotions where the initial customer activity and the prize are both within the same product category. For example, ‘Spend £5 on casino products and get 20 free spins’.
  • Promotions that are construed in a manner that allows the customer to have full freedom of choice in which product category to use credits or bonus money, for example, ‘Bet £5 to get £10 credit or bonus to be used on all products available’.
  • Promotions that allow the customer the freedom to choose which product category they chose to play and the prize or reward is also not limited to product category. For example, ‘Spend £10 on any licensed product of your choice and get £10 credit or bonus to spend on your choice’, or ‘Deposit £5 (not linked to participation of a product category) and get £5 credit or bonus of any licensed product’.

Examples of non-compliant promotions

• • Promotions that mix product types. For example, ‘Bet £5 to get 20 free spins’. This offer invites the customer to participate in one type of gambling activity, to get a prize from a different product category.
  • Promotions that offer a prizes in respect of different products. For example, ‘Bet £5 and get a £5 free bet and 20 free spins’.
  • Promotions that provide the customer with the choice of initial qualifying activity but specify the product category to which the prize is applicable. For example, ‘Spend £10 on any licensed product of your choice and get £5 free bet’.

Next steps

Licensees are encouraged to review the changes to SRCP 5.1.1 to ensure that all necessary changes are made from today, 19 January 2026. Please get in touch with us if you have any questions about the socially responsible incentives.