New remote customer interaction requirements to take effect from the 12th September

In April this year, the Gambling Commission announced changes to the Licence Conditions and Codes of Practice, which aimed to raise standards of customer monitoring, interaction and the identification of customers at risk of harm.

Social Responsibility Code Provision 3.4.3 takes effect on the 12th September and operators should ensure compliance with the new requirements, which can be found here.

The Commission also issued new guidance on customer interaction back in June, which included scenarios, case studies and minimal steps that the Commission would expect to see implemented.

Operators had been expected to fully implement all proposed changes by the 12th September, but following industry feedback concerning technical challenges being faced, the following requirements of new code provision 3.4.3 will be delayed, potentially until February 2023:

• The requirement to take timely action where indicators of vulnerability are identified and to take account of the Commission’s approach to vulnerability as set out in the Commission’s guidance (paragraph 3)
• The requirement to prevent marketing and the take-up of new bonus offers where there are strong indicators of harm (paragraph 10).
• The requirement to take into the account the Commission’s Guidance on customer interaction for remote operators (paragraph 2 and the reference to the guidance in paragraph 1).

The Commission is now looking to conduct a further consultation on the details of the guidance document itself and it will be inviting respondents to provide details of good practice and lessons learned from implementing the requirements.

The new six-week consultation is expected to be launched later this month with a provisional intention to publish revised guidance in December 2022.

Full details can be found here.