To Promo or Two Promos?
A regular client request we receive is to review marketing terms and conditions, promo text and other associated paraphernalia. Usually, it takes us a while to get our heads around the precise requirements of a particular promo or bonus which is normally down to the way the Ts&Cs are worded, laid out, presented or in some other way provided to the reader.
It is therefore no surprise that the British Gambling Commission have just announced their intention to restrict some promo types and terms from December 2025, within their response to the Autumn 2023 consultation. Obviously, promos enjoyed numerous references in the White Paper (35 mentions of the word “promotion”, 69 of the word “bonus” with relatively few positive comments) and the tone of the original consultation document was definitely one of ‘restriction’.
In simple terms, it boils down to “no more than 10x wagering allowed” and “no mixed gambling products within the same promo”.
Both restrictions were somewhat expected although there may be small relief with the 10x limitation vs an all-out ban, which was a possibility. Be grateful for small mercies perhaps.
Cross sell???
From the GC’s own announcement covering the changes, operators will still be able to include different gambling products within the same physical (or electronic) presentation, but they must have separate and unlinked terms. The GC announcement says:-
“We confirm that the aim of this proposal is to ban the mixing of products within an individual incentive or promotional offer, where terms are linked and shared.”
and
“…should a customer opt-in to receiving marketing for betting and casino products, a licensee can send bonus offers for betting, and bonus offers for casino products, within the same email.”
Therefore, “cross sell” will still be possible, sort of, just not as we know it, Jim.
Wagering
Two reasons for choosing the max 10x wagering limitation, and provided by the GC in their response paper, confused us somewhat: -
“Customers look for high value promotional offers and there is a risk that some customers may be pushed to seek higher value offers in the online illegal market…”
“Impact on competition, specifically on small to medium sized gambling licensees finding it difficult to compete with licensees that dominate market share, who can afford to give a high volume of generous offers…”
We’d suggest there is more than “a risk” that “customers may seek higher value offers in the illegal market”. We’d suggest that it’s pretty much guaranteed. And the likelihood that those doing so would be at a higher risk of suffering potential harm from undertaking higher risk activities (as is obviously the case with unlicensed / illegal operations) is also greater, in our opinion.
As for the impact on competition, we don’t understand the assertion that lower wagering supports small to medium sized businesses over the big boys and girls. Lower wagering surely means the customer is more likely play through and realise the winnings which the bigger operations would have a greater ability to absorb. Therefore, smaller operators will be less likely to offer promos.
Are we missing something here?
It will obviously go ahead in December 2025. So, plenty of time for the financially astute to work out the newly required profitability characteristics and the geniuses in Marketing to come up with the (separate) campaigns to present an attractive offer.
Just make sure each gambling product type has its own, unlinked Ts&Cs and no more than 10x wagering……
Written by Andrew Mason
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