In the fast-paced world of the gambling industry, keeping up with regulatory changes is essential for both operators and players. One such pivotal amendment is the revised Formal Guidance under SR Code 3.4.3 by the Gambling Commission (GC) which replaces all earlier versions of guidance issued for remote gambling operators. Let’s take a closer look into its evolution, main requirements, and the overarching trend of social responsibility.

A Timeline of SR Code 3.4.3

  • July 2019: The Commission released its remote customer interaction Guidance in July, which became effective in October 2019. In May 2020, further guidance was issued due to COVID-19, both ceased to be in force on 11 September 2022.
  • January 2021: In response to feedback, the Commission released a short survey on customer interaction and affordability as aspects of ‘harm.’
  • June 2022: Alongside the SR Code, the UKGC released comprehensive guidance, set to launch in September, but the timeframe for the consultation was extended.
  • August 2023: After the January consultation, the Commission’s updated remote customer interaction guidance was scheduled for enforcement on 31 October 2023.

SR Code 3.4.3 Guidance: The Core

The revised SR Code 3.4.3 reflects the Commission’s commitment to enhancing player protection while balancing the operational needs of remote operators. To maintain transparency and compliance, operators are expected to demonstrate to the Commission how the Guidance has been implemented into their overall customer interaction systems and processes.

Central to this guidance is the transition from an observational stance to a proactive one. The Commission’s shift from “interaction” to “action” signifies an increased emphasis on operators to actively intervene when customers display potential harm signs. Consequently, operators have a heightened responsibility to identify, act upon, and evaluate signs of gambling-related harm, underlining the Commission’s unwavering focus on player well-being. Specifically:

  • Requirement 1 & 2: Introduces foundational protocols for remote gambling operators to continuously analyse customer behaviours, detect potential harm, and fine-tune their approaches to risk assessment and intervention. Operators must implement effective customer interaction systems that embed the three elements of customer interaction to comply with the Guidance: namely, to identify, act and evaluate.
  • Requirement 3: Licensees must prioritise protecting vulnerable customers. Operators need to effectively assess available information, recognise signs of vulnerability, and act swiftly.
  • Requirement 4 & 5: From account creation, operators must monitor customer activity for potential harm. This includes assessing various indicators holistically, with both automated and manual real-time monitoring.
  • Requirement 6: Operators must track customer activity for harm indicators, even when collaborating with third-party B2B providers, stressing continuous oversight.
  • Requirement 7: Emphasises immediate response to harm markers, endorsing automation followed by manual review for fairness.
  • Requirement 8: Directs Operators to adjust their actions based on harm severity.
  • Requirement 9: Mandates licensees to adapt their responses based on the observed indicators of harm in customers, ranging from encouraging the use of management tools and limiting product visibility to terminating service in persistent cases. The objective is to ensure actions are proportionate to the level of potential harm, aiming to minimise risks and guide customers towards safer gambling behaviours.
  • Requirement 10: Operators must cease marketing and promotions when strong indicators of harm are detected.
  • Requirement 11: Customers can now understand and challenge automated procedures. Challenges would prompt a manual review of decisions.
  • Requirement 12 & 13: Operators are expected to evaluate and enhance their customer interactions, pushing for system upgrades for detailed assessments.
  • Requirement 14: Operators should incorporate recent problem gambling rates as published by the Commission into their protection strategies.

The Rising Tide of Social Responsibility:

The SR Code 3.4.3 is part of a bigger shift in the industry towards increased social responsibility. The GC is regularly updating and consulting to ensure they prioritise player welfare over making profits. At the same time, they recognise that their view on the potential harms of gambling is always evolving, so they’re committed to improving their guidance as they gain more insights. This change means companies are expected to do more to prevent gambling issues. In essence, SR Code 3.4.3 is more than just guidelines; it shows the GC and the industry’s commitment to a balance between business and player protection.

Customer Interaction Training:

Finally, in light of the evolving regulatory landscape, we have updated our Customer Interaction training which has been tailored specifically to the newly issued guidance. This comprehensive training is instrumental in navigating the updated protocols and requirements, so to get a more detailed overview and essential insights into the course, please click here or reach out to us at

Author: Ioanna Meletiadou, Compliance Research Manager

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