Managing Player Preferences Across Products and Channels

The British rule in brief

The Gambling Commission consulted in 2023 on letting customers control direct marketing by product type and channel. Its response says the requirement "only applies to remote gambling operators" and that "The new requirement will come into force on 1 May 2025."

Code 5.1.12 applies to all remote casino, bingo and betting licenses, with exceptions for ancillary, host, remote betting intermediary (trading room only) and remote general betting (limited) licenses. Its first paragraph reads: "Licensees must provide customers with options to opt-in to direct marketing on a per product and per channel basis." The second says: "Channel options must include phone call, email and text messages (SMS) as applicable." Product options must include betting, casino and bingo, as applicable, and licensees must make clear which of their products sit in each category.

The remaining paragraphs, summarized:

• The options cover all of the licensee's products and channels, start as not opted in, are offered at registration and can be updated at any time.
• Customers must not receive direct marketing that goes against their channel or product preferences.
• Existing customers who had not already opted out had to be asked to confirm their preferences at their first log-in after the code started; matching preferences could be carried over.

The matrix

Example, illustrative only, for an operator offering betting and casino by email and text:

This customer can receive betting emails and nothing else. A casino promotion by email is blocked even though the customer receives emails, because the product does not match.

Classifying messages by product

The hard part in practice is deciding which product a message promotes. A bonus that can be used on both sportsbook and casino games promotes both, so it needs an opt-in for both products on that channel. Agree a written rule, store the product tag on every campaign and have the decision point check it, as described in consent-gated workflows. When choosing a consent tool, check that it stores this matrix; see consent platform test criteria.

Withdrawal still applies everywhere

Code 5.1.11 applies to all licenses and sets the floor: consumers must not be contacted with direct electronic marketing "without their informed and specific consent" unless the law permits it, and "Whenever a consumer is contacted the consumer must be provided with an opportunity to withdraw consent." A product-level opt-out in an email footer should withdraw that product on that channel, and the change should reach every system. Withdrawal and opt-out handling covers the timing.

Ontario for comparison

Ontario has no product-by-channel matrix rule. The AGCO's Standard 2.05 allows inducements, bonuses and credits to be communicated "through direct advertising and marketing, after receiving active player consent", and Standard 2.07 says players "must be provided a method to withdraw their consent at any time". A matrix still works well there, because it records which consents were given.

For the screens that collect these choices, see consent capture and preference center design. For how each cell is stored as events, see the event schema for permission changes.