Compliance
Markers of Harm
Definition
Behavioural and transactional indicators in a customer’s account activity that suggest gambling-related harm, such as escalating deposits, chasing losses, long or late-night sessions, declined payments, cancelled withdrawals and changes in pattern, which operators are required to monitor and act on under customer-interaction rules.
Key takeaways
- Markers of harm are the account-level indicators (deposit escalation, chasing, session length, late-night play, cancelled withdrawals) that signal harmful gambling.
- Customer-interaction rules in Britain and other markets require operators to monitor them, act on them and evaluate the action.
- No single marker is conclusive; operators combine them into risk scores that trigger interactions.
- Enforcement for interaction failures usually turns on markers that were in the data and not acted on.
Why it matters
Regulators moved during the 2020s from telling operators to look after vulnerable customers to telling them how, and markers of harm are the how. Britain's customer interaction requirements, in force from 2022 and tightened since, require operators to monitor a defined set of indicators (spend, time, behaviour, customer-led signals and known vulnerabilities), to act when they are triggered, at earlier stages for younger customers, and to evaluate whether the action worked. Other regulators, in the Netherlands, Sweden, Ontario and Australia, have equivalent requirements framed around the same indicators, and the industry's own codes list them.
The markers are drawn from research into what distinguishes harmful gambling in account data: deposits that rise sharply or hit limits repeatedly, deposits shortly after withdrawals, cancelled withdrawals, play through the night, sessions of unusual length, increasing stake sizes after losses, use of multiple payment methods or declined payments, and customer statements in chat or email. No single marker is conclusive; the requirement is to combine them into a risk score, to interact (a message, a call, a limit, a suspension) when the score demands it, and to record what was done.
For operators this has become a data and operations discipline: models scoring accounts in near real time, teams handling the interactions, and an audit trail the regulator will ask for. Enforcement actions for customer-interaction failures are now among the most common and the largest, and they usually turn on markers that were present in the data and not acted on.
Frequently asked questions
What are the most common markers of harm?
Escalating deposits, deposits soon after withdrawals or cancelled withdrawals, chasing losses with larger stakes, long or overnight sessions, repeated limit hits, declined payments and statements of distress to customer service.
What must an operator do when a marker is triggered?
Interact in a way proportionate to the risk: a safer-gambling message, a call, a suggested or imposed limit, a cooling-off period or account suspension, and then check whether it worked. The interaction must be recorded.
Are markers of harm the same as affordability checks?
No. Affordability checks assess whether spend is affordable against financial information; markers of harm are behavioural signals in the account. Both feed the operator’s customer-interaction process.