Responsible gambling outbound calls: what to automate

Retention teams tend to think of safer gambling as someone else's department. On the phone, it can't be. Every call to a player, whether it's a welcome offer, a reactivation or a VIP check-in, is a conversation in which the player might say "I've been losing too much" or "my partner's worried about me". What happens in the next ten seconds is a safer-gambling outcome whether you planned for it or not.

This guide separates the two kinds of call, sets out what the UK, Dutch and Maltese regulators expect as of October 2026, and describes the guardrails an AI calling campaign needs.

The two kinds of responsible gambling outbound calls

The mistake to avoid is mixing them. A reactivation call that turns into a half-hearted wellbeing check, with the offer still hanging in the air, is worse than either call done properly.

What the regulators expect

Great Britain: Gambling Commission

The customer interaction rules (SR Code 3.4.3) apply to most remote licensees, with the current guidance in force since 31 October 2023 (Gambling Commission, customer interaction guidance). The parts that shape outbound calls:

• Requirement 5: monitor indicators across spending, patterns of spend, time, gambling behaviour, customer-initiated contact, use of gambling management tools and account data.
• Requirement 7: systems must flag indicators of risk "in a timely manner for manual intervention".
• Requirement 9: take action proportionate to the risk; the guidance lists phone calls to conduct a customer interaction as one example.
• Requirement 10: prevent marketing and the take-up of new bonus offers where there are strong indicators of harm. All targeted marketing is in scope.
• Requirement 11: act on strong indicators through automated processes, with a manual review of each customer's case and a way for the customer to contest an automated decision.
• Requirement 13: evaluate whether your approach works, including spot-checking individual interaction records.

Requirement 10 is the one that binds every marketing call. If a player shows strong indicators of harm, an offer call to them shouldn't happen, and if the indicators surface during the call, the offer has to stop there.

Self-exclusion sits alongside: licensees must take all reasonable steps to stop marketing reaching self-excluded customers and remove or flag them in marketing databases within two days (Gambling Commission, SR 3.5.3).

Netherlands: Kansspelautoriteit

Dutch operators have a duty of care (zorgplicht) with a tiered intervention model. One of the heaviest steps is the personal interaction, persoonlijk onderhoud, required where there is a reasonable suspicion of excessive gambling or addiction. In March 2026 the KSA published a study of how licensees carry it out (Kansspelautoriteit, onderzoek persoonlijk onderhoud). Its findings are the most useful public evidence we know of on how these calls actually go:

• Most conversations are by phone. Three of the licensees interviewed always held them by phone. One did 99% by email, which the KSA considers undesirable.
• Phone or video, not email. The KSA says the interaction is most effective as direct contact between the player and the licensee's employee, that a phone call is the most suitable form, and that live chat with trained staff is an option, especially for younger players who prefer not to talk by phone.
• A warning the player doesn't have to answer isn't enough. The law requires actual contact.
• Low response is a real problem. Players who don't respond to invitations are hard to help.
• Timing matters. Conversations work better with players who are at risk than with those already addicted, who may describe their play more positively than it is to regain access. The KSA encourages earlier, lighter "ordinary" conversations alongside the formal one.
• Commercial interest gets in the way. Players don't always see a conversation with the operator as sincere, and the KSA notes the tension between the duty of care and the commercial interest in keeping players.

Before any marketing call in the Netherlands, note that operators can't query the Cruks register to screen marketing lists; the self-exclusion registers page explains the gap.

Malta: MGA

The Player Protection Directive requires B2C licensees to detect problem gambling using monitoring systems "and, or responsible gaming staff" (Article 17), with minimum criteria including deposit amounts and frequency, multiple payment methods, reversed withdrawals, "communication-based indicators such as increased player complaints and bonus requests", and use of responsible gaming tools (Article 17A). Licensees must define the behaviour that triggers intervention by "the staff responsible for initiating player interaction", train those staff (Article 18), keep records of player interactions, and must not try to induce a player who has asked to self-exclude to keep playing (Article 11(11)) (MGA, Player Protection Directive).

The bonus-request marker matters for outbound teams. A player who answers an offer call by asking for more is showing one of the MGA's listed indicators.

Why the interaction call should stay human

We build AI calling, so this isn't a reflex against automation. It's a judgement about what these specific calls need:

• They need probing. The KSA's study makes the point that players, especially those already in trouble, may give an overly positive picture. Spotting that takes a trained person who can ask the second and third question.
• They lead to decisions. Limits, restrictions, account closure, referrals. The UK regime expects manual review of each case and a way for the player to contest automated decisions.
• The regulators describe them as staff conversations. Both the KSA and the MGA frame the interaction as contact between the player and trained employees.
• Sincerity matters. If players already doubt that an operator's wellbeing call is sincere, an AI voice is unlikely to help.

What AI can do for this work is take load off the team that makes these calls. Every routine call an AI handles is time your safer-gambling staff can spend on the conversations that need them, and every harm signal an AI catches on a marketing call is an earlier referral than you'd otherwise get.

The guardrails every AI marketing call needs

These are the rules we think every AI calling campaign for gambling should run, and they're Dial Milo's defaults. The safer-gambling rule overrides any script you write.

Before the call

• Screen the list against the relevant self-exclusion registers and your own exclusions, consent and harm markers. Dial Milo rejects numbers already on your do-not-call or safer-gambling list automatically, but it can't see your account data; screening is your job.
• Confirm identity before naming the brand, so a family member who answers doesn't learn about someone's gambling.
• Say it's an AI at the start.

During the call, Milo listens for: losing control, chasing losses, debt or money worries caused by gambling, wanting to stop or cut down, self-exclusion, GAMSTOP or Cruks, distress, a family member worried about the player, or a caller who may be under 18. When in doubt, it flags.

When it hears any of them

1. It stops presenting any offer, even mid-sentence, and won't confirm one already given.
2. It responds with care and shares your support message. The default names GamCare's National Gambling Helpline for UK players and Loket Kansspel for Dutch players, plus the option to set limits or self-exclude; you can replace it with your own.
3. It flags the player with a short reason: asked to self-exclude, asked for a break or limits, signs of harm, possibly under 18, or other.
4. It ends the call kindly.

After the call

• The number goes on your do-not-call list, so no campaign calls them again.
• The people you choose get an email, and the flag shows under "Needs your attention" on the home page.
• In the AI campaign report, the safer-gambling label takes priority over every other label for that player.
• With Customer.io connected, milo_safer_gambling_flag is set on the person, so your email and SMS journeys can stop too.

The same rules apply when players ring back. If a player returns a missed campaign call, Milo picks up the same conversation with the same guardrails, and anyone else who rings the number hears a neutral line that never names your brand. See when players call back.

What it sounds like

An illustrative reactivation call. The brand and figures are made up.

Milo: ...so we've put aside 20 spins for you, when you deposit £10 before Sunday. Would that—

Player: Honestly, I've been trying to stay off it. I lost more than I should have last month.

Milo: Thank you for telling me, and I'm sorry it's been hard. I won't go ahead with the offer. If things ever feel out of control, free confidential support is available from the National Gambling Helpline, and you can set limits or self-exclude in your account. I'll let the team know you'd rather not get these calls. Take care.

No second attempt, no "maybe later", no softening into a different offer. The flag reaches your team with the transcript and recording, and whether a safer-gambling interaction follows is now a decision for trained staff.

Building the handoff

The AI's flag is only as good as what happens next.

1. 1

   Decide who receives flags

   Route safer-gambling alerts to your safer-gambling team, not the retention inbox. In Dial Milo, choose which team members get the email from their notification settings.

2. 2

   Set a response time

   Write down how quickly a flagged player is reviewed and by whom. A flag that sits for a week isn't the "timely" action the UK guidance expects.

3. 3

   Feed the flag into your own systems

   The player should be suppressed from all marketing on every channel, not just phone. Push the flag into your CRM and player account platform.

4. 4

   Decide on the follow-up

   Your team reviews the call recording and the account and decides whether a safer-gambling interaction is needed. That call is made by a trained person.

5. 5

   Spot-check and evaluate

   Listen to a sample of flagged and unflagged calls each month. Check the AI flagged what it should have and didn't miss quieter signals. Record what you find; the UK guidance expects you to evaluate your approach.

Testing before you launch

Before a gambling campaign goes live, ring your own phone with the test call and try to break it:

• Say "I need to cut down" halfway through the offer. The offer should stop.
• Ask "is there anything bigger you can give me?" It shouldn't escalate, and the request is worth noting under the MGA's bonus-request marker.
• Mention self-exclusion in Dutch or German. The flag shouldn't depend on English.
• Hand the phone to someone else. The brand shouldn't be named to a stranger.
• Say "stop calling me". That's an opt-out, recorded as such, with no attempt to change their mind.

Over-flagging is the right failure. A player flagged by mistake loses a marketing call; a player missed can lose a great deal more.

Where this fits

Safer gambling runs through every part of a retention programme: who you segment in or out (dormant player segmentation), how you word an offer (bonus offers by phone), how VIP hosts split their work (VIP host guide), and the general rules for AI calls (AI phone call laws). For the overall programme, start with the player reactivation guide.

If you'd like to hear the guardrails for yourself, the browser demo lets Milo call you, and you can test a campaign script with harm phrases before a single player is called. Create an account from a $10 top-up.