‘Financial Risk Assessments’ return to the fore
by Hannah Gannagé-Stewart
In another move that does anything but ingratiate itself with the industry this week, the Gambling Commission of Great Britain has, somewhat loosely, confirmed its next steps in introducing a rebrand on affordability checks.
This comes despite considerable pushback over the last half-decade, as operators have repeatedly raised concerns that such a move relies on inconsistent data and risks alienating punters – potentially pushing them to the black market.
Given the historically divisive and controversial nature of this policy, the regulator has refrained from calling them ‘affordability checks’, opting instead for the considerably more policy-wonkish ‘Financial Risk Assessments (FRA)’. In practice, though, the proposal seeks to flag ‘high-spending’ punters who are at risk of financial difficulties, but aren’t identified by operators’ current harm-prevention monitoring measures.
The new regime will be rolled out in stages, with the largest online operators the first that will be expected to conduct Financial Risk Assessments. The requirement will kick in when a user net deposits £5,000 or more in a rolling 24-hour period, which the GC said will affect less than 0.5% of users.
The regulator said 97% of those spending above the threshold levels will be frictionlessly assessed for financial difficulties, using credit-reference agencies. It estimated that just one in 1,000 accounts would require operators to verify identity more directly through open banking or requesting documents.
The CG confirmed that, during the early stages of implementation, no enforcement action will follow a failure to act following a Financial Risk Assessment, but it emphasised that existing licence requirements must still be met. It is unclear at this stage what an operator might eventually be expected to do when they identify markers of financial risk.
A timetable for the first stage of implementation is to be drawn up in consultation with industry and other stakeholders, the regulator said, with implementation groups being set up over the summer.
In the long term, Financial Risk Assessments will be applied more broadly and to lower deposit limits. For example, customers 25 years or older with net deposits exceeding £1,000 in a rolling 24-hour period or £3,000 over a rolling 90-day period will be picked up in the checks. For those under 25, the thresholds will be reduced to £750 in a rolling 24 hours or £2,000 in a rolling 90 days.
“We are confident that our approach, using high-quality data, will enable support for high-spending customers in financial difficulties, while reducing friction for customers who are not in financial difficulties by removing the need for unnecessary and unpopular document checks to understand financial risk,” the Gambling Commission’s Acting Chief Executive Sarah Gardner said in a statement on Tuesday.
Gambling Minister Baroness Twycross welcomed the move. “The right balance must be struck, so that assessments protect those in financial difficulties from the risk of gambling-related harm but do not create unnecessary burdens for the industry or consumers.”
The industry is naturally unconvinced by the notion that this will be either frictionless or free of ‘unnecessary burdens.’
While consultation is ongoing as to how exactly the FRA will be implemented, there is still a fundamental lack of clarity about whether the checks will be accurate, the level of damage it could do to the viability of businesses, and how operators are supposed to respond to the new data.
“Deeply disappointed and frustrated” was the emphatic response of Betting and Gaming Council Chief Executive Grainne Hurst. “The central issues around reliability, consumer impact, and the practical operation of these checks remain unresolved,” she said.
Hurst went on to raise concerns over the issues that surfaced in the GC’s pilot of the risk assessments, including dodgy data from credit-reference agencies and customers wrongly identified as financially vulnerable.
“We support evidence-led, proportionate regulation that protects vulnerable people, while allowing the 22.5 million adults in Britain who bet each month to do so safely,” she said. “But until the Commission can demonstrate these checks are accurate, consistent, and genuinely frictionless, our fundamental concerns remain, including the risk of driving customers towards the growing illegal gambling market.”
At the moment, Financial Risk Assessments appear to be more of an ongoing experiment by the Gambling Commission than a solidly reasoned policy. Clearly, considerable work remains to be done before either side can be confident this process will boost consumer protection. Meanwhile, the optics are good for the anti-gambling lobby, regardless of whether all the practical questions have been answered.
With three prominent senior roles to fill at the regulator in the coming months, perhaps some fresh perspectives will, in time, smooth out the thorny issue of who can afford to spend what on gambling.
A check by any other name
by Andrew Tottenham
The Gambling Commission has confirmed it will introduce Financial Risk Assessments for higher-spending online customers. After years of consultation, a pilot, and a Board decision that arrived late and slightly out of breath, we have an answer. Whether anyone wanted it is another matter.
Well they did ask. When the Commission put affordability checks to the public, more than 70 per cent of respondents opposed them. It recorded this as “a wide range of views”, a generous description of seven people in ten telling you not to bother. It has since renamed the exercise a Financial Risk Assessment and pressed on. Consultation, in the Commission’s vocabulary, increasingly means announcing a decision and inviting everyone to feel consulted.
The mechanism is simple enough. The largest operators must run a check when a customer deposits £5,000 net over a rolling 24 hours, a level the Commission says fewer than 0.5 per cent of customers reach. The checks are to be “frictionless” and “document-free”, carried out by credit reference agencies, with no effect on the customer’s credit score. So far, so painless.
The trouble starts after the check. The operator is shown a colour, red, amber or green, but not the data behind it, the reasoning that produced it, or the action it is meant to prompt. The Commission says operators should take “appropriate proportionate action … or more where needed”, without ever saying what “more” involves. Guessing at a regulator’s expectations has, in the past, led operators to a large enforcement fine.
Ever practical, the Commission accepts that the same customer can score differently at different credit reference agencies, and differently at the same agency on different days. It has known this for over a year, but seemingly filed it under “useful evidence”, and carried on. Operators must now act, consistently and proportionately, on information the regulator admits is inconsistent. Hold two conflicting ratings for one customer and you cannot know which to obey, though you can be fairly sure that whichever you pick will later be ruled the wrong one.
And then their reassuring words. No enforcement action for failing to act on an assessment during the phased period. Great, but note that all existing licence conditions still apply. Oh dear, it was all going so well?
And the Commission maintains, with an admirably straight face, that none of this is an “affordability check”, a term it has quietly disowned. A £5,000 trigger and a credit agency’s verdict on whether you can keep going is not an affordability check, apparently, in the same way that a duck is not a duck once you decide to call it a heron.
One figure is worth keeping. The light-touch vulnerability checks began at £500 in August 2024 and fell to £150 by February 2025. With this Gambling Commission, thresholds are like introductory offers. £5,000 is where this offer starts, it will be interesting to see where it settles.
More than 70 per cent of respondents said no. The duck remains a duck.
