The Gambling Commission of Great Britain was somewhat boastful in its latest speech to the industry at iGB Live in London last week.
Gambling Commission Director of Major Policy Projects Helen Rhodes was the keynote speaker on day one of the show (2 July) and used the opportunity to talk up the regulator’s successful implementation of various aspects of the Gambling Act Review.
Possibly recognising that the industry is suffering a level of deep fatigue on this topic, Rhodes was careful to point out that, “in regulatory terms” the numerous changes rolled out by the GC and government over the past year had all happened “in a relatively short period of time”.
Among those changes, she pointed first to improved consumer control over direct marketing opt-ins and the introduction of new technical standards relating to customer-led tools. These include easier ways to set and maintain deposit limits online, which from October 2025 will be reinforced by the requirement for all operators to prompt their customers to set a financial limit before they make their first deposit.
Following a supplementary consultation on promotional offers, from 19 December 2025, the regulator is also introducing a ban on mixed-product promotions, limited bonus-wagering requirements, and changes to the Licence Conditions and Codes of Practice, to clarify the GC’s expectations across promotions.
But chief among Rhodes’s success stories for the year was the oft-controversial financial risk checks. While the bulk of her speech focused on how little friction these pilot checks have caused, the GC is clearly aware of the pushback the idea engendered during the Gambling Reform Review.
“To be clear,” she was at pains to point out, “this is not just another way of saying ‘affordability checks’. We do not have any regulatory requirements for affordability checks and are not proposing any.”
So what are the “light-touch financial vulnerability checks” that the GC has been apparently so successfully carrying out via two pilots this year?
The checks have been conducted using publicly available data since last August. In the first pilot, the checks kicked in at £500 net deposits per 30-day rolling period and then, since 28 February, from £150 net deposits per 30 days. With the pilot complete, she said the regulator had now moved to the analysis phase.
“For those of you who may not be living and breathing this with me,” she said, “the objective of financial risk assessments would be a very targeted way of identifying customers who are both high-spending and in current significant or imminently worsening financial difficulties, by flagging customers who are, for example, in significant or multiple arrears, defaults, or bankruptcy.”
While the reassurance that these were not “affordability checks” will please those concerned that “affordability” is too subjective to apply to every individual gambler fairly, the other major sticking point on financial checks of any sort was the effect they may have on the customer’s user journey. Punters who feel spied on, or even just inconvenienced by financial checks, might swerve the regulated market and revel in their anonymity in the black market, critics pointed out.
Rhodes served up reassurances here too. She said in stage one of the pilot, approximately 95% of assessments were “possible in a frictionless manner”, with this increasing to 97% in stage two.
These figures are undeniably positive if true, but Rhodes also pointed out that they exceed the anticipated 80% frictionless rate predicted in the 2023 White Paper.
“If the proposed thresholds from the Commission’s 2023 consultation were introduced, stage 1 and 2 would suggest that operators would be unable to meet the requirements in a frictionless way for only 0.3% of active accounts or one customer in every 1,000 accounts,” she said. In other words, there’s no excuse, guys.
The pilot also offered some insights into the general risk associated with gambling-customer accounts that would receive an assessment if they were fully introduced.
While the results varied between operators, Rhodes said customers in the pilot cohort were between twice and four times more likely to have a debt-management plan and between twice and five times more likely to have a default in the last 12 months compared with other types of consumers in comparison UK populations.
These figures will prick the ears of the anti-gambling lobby, but it would be interesting to see more in-depth research on that observation to get a clearer picture of the overall financial risk to the gambling population.
The next step for financial risk checks is for the regulator to complete its analysis of the pilots and refine the ways in which operators could embed these assessments into their own customer journeys. Rhodes said the regulator was also looking at ways to reduce unnecessary inconsistency between credit reference agency reports in a bid to make implementation of the checks easier.
