Gambling Commission to introduce Financial Risk Assessments to operaors in staged approach

A streamlined approach to identifying and supporting high-spending customers in financial difficulties is to be introduced in the UK

The Gambling Commission will introduce Financial Risk Assessments (FRAs) in stages to identify customers in financial difficulties and streamline and improve operator processes.

There is evidence that some high-spending gambling customers are experiencing current financial difficulties but are not being identified or supported by gambling businesses.

High-spending customers are between two and four times more likely to have a debt management plan and between two and five times more likely to have a default in the previous 12 months than consumers in the wider population. Without being identified, they may continue to receive marketing and promotional offers encouraging further gambling despite being financially vulnerable.

Following extensive consultation, engagement with stakeholders and piloting, the Commission has decided on a staged approach to implementation. Financial Risk Assessments will provide operators with a new, more effective and proportionate way of identifying customers in significant financial difficulty, while reducing reliance on the document checks that some operators currently use to seek to identify financial risk and that are unpopular with many consumers.

The vast majority of customers will never require a Financial Risk Assessment, which means people who place an occasional bet, are a recent winning customer or even regularly spends hundreds of pounds would be unlikely to need a check. Those who do will have a frictionless, document-free assessment provided by Credit Reference Agencies, with no impact on their credit score.

The pilot showed that 97 percent of those spending above the threshold levels could be easily and frictionlessly assessed for financial difficulties – significantly higher than the 80 percent estimated in the 2023 White Paper. This means that less than 3 percent of accounts would have an assessment and less than 1 in 1,000 accounts would be unable to get one. For those 1 in a 1,000 accounts, operators will have to verify identity properly and may have to assess financial risk through other means such as open banking or requesting documents.

The first stage of implementation will see Financial Risk Assessments carried out by the largest operators, where there is high spend of multiple thousands of pounds over a 24-hour period. For most, this means £5,000 net deposit in a rolling 24-hour period, which is a very unusually high spend pattern that less than 0.5 percent of customers exceed.

The Commission will continue working with gambling businesses, Credit Reference Agencies and other stakeholders to refine the assessments, develop guidance and support proportionate implementation.

For the small proportion of customers that may require support, we will back operators to take appropriate proportionate action, considering everything they know about the customer and using all options such as reducing marketing to vulnerable consumers, supporting customers to set deposit limits or more where needed.

Importantly, the Commission has also confirmed that, during the early stages of implementation, no enforcement action will be taken on a failure to act following a Financial Risk Assessment, though operators are still subject to all other existing licence requirements which must be met, and in relation to which action may be taken.

The Commission will confirm the timetable for stage one following engagement with industry and other stakeholders through implementation groups being established over the summer.

Once fully implemented in due course, Financial Risk Assessments will be applied to customers aged 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; for those under 25 these thresholds will be reduced to £750 in a rolling 24 hours or £2,000 in a rolling 90 days.

Sarah Gardner, Acting Chief Executive of the Gambling Commission, said: “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.

“We have listened to feedback throughout the pilot process which has led to us deciding to carefully proceed. We will work with key partners to make sure that they are implemented in the most effective way for consumers and operators.”

Gambling Minister Baroness Twycross said: “I welcome the Gambling Commission’s decision to implement financial risk assessments in a careful, phased way. Attention must now turn to successful implementation, so that financial risk assessments work for consumers, gambling operators and the wider ecosystem.

“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.”

Grainne Hurst, CEO of the Betting and Gaming Council, said she was ‘deeply disappointed and frustrated that the Gambling Commission has decided to press ahead with Financial Risk Assessments despite the significant concerns raised over the last 18 months by the BGC, operators, racing, parliamentarians and customers.’

Hurst said: “The fact that the Gambling Commission has delayed implementation, raised thresholds and abandoned its original timetable is a clear recognition that the concerns raised by the BGC and others were well founded. Unfortunately, the central issues around reliability, consumer impact and the practical operation of these checks remain unresolved.

“The Commission has failed to address the fundamental issues identified during its own pilot. It has not demonstrated that the data underpinning these checks is accurate, reliable or consistent enough to support regulatory decisions affecting customers.

“The pilot exposed inconsistencies in the information returned by credit reference agencies, with the same customer potentially receiving different outcomes depending on the provider. Customers risk being wrongly identified as financially vulnerable based on a system that remains unproven. That is not a sound basis for regulatory intervention.

“The Commission has yet to publish a full evaluation of the pilot, so neither the industry nor the public has seen the evidence needed to justify introducing these checks.

“These checks cannot be described as genuinely frictionless if they produce unreliable outcomes, lead to unnecessary account restrictions or ultimately result in customers being asked to provide documents or open banking information.

“While the Commission has announced implementation groups, it has given no indication that they will resolve the outstanding questions around reliability, consumer impact and how the system will operate in practice.

“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. 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.”