The UK’s Gambling Commission has reiterated that its affordability solutions will have little to no impact on the vast majority of British bettors amid a wave of criticism.
Affordability checks, as they colloquially are known though the Commission prefers to avoid this term, have stoked a lot of controversy lately, with the Betting and Gaming Council (BGC) even going as far as to say legal action may be necessary to prevent full implementation.
In a speech this week at the Clarion Payments Providers event, Ian Angus, the Commission’s Director of Policy, reasserted that the planned Finance Risk Assessments (FRAs) are “are not affordability checks by another name”.
“Nor do the proposed thresholds for an assessment limit or cap customer spend,” he said.
Commission stands by affordability numbers
The need for some kind of affordable solution for UK gambling was promoted heavily by those calling for legal reform during the 2020-2023 review of the 2005 Gambling Act.
When the review White Paper was published, the notion of FRAs and Financial Vulnerability Checks was put forward – the former being more extensive, while the latter are more ‘light touch’.
The Commission subsequently ran a six month pilot of the checks last year. Critics of this, including politicians from the Conservative Party and Reform UK leader Nigel Farage, argue that this pilot has not cleared anything up.
Angus argues the opposite. In his speech, Angus reiterated the Commission’s long-held belief that ‘less than 3% of active customer accounts’ will trigger any sort of financial check, whether a Vulnerability Check or a Risk Assessment.
Of the 3% that would meet the requirement for an assessment, Angus and the Commission argue that 97% would experience this frictionlessly – it can be assumed via the lighter Vulnerability Checks, implemented when over £150 is deposited over a rolling 30 day period.
“This is far better than what government estimated when they published the White Paper, which was 80%,” Angus said, adding that “only a small proportion of active accounts would require an assessment and be unable to do so in a frictionless manner”.
“The pilot shows it would actually be 0.1%, again, better than the white paper estimated. That’s only one in a 1000 accounts that would be unable to receive an assessment in a frictionless way.
“And even that number could be reduced further, by operators meeting their existing obligations at the start of the consumer relationship to ensure that customers’ details are correct and their identity had been appropriately verified.”
The Commission will be holding a meeting later today to decide which course of action to take on its affordability measure. The Vulnerability Checks have been in effect for some time, introduced at a £500 threshold on 30 August 2024 and at the £150 threshold on 28 February 2025.
FRAs are a different kettle of fish for many, however.
These are the ones that stakeholders in betting and racing are most concerned about, while even some advocates for reform and for some form of affordability solution, like Dr James Noyes of the Social Market Foundation (SMF), believe the measure needs more thought.
Progress on black market battle
A key argument the betting industry, its symbiotic partner in horse racing and its political supporters have been making is that strict affordability checks will drive customers away from the regulated industry and to the unregulated one.
This argument will be familiar to many for a number of reasons. The black market, grey market, and the visibility of unlicensed operators in the Premier League have been regular topics of debate in recent years – Ladbrokes and Coral owner Entain has made the latter a cause celebre in particular.
The black market found itself at the centre of discussions around taxation last year, with the industry making the case that a heavier tax rate would force mitigating measures that would ultimately push customers to unregulated operators with much more liberal offerings.
While the industry was not able to get its point across against tax raises, which came into effect in August, the government did pledge to give the Commission an extra £26m a year in funding specifically to fight the black market.
“The Gambling Commission welcomed the £26m over three years of funding for our efforts to combat illegal gambling and we think this is a sign of support in the effectiveness of the Commission in what we’ve done to tackle illegal gambling in recent years,” Angus said.
Given that the industry fought so bitterly against tax increases last year, stakeholders are probably quite interested in how this £26m is being spent. Angus stated that the Commission intends to grow its focus on illegal gambling “to consider the drivers of consumer demand to the illegal market and how regulation can support innovation”.
The regulator intends to build on the efforts it undertook against illegal gambling last year, which included issuing 741 cease and desist orders to operators and advertise, reporting 397,528 URLs to search engines and securing 266,667 URL removals.
Angus also shared that the Commission has referred 1,068 websites to search engines for delisting and disrupted 1,134 websites “so that they have either been taken down or geo-blocked”.
Regulator welcomes innovation
The Commission has also found itself added to the Department of Culture, Media and Sport’s (DCMS) Illegal Gambling Taskforce, a new body created earlier this year with the sole purpose of disrupting the illegal market.
Despite this, the industry continues to ring alarm bells. The BGC argues that over £16.6bn was staked via offshore companies last year, and the industry has been crying out against what it believes are over-regulation and over-taxation for years now.
Both the Commission and DCMS will have to work hard to ensure that operators are convinced that anti-black market efforts are having the desired effect, especially as the industry continues to ring alarm bells over affordability, taxation, marketing, and everything in between.
Closing off his speech, Angus remarked that “when the illegal market may be ramping up its attack on the licensed sector, we want to make clear our support for innovation when it’s in line with our licensing objectives”.
“If you have ideas to improve the customer experience, make it more positive, make it more competitive, we want to hear them,” he concluded.
“The current statutory and public policy framework does place some limitations on what can be achieved but it doesn’t block innovation out of hand. So if you have ideas that could deliver a better consumer experience, do reach out to us.”
