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The UK Gambling Commission (UKGC) has confirmed that financial risk assessments will be introduced in stages, marking a major change in its regulatory approach after months of debate about proposed affordability checks.

During a meeting announcing the decision and attended by ReadWrite, Acting Chief Executive Sarah Gardner said the regulator wants to identify customers who are spending heavily while facing serious financial problems, without creating the level of disruption that has been associated with existing affordability processes.

“We found evidence that some high-spending gambling customers are experiencing current financial difficulties and they’re not being identified via means that are already open to gambling operators,” Gardner said. “Those 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 had a default in the previous 12 months than comparable consumers.”

The announcement accompanied publication of the commission’s policy confirming that financial risk assessments will replace the earlier affordability check proposal. Instead of judging whether someone can afford to gamble, the new framework is intended to detect signs of significant financial distress, including defaults, arrears and debt management plans.

“The vast majority of gambling customers will never ever require a financial risk assessment.” – Sarah Gardner, UK Gambling Commission Acting CEO

Commission officials repeatedly highlighted that distinction throughout the briefing.

“I do want to pick up on the terminology,” Finance Director Helen Gibson told reporters. “These really are not affordability checks. They do not take account of affordability. They are identifying customers who are in financial difficulties… We want to reassure customers that we’re not accessing deep levels of information about them.”

Highest thresholds limit the initial rollout

One of the biggest changes is the decision to begin with much higher spending thresholds than many in the industry had expected.

Rather than introducing the lower levels discussed during the Gambling Act Review consultation, the first phase will cover only the largest gambling businesses and customers making exceptionally high deposits.

“We want to reassure customers that we’re not accessing deep levels of information about them.” – Helen Gibson, UK Gambling Commission Finance Director

For customers aged 25 and over, an assessment will initially be triggered only when net deposits exceed £5,000 ($6,694) within a rolling 24-hour period. According to the agency, that pattern affects fewer than 0.5% of gambling customers. Separate, lower thresholds will apply to younger adults.

Gardner described the approach as part of a “careful, informed, staged implementation” intended to balance consumer protection with the practical realities of introducing a new system.

The regulator also said it will create implementation groups bringing together gambling operators, credit reference agencies and other stakeholders. Those groups will help refine the process before it is expanded more broadly across the sector.

Most checks can be completed without customer documents

The commission said results from its pilot programme gave it confidence that the new process can operate with minimal disruption for most customers.

According to Gardner, about 97% of customers who exceeded the pilot thresholds could be assessed automatically using credit reference data without being asked to provide documents.

That result was higher than the 80% estimate included in the Government’s 2023 Gambling White Paper.

Gardner also said fewer than 3% of active gambling accounts would ultimately require an assessment. Of those, fewer than one account in every 1,000 could not be assessed automatically, meaning only a very small group might need another verification method such as Open Banking or document requests.

The commission states that it has consistently argued that these assessments will not affect a customer’s credit score. It also says the intention is to replace document requests already used by some operators rather than introduce additional barriers for consumers.

This is reinforced in a Freedom of Information response released by the regulator. It states that financial risk assessments are different from affordability checks and confirms the commission is not considering mandatory Open Banking or automatically preventing customers from gambling because they refuse to share banking information.

Evidence-driven rollout for financial checks over affordability aims to balance protection with practicality

It also announced an unusual temporary enforcement approach during the early stages of implementation.

Gardner said the regulator will not immediately take enforcement action against operators that fail to act solely because of a financial risk assessment result. She described that position as unusual for a regulator but said it should give operators confidence while they develop suitable customer interaction procedures.

Instead of expecting automatic account closures, the commission pointed to a range of proportionate responses. These include reducing marketing communications, encouraging customers to use deposit limits and offering additional support where appropriate. Gardner stressed that operators will still be expected to meet every other regulatory obligation.

The announcement follows months of discussion about the pilot programme. In April, Social Market Foundation senior fellow Dr James Noyes called on Culture Secretary Lisa Nandy to delay implementation until the complete pilot evaluation had been published.

“My support for affordability checks was done on the basis that there would be adequate oversight and evaluation of their efficacy,” he wrote, adding that changing market conditions warranted fresh scrutiny of the policy.

The commission responded by saying it was continuing to analyse pilot findings before reaching a final decision while remaining focused on reducing friction for consumers.

Earlier debate also intensified after financial vulnerability check thresholds were lowered from £500 to £150 in net deposits over a rolling 30-day period during 2025. Research published by the Department of Trust and previously reported by ReadWrite suggested roughly one-quarter of UK gamblers would exceed those lower thresholds, underlining the potential scale of enhanced customer interaction measures. The same analysis found that those customers accounted for almost all gambling deposits despite representing a minority of players.

The latest policy makes clear that financial risk assessments themselves will begin at far higher thresholds and will be introduced gradually rather than all at once.

That approach also reflects comments made last year by Executive Director Tim Miller during the Peers for Gambling Reform Summit.

“We are not going to rely upon gut instinct or belief to measure the success of previous gambling reforms – we will rely upon evidence,” Miller said.

Gibson acknowledged concerns raised by operators about differences between credit reference agencies during the pilot. She said the commission plans to work with both operators and agencies to improve consistency, refine the models and provide clearer information about the severity and timing of customers’ financial difficulties. 

The regulator also declined to publish a fixed timetable, saying implementation will be agreed with industry groups after businesses have prepared their systems.

Featured image: Canva 

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