The UKGC seems as confident as ever in how it has crafted one of the key measures of the UK Gambling Act review, emphasising that financial vulnerability checks are turning out to be as “straightforward as possible”.
Last week, Helen Rhodes, who is the Commission’s current Director of Major Policy Projects, gave a speech which set out a more refined, data-led vision for player safety, including an update on what has been learned from the pilot of financial checks.
In August last year, the UKGC began rolling out what it calls ‘light-touch’ vulnerability checks using publicly available data. These checks were a key measure of the Gambling Act review, seen as a means to protect customers against potentially unsustainable gambling spending.
Initially set at a threshold of £500 in net deposits over a 30-day rolling period, the limit was lowered to £150 from February 2025. These checks were designed to operate with what the UKGC described as “minimal friction”, something betting stakeholders have been adamant is an absolute necessity.
During stage one of the pilot, around 95% of financial vulnerability assessments were completed what the UKGC described as frictionlessly, which then rose to 97% in stage two. These figures exceed the 80% frictionless completion rate estimated in the 2023 Government White Paper.
Black market concerns
The news comes in the midst of industry demands to see greater consistency when it comes to financial risk checks. Concerns that these checks could turn more gamblers towards black market betting if not carried out in a frictionless and simple manner are long-running, dating back to the initial conversation around affordability during the 2020-2023 review of UK gambling regulation.
BGC CEO Grainne Hurst recently explained on SBC’s Safe Bet Show podcast that obstacles such as this wouldn’t see customers stop using the products they like, they’ll just decide to stop using the products they like in the regulated sphere, and they’ll go elsewhere to get those products.
She added: “In the black market, where there’s no regulation, they pay no tax, there’s no player protection whatsoever.”
Meanwhile, the UKGC has previously reiterated that finance risk checks’ should not be considered ‘affordability checks’.
In May, the Commission explained: “Financial risk assessments would be a much more targeted way of identifying potentially financially vulnerable customers. They would not affect a customer’s credit score if they were introduced in the future.”
A turning point?
What sets this new approach apart, Rhodes emphasised, is that it avoids blanket affordability checks. Rather than testing if every punter can afford their spending, the Commission’s model hones in on those who may already be financially at risk.
The goal is not to interfere with the vast majority of players who gamble safely, but to step in early where harm is most likely, the Director asserted.
In stage two of the recent pilot, around 3% of assessments could not be matched, improving on the 5% unmatched rate seen in stage one. Both percentages are significantly lower than the 20% rate without frictionless assessments predicted in the White Paper.
Having now moved into the analysis phase, the Financial Risk Assessments are designed to identify a specific group of customers: those who are not only spending large amounts, but also showing signs of worsening financial distress.
This can include red flags such as multiple arrears, defaults or evidence of bankruptcy.
Continuing her speech, Rhodes said: “The pilot findings represent a significant step forward, and our analysis phase will enable us to further explore how operators could embed assessments into their overall customer interaction approaches and how to reduce unnecessary inconsistency between credit reference agency reports.”
Looking ahead, the Commission is analysing how these financial checks can be embedded more smoothly into the customer journey.
Rhodes was keen to stress that the regulator remains open to industry feedback, mentioning that nearly 1,000 responses were submitted during the consultation.
By anchoring its reforms in financial vulnerability rather than broad affordability, the Commission is signalling a more balanced and targeted approach, making financial vulnerability checks no longer “an afterthought”.
