UK Gambling Commission Consults on Financial Risk Checks for Online Bettors

The UK Gambling Commission launched a formal public consultation in July 2023 on proposals for financial risk checks for online gambling customers — one of the most significant and controversial elements of the post-White Paper regulatory reform programme. The consultation set out proposals for a tiered system of affordability assessment that would use data from credit reference agencies to identify customers who may be financially vulnerable.

Under the UKGC's proposals, two tiers of checks were outlined:

Frictionless checks — For customers spending above an initial threshold (initially proposed at £125 net losses in 30 days or £500 in a year, though thresholds were subject to consultation), operators would conduct automated checks using credit reference agency data in the background, without requiring customers to submit any documentation. These checks would focus on identifying markers of serious financial difficulty such as County Court Judgments (CCJs), individual voluntary arrangements (IVAs), or bankruptcy.

Enhanced checks — For customers spending above higher thresholds, operators might be required to request specific financial documentation from customers to verify that their spend level was consistent with their income and financial circumstances.

The consultation generated an unusually high volume of public responses, with many bettors objecting to the privacy implications of operators sharing their spending data with credit reference agencies and the potential for legitimate recreational bettors to face intrusive checks. Industry operators broadly supported the frictionless check approach but raised concerns about the impact of friction on legitimate customers and the risk of driving bettors to unlicensed offshore sites.

The UKGC noted that the proposals were intended to complement — not replace — existing customer interaction requirements and were targeted at identifying customers in genuine financial distress, not at restricting recreational gambling activity. The Commission committed to assessing the pilot results from an initial voluntary phase before making the checks mandatory.