The Gambling Commission has long grappled with the challenge of identifying and supporting high-spending gambling customers who may be facing financial difficulties. To address this, they have developed a four-step pilot program that tests a targeted approach to financial risk assessments without disrupting the customer experience. In this article, we’ll break down these four steps and explain how they could shape the future of responsible gambling.

How the pilot will work

A four-stage plan was initiated by the UKGC (United Kingdom Gambling Commission) in May, with the hope of adopting regulatory changes that will affect ‘remote gaming projects, direct marketing terms and conditions, light touch financial vulnerability checks and more rigorous processes to support age checks on premises’.

Once launched, the project will run for six months to apply soft financial vulnerability checks with an initial limit on customer deposits of £500 per month. Subsequently, the project aims to reduce the deposit limit to £150 per month by 28 February 2025.

This amount will be a mandatory threshold for accessibility checks to be applied by online operators to protect players from significant financial losses.

Ahead of the project's launch, Helen Rhodes, Director of Major Policy Projects and Evaluations at the UKGC, reaffirmed that the aim is to test the feasibility of introducing risk assessments to identify and support high-spending online gambling customers in financial difficulty, with minimal impact on recreational customers.

The project is being carried out with credit agencies and online gambling operators to examine the possible impacts of deposit limits on customers, where ‘assessments are not being implemented in a real environment’.

‘We want to deal with cases where customers were able to bet large amounts without any verification or support, when it was later identified that this caused significant damage,’ Rhodes continued.

To address these challenges, the project will prioritise the identification of high-risk accounts, with the UKGC hoping to test ‘how operators can receive limited information to understand the severity of these financial difficulties in order to take action to support the customer’.

Rhodes added: ‘This would allow operators, in the future, to analyse other indicators of damage and adapt customer support, from reducing marketing, encouraging the use of deposit limits, to interrupting the relationship with the customer. When no financial difficulties are identified, the operator won't need to take any action.’

We are testing how operators can be given limited information to understand how severe these financial difficulties might be, in order to take action to support the customer. This would potentially allow operators in the future to look at other indicators of harm they have and tailor support to the customer ranging from reducing marketing, encouraging the use of deposit limits, right up to ceasing the customer relationship. Where no financial difficulties are identified, the operator would not need to take any action."

At each stage, the Gambling Commission will be testing at least one of the success criteria. They expect each stage will give different results.

The criteria the UKGC will use is as follows:

1. Frictionless part 1

If the assessment were to be applied to the highest spending accounts, what proportion of these accounts could get a financial risk assessment from credit reference agencies? Is this amount in line with the estimates of the 2023 Gambling Act Review White Paper (opens in new tab) which estimated that approximately 80 percent of accounts that undergo a check would be able to do so? Is the ‘unmatched / thin file’ proportion of accounts approximately 20 percent of those accounts that undergo a check?

If the thresholds were set at those proposed in the consultation, this would mean that approximately 3 percent of accounts would be checked. We are testing whether 80 percent or more of that small proportion being checked would be frictionless. Overall, this would mean that the gambling businesses can ensure that the vast majority of accounts could have a frictionless customer journey.

2. Frictionless part 2

How quickly could credit reference agencies process an assessment and return a score or Red, Amber, Green (RAG) rating to gambling operators? Can credit reference agencies return the score or RAG rating to gambling operator within minutes for matched customers? To what extent does latency affect the frictionless process?

3. Data relevance and accuracy

Is using credit reference data meaningful for understanding of an individual customer’s current or imminent overall financial risk and financial vulnerability? How does this data compare to information that is otherwise available to operators about a customer’s individual financial vulnerability? Can Current Account Turnover (CATO) data add additional relevant insights on a customer’s individual financial risk? If so, in what circumstances? Could CATO data in some circumstances negatively impact the accuracy of an overall financial risk assessment? If so, in what circumstances?

4. Implementation issues

• how could the data be presented to operators to help understand the level of financial risk/ vulnerabilities associated with individual customers? 
• how could operators build financial risk assessments into their overall customer interaction processes? 

The pilot will provide insight to help us decide whether to proceed with the implementation of frictionless Financial Risk Assessments and, if so, how.   But these decisions would also be informed by wider considerations of data, evidence, consultation responses and our consumer research.

If financial risk assessments are introduced in the future, we are committed to longer term evaluation which we have discussed in our March blog on this topic. This would enable the Commission and the Department for Culture, Media and Sport (DCMS) jointly to consider if the policy is delivering the intended outcomes for consumers in a live environment.