Gambling Commission consultation: an affordability checks roadmap

While there are important questions still to be answered, the Gambling Commission's response to the public consultations it ran last summer lays out a roadmap in terms of the timing, both for the introduction in Britain of so-called 'light-touch' affordability checks, as well as the pilot scheme for enhanced checks.

The response highlights changes made from the proposals aired in the consultation across several key areas – notably some tweaks to deposit limits and the definition of spend – while the period over which the pilot scheme runs has been made more elastic, raising the prospect of a delayed decision on their eventual implementation.

Tier 1: Financial vulnerability checks

These so-called 'light-touch' checks will initially be introduced at a much higher spend than originally envisaged, with background investigations using publicly available data commencing on August 30.

For six months from that date they will be triggered at £500 of net deposits per 30-day rolling period, with withdrawals from a betting account also being taken into account, a change from the white paper proposals unveiled last April. The cumulative £500 threshold within a 12-month period has been scrapped.

From February 28 2025 the checks will be triggered at £150 per 30-day period, a slight increase from the original proposal of £125.

The Gambling Commission has also repeated its assertion that details such as a customer's postcode and employment will not be considered when firms make an assessment of whether a there is a risk of harm, a measure that featured in the consultation. They will consider bankruptcies, Individual Voluntary Arrangements, and Debt Relief Orders.

Tier 2: Piloting enhanced affordability checks

As with the financial vulnerability checks, the pilot scheme will dispense with the cumulative annual thresholds, and will subtract any amount withdrawn from a customer's account in assessing the spend within a given period.

Surviving after the consultation, thresholds remain £2,000 spend per 90-day rolling period and £1,000 within 24 hours for the purposes of the pilot, a process that will review final thresholds.

So-called 'frictionless' checks will, the Gambling Commission says, negate the need for punters to hand over sensitive financial data

Starting on August 30, the pilot for 'frictionless' tests will be run in three phases, with the first two concerned with the 90-day spend, while tests triggered by the 24-hour limit will be added to the trial in phase three.

As promised when a pilot phase was first mooted, no action will be taken against customers at this stage; the pilot is concerned with data collection and testing the technological solutions which the Gambling Commission believes will negate the need for bettors to hand over sensitive paperwork in "the vast majority of cases."

The commission has allowed itself the option to extend the pilot programme past its designated target date of March 31, 2025 for another month "for practical reasons," although all participants would need to be warned in advance.

During the pilot, three credit reference agencies – Equifax, Experian and TransUnion – will model a betting customer's risk profile using all the information it holds on them, including credit performance data and aggregated current account turnover data (Cato).

They will provide betting operators with a credit score or index, but they will not be able disclose any data which the firms do not already hold, including Cato or salary.

No final decision until 'at least 2025'

The Gambling Commission has pledged to publish "a final and full response" on affordability based on the findings of its pilot. Given the potential for the timeline of the pilot to extend deep into the spring, the commission says that final decision will not be "at least until 2025".

The commission says that concerns raised by respondents to the consultation – including thresholds, which data should be included in affordability checks, and the action which operators can take while an assessment is being made – will remain "under consideration" ahead of its final response.

Read more . . .

Strength of your views on affordability is hidden away under Gambling Commission's diplomatic verbiage 

BHA chief Julie Harrington encouraged by interim gambling code but stresses concern over levy review uncertainty 

Gambling Commission confirms plans for six-month pilot of 'frictionless' affordability checks 

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