Glacial progress, substantial problems and no evaluation - why there are huge concerns about the affordability checks pilot

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Following a two-year trial cloaked in mystery and carried out with brief and sporadic updates, the board of the Gambling Commission is widely expected to sign off on the introduction of controversial new affordability checks this week.

It is a prospect which is causing enormous concern in British racing, based on well-founded fears the checks will not work and will cause the sport to suffer a huge loss of revenue, estimated at £250 million over five years.

Since the launch of the pilot on affordability checks, or financial risk assessments (FRAs) as the Gambling Commission has rebranded them, only intermittent updates on progress have been issued.

Gambling operators are unwilling or unable to say anything publicly about the trial. But in recent weeks their trade body, the Betting and Gaming Council (BGC), has made it plain the pilot shows they do not pass the test of being 'frictionless', the all-important measure which ministers have said must be met.

Yet the Gambling Commission appears determined to press ahead with the project, despite every indication it has failed to deliver what was promised. 

Plans for affordability checks were outlined in the last government's gambling review white paper in 2023

Slow progress – and little in the way of communication 

It is more than three years since the last government published its gambling white paper, including plans for affordability checks, which would apply when a bettor hits net spend greater than £1,000 within a rolling 24 hours or £2,000 within 90 days. It was claimed the checks would be 'frictionless' for the vast majority. 

The Gambling Commission ran a consultation during summer 2023 and published its response on May 1 the following year. That set out plans for a pilot of checks, due to launch at the end of August and last for six months. The pilot would test whether punters facing financial difficulties, such as significant arrears, high levels of debt or multiple missed payments, could be identified.

And as part of the test for whether the checks would be frictionless, the pilot would see how quickly credit reference agencies could process an assessment and return a score (or Red, Amber, Green rating) to gambling operators. The pilot would give the commission the information it needed to determine whether to move forward with frictionless financial risk assessments and, if so, how they should be introduced. 

Helen Rhodes, the Gambling Commission's director of major policy projects and evaluation, provided an update in February 2025, after the first of three stages.

She acknowledged issues with the findings presented to operators by the credit agencies, admitting a green rating meant different things to different agencies and that bookmakers needed more help to understand the findings. 

Rhodes provided a further update that May after stage three, and similar problems were surfaced. Ironing those out was to be key to the post-stage three analysis, which would run into the summer. 

But summer, autumn and winter would pass before there was another update from the Gambling Commission.

That came last month, nearly a year after the previous update, following reports that the Gambling Commission was close to agreeing to go ahead with the checks, in the face of massive concerns voiced by the betting industry and racing, which launched a campaign asking the government to pause their introduction.

Rhodes, who claimed much of the commentary about the checks had been "ill-informed", said the pilot had provided encouraging findings, while again acknowledging the practical issues bookmakers raised and concerns about the consistency of the credit agency findings. 

Rhodes said that the commission would "in no way" expect bookmakers to confirm the findings of a financial risk assessment through document checks.

Perhaps more worrying were Gambling Commission executive director Tim Miller's comments at a conference last week, in response to the resignation of key DCMS adviser James Noyes because of what he described as a lack of "meaningful" evaluation of the pilot. 

Miller said: "What I will say is that in terms of evaluation, you can't evaluate something until you have implemented it. You can't properly evaluate something until it has actually been rolled out." 

Those comments were described by professional punter Neil Channing as "clearly ludicrous". He added: "The Gambling Commission can’t mark its own homework as it, no doubt, thinks it’s done a great job. At no point have they listened to punters." 

Unresolved concerns could force punters to supply documents  

The Gambling Commission may not expect bookmakers to use documents to confirm findings, but that is not a view shared by those who will have to deal with affordability checks on the front line. Huge concerns around the results returned by credit reference agencies have not been resolved. 

The issues were detailed in the letter sent by the BGC to the commission last month, seen by the Racing Post. It said that the problems with checks "are substantial and currently incapable of reasonable resolution", describing them as "not fit for purpose".

In the pilot, when a bettor triggered a check, their bookmaker would contact one of the three credit reference agencies (Equifax, Experian and TransUnion), who would match the punter's name against their records and return a score on their financial risk – red, amber or green.

The BGC claimed the pilot demonstrated that a punter could return a 'red' result from one credit reference agency with one bookmaker and a 'green' result from a different credit reference agency from another bookmaker. In only 57 per cent of cases did punters receive the same RAG score from two checks. 

"This creates a serious problem for operators who cannot rely on the score being accurate," said the letter, "and jeopardy for customers, who may be restricted from gambling due to faulty reporting and/or be treated differently by different operators depending on the agency used by that operator".

The pilot also looked at financial data measures (SCOR) developed by an industry body that includes the credit reference agencies. Those covered four areas – current significant arrears, multiple arrears, debt management plans, and defaults over set time periods – and again they threw up the risk of punters being restricted due to differences in reporting. 

According to the BGC, the pilot showed one credit reference agency could identify a risk flag, but the other two might not. The BGC highlighted that if a bettor was subject to debt management arrangements, in 50.2 per cent of cases a risk flag was identified by only one of the three credit reference agencies, with the other two failing to do so. 

Another major stumbling block is the limited nature of the information bookmakers were receiving. They see only a 'yes' or 'no' result, which does not let them know whether a result signifies that a punter has missed a credit card payment or has months' worth of missed mortgage payments. The upshot is that punters may well be asked to supply documents to back up a finding. 

There are also suggestions that bookmakers are unhappy with a lack of guidance over how to deal with 'edge' cases thrown up by the checks, such as when a punter's profile looks good but a risk flag is nonetheless identified. The risk of the Gambling Commission asking why a bookmaker had not intervened, and the punishment which might follow, could effectively render a document check inevitable.

In its letter, the BGC claimed that, based on data from the pilot, five per cent of all bettors (1.2 million) hit the triggers. Of those, 480,000 would return a risk flag and, if all those were asked for documents, that would result in 384,000 refusing to do so, based on previous experience with affordability checks. 

The BGC's letter said it had raised this inconsistency with the Gambling Commission but that the regulator had failed to engage with them.

A decision with huge ramifications  

The Gambling Commission has, however, sought to counter the industry's argument that a considerable number of customers would inevitably be asked for documents in a combative speech from Miller.

He told a conference in Leeds: "If these checks are implemented it will allow us to give clear guidance to operators that they should not require consumers to provide documents to assess financial risk following a financial risk assessment."

Operators, however, remain unconvinced. In response to Miller's speech, BGC chief executive Grainne Hurst said: "If the data cannot be trusted, the system cannot deliver consistent or fair outcomes. In practice, that leaves operators with little choice but to act cautiously, which risks unnecessary restrictions or requests for further information."

Miller has repeatedly said there are no predetermined next steps following the pilot, and that the regulator's board would want to be satisfied there is a "strong evidence base".

The question is whose interpretation of the evidence from the pilot they follow. The decision will have huge ramifications for a beleaguered racing industry and its followers. 

Read these next:

Racecourse MPs slam insufficient scrutiny and lack of transparency as they urge a halt to introduction of 'damaging' affordability checks 

Bookmakers threaten legal challenge to affordability checks that could mean one in five regular punters are asked for financial documents 

Betting expert hits back at 'clearly ludicrous' claim affordability checks can't be assessed until they are implemented 

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