Affordability checks explained and how to respond to the Gambling Commission consultation

The UK government finally published its gambling review white paper in April and contained a number of proposals for reform including the introduction of "frictionless" financial checks for online gambling – in other words, affordability checks.

The next stage of the process began on Wednesday with the launch of a 12-week Gambling Commission consultation to examine how these checks will be implemented. The government's plans set out proposals for two tiers of checks.

The first level would test financial vulnerability, "unintrusive" checks conducted when a punter reaches a £125 net loss within a rolling 30-day period, or £500 within a rolling 365-day period. It is estimated this would reach around 20 per cent of customer accounts. The checks would use "publicly available data" and look for issues such as bankruptcy orders or a history of unpaid debts. Such checks would not need to be repeated within a 12-month period.

The second level assesses financial risk using credit reference data which would be triggered by losses greater than £1,000 within a rolling 24 hours or £2,000 within 90 days. The triggers for such enhanced assessments will be lower for those aged 18 to 24. However, when a credit reference agency is unable to provide sufficient information, operators would need to ask customers for data through open banking or providing documentation. At this tier, checks could take place as often as twice a year.

The Gambling Commission consultation provides more detail about the possible implementation of the affordability checks than was contained in the white paper.

This is notably the case in the case of financial risk checks, which would not take into account any winnings outside the previous seven days for the £1,000 trigger, or the last 90 days before the £2,000 trigger, if the proposals in the consultation are implemented. That would mean someone who had £5,000 in their account following a big win a fortnight before the Cheltenham Festival would still have to undergo a check if they lost £1,000 on the first day of the meeting.

How to respond to the Gambling Commission consultation

For those who wish to contribute their opinions to the consultation, here is a step-by-step guide on how to do it and some of the key sections:

>> The consultation can be accessed here.

This page sets out what the Gambling Commission is consulting on this summer, including financial vulnerability and financial risk checks.

At the top and bottom of the page there is a button to take you through to the Gambling Commission's website where you can begin the online survey.

There is a printable version of the consultation below that. The Gambling Commission has asked for responses to be given online but hard copies can be sent to: Policy Team, Gambling Commission, 4th Floor, Victoria Square House, Birmingham, B2 4BP.

>> The next page explains more about the consultation, which closes on October 18, with the document covering six areas of proposals, each with a number of questions.

You need not answer all the questions and can concentrate only on the issue of affordability checks.

You can also save your answers and return to the document later.

At the bottom of the page press continue.

>> The next page is titled 'Introductory Questions', asking for your name, email address, your organisation if relevant, and whether you consent to your name being published by the Gambling Commission to say you have responded to the consultation.

It will also ask you in what capacity you are responding, which includes as a member of the public.

>> Introductory questions continue on the next page, asking you about your gambling habits.

>> The next page sets out what the Gambling Commission is doing. Press continue to take you to the next page which will ask you to select a consultation section.

For affordability checks click on 'Remote gambling: financial vulnerability and financial risk' and then continue.

>> The next page sets out the proposals for affordability checks and why the Gambling Commission is considering them.

The questions begin at question 67. Among them question 68 asks whether you believe you might be subject to financial vulnerability checks, which would be conducted at a £125 net loss within a rolling 30-day period or £500 within a rolling 365-day period.

>> The next page sets out more background to the proposals, followed by a page setting out seven further issues to be explored, including the thresholds for checks, definitions of net loss and the use of data.

You may choose to answer as many or as few questions as you wish.

>> Questions 71 to 75 are among the most important, asking for your opinions on the various thresholds that are being proposed as triggers for the checks.

>> The next section sets out the position on how a net loss is defined and asks respondents for their opinions in questions 76 to 79.

In particular, question 78 allows respondents to comment on the proposals which would mean that winnings before certain thresholds do not count for the calculation of a net loss.

>> Questions 80 to 87 ask for opinions on the data used to carry out financial vulnerability and financial risk checks.

Question 85 allows respondents to give their views on the controversial topic of customers being asked for financial documentation to prove they can afford their level of betting.

>> Questions 91 to 93 cover data protection considerations, with question 93 asking for views on whether the proposals make clear that operators should not use the information they receive for any other purpose.

>> Once you have worked through the questions you wish to answer, there is the opportunity to attach additional information.

>> Once past that stage click on 'finished' to complete the consultation section.

The Racing Post wants to hear from you. What has been your experience of affordability checks since the white paper was published at the end of April, and what do you think of the government's proposals? Have affordability checks affected your betting behaviour?

It's a chance for your voice to be heard. Email the Racing Post at editor@racingpost.com with the subject 'Affordability checks' to share your experiences, your thoughts about the government's proposals, and your contact details.

Read these next:

The Gambling Commission is waging a war on punters, and this is our last chance to fight back 

Punters could face affordability checks every six months under new proposals triggered by white paper 

Tell us about your experience of affordability checks 

The Front Runner is our unmissable email newsletter available exclusively to Members' Club Ultimate subscribers. Chris Cook, a four-time Racing Reporter of the Year award winner, provides his take on the day's biggest stories and tips for the upcoming racing every morning from Monday to Friday. Not a Members' Club Ultimate subscriber? Click here to join today and also receive our Ultimate Daily emails plus our full range of fantastic website and newspaper content.