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

If you, like tens of thousands of other Racing Post readers, regard the very notion of affordability checks as an affront, then the British government's white paper issued in April was a decidedly mixed bag, enshrining the loathsome checks as official policy but at least promising to moderate their impact on ordinary bettors.

Gambling minister Stuart Andrew even appeared in these pages in June to reassure Racing Post readers that the proposals for affordability checks were proportionate, necessary and would have a "minimal" impact on the sport. Most importantly, he stated, most punters would never realise the checks were even happening, echoing the white paper in claiming that they would be "completely frictionless".

Last week we discovered the reality. The Gambling Commission's detailed proposals for affordability checks, published in its consultation document and apparently agreed with the Department for Culture, Media & Sport, reveal a lack of betting knowledge and an unmistakable (though potentially unconscious) contempt for those who choose to bet.

The most charitable thing that may be said for the government is that it might be unaware just how offensive, meddlesome and damaging the Gambling Commission's proposals will be. So let me explain.

There are three deeply objectionable elements to the regulator's new proposals. The first relates to the frequency with which the most intrusive affordability checks, which will be triggered at a spend of £1,000 in 24 hours or £2,000 in 90 days, will be required.

Now redubbed 'enhanced financial risk assessments', these checks will be carried out as often as every six months. The theory here is that financial circumstances change, and so checks must be periodically rerun to ensure gamblers have not fallen into the abyss.

Allow that to sink in. When you purchase a car on credit, does the dealership come round again after six months to check your payslips again? When you take out a mortgage, does the lender demand biannual bank statements to ensure you are not spending beyond your means? And yet to bet – with your own money! – the government proposes you should be subjected to these checks.

It also begs the question of who the Gambling Commission believes this measure will protect. What tiny percentage of a percentage of gambling harm is suffered by those who were sound in June, ruined by December and unable to sensibly adjust their own betting behaviour as a consequence?

It is hard to comprehend that there might be anything more revealing of the regulator's disdain for bettors than this measure, which suggests it believes we are so inevitably prone to life-ruining irresponsibility that only biannual financial audits will suffice, and yet there is worse.

Next is its attitude to winnings, which has been covered extensively already in this newspaper, including by Lee Mottershead on Monday. In brief, the regulator proposes ignoring for the purposes of calculating net loss positions winnings won more than seven days ago for the £1,000 threshold, or 90 days for the £2,000 one.

Explaining this in the consultation document, the commission states "a big win a number of years ago may well not have any bearing on risk now". Then, without any attempt at explanation, it makes the leap to determining the time period in which winnings can be considered winnings should not be years, or 12 months, but one week.

This is yet more evidence the Gambling Commission does not understand betting – the proposals could sound the death knell for exchange betting, with its reliance on high turnover market makers – but its more sinister implication is the further contempt it reveals for gamblers, suggesting that the period in which we can – on balance – just about be trusted not to entirely fritter away a big win is 168 hours.

All the above might almost be acceptable if affordability checks were truly "frictionless", but the consultation admits the truth in its third, and worst, objectionable aspect. To conduct checks, operators will first seek "income and expenditure data, such as current account turnover" from credit reference agencies. 'Current account turnover', or Cato, is an existing data set provided by banks to credit agencies, and as the name suggests offers information about incoming and outgoing sums in your bank account. It is already used by lenders to assess affordability.

For those with a regular income source like a salary this may just offer the fabled "frictionless" experience. But for those without – such as the self-employed, retired, company directors, the independently wealthy and pro punters – a system that ignores savings, investments or irregular income simply will not work. For this vast cohort, it appears there is no route to frictionless checks.

This then is the true form of the government's affordability checks strategy: a bouncer on your own bank account, prying into your financial affairs twice yearly to check you haven’t succumbed to state-proscribed irresponsibility, ignoring anything but the most recent winnings, and for many racing punters leaving no choice to comply but to submit sensitive financial documents to bookmakers.

The glimmer of hope in this dismal picture is that the Gambling Commission's proposals are only that: proposals, put out to public consultation for the next two and a half months. As such, everyone who bets, cares for the future of racing, or believes the rights of the individual to reasonable privacy and freedom are worth protecting must respond to the consultation and make their views clear. It is no exaggeration to say the future of betting as we know it – and the racing industry which relies on it – is at stake.

How to respond to the Gambling Commission consultation: Views can be provided at this page. After completing the introductory questions, select 'Remote gambling: financial vulnerability and financial risk' from the 'Consultations contents page'. You may choose to answer as many or as few questions as you wish. Further Racing Post guidance on responding to the consultation can be found here.

Read these next:

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

No BHA support for 'blanket' affordability measures as checks should reflect interdependency of racing and betting 

'I don't think they truly understand a lot of betting' - concerns raised over Gambling Commission consultation 

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