Financial checks caused no unintended consequences for most operators, Gambling Commission says
The British regulator says only a “very small number” of operators reported challenges in the initial wave of the Financial Vulnerability Checks pilot.
UK.- The British Gambling Commission has provided more details on data gathered from its controversial pilot of financial checks, specifically the lighter Financial Vulnerability Checks. The regulator has reported back after it requested data from online gambling operators on how the checks were being implemented during the first wave of the pilot.
Financial Vulnerability Checks and more detailed Financial Risk Assessments (FRAs) were proposed in the 2023 Gambling White Paper. The former were introduced in August 2024, initially when a customer’s net deposits with a gambling business reached a threshold of £500 over a rolling 30-day period. That threshold was then reduced to £150 in February 2025.
The measure remains in place, and the regulator has stressed that it plans to carry out further research on the impact of checks over a longer period at this lower threshold. The data so far relates to the initial phase of the pilot.
The Gambling Commission says that 68 per cent of operators already had some form of financial vulnerability check in place voluntarily for a number of years ahead of the policy change. A further 26 per cent had introduced them in anticipation of the rule changes.
During the three month period following the introduction of the requirement to conduct financial vulnerability checks at the £500 threshold, operators undertook the checks on 7 per cent of their active customer accounts on average.
Operator feedback on initial Financial Vulnerability Checks
Generally, checks were delivered quickly, with many returned almost instantly, the regulator says: 78 per cent were delivered within 10 minutes and a further 10 per cent within two hours. The majority of operators (63 per cent) delivered checks when a customer hit the threshold, but 36 per cent made checks at earlier points in the customer journey (including at registration and/or first deposit).
The Gambling Commission noted that the threshold level is when operators are required to undertake a financial vulnerability check but operators can choose to do so earlier in the customer journey as a check is valid for six months even when a customer reaches the threshold on multiple occasions.
According to the report, most respondents agreed that the checks provided useful additional information that helped them tailor interactions and monitor customers over time, often prompting earlier engagement with those who are indicated to be at risk and providing insight beyond existing data which helped operators build a more complete picture of customer vulnerability.
Operators highlighted benefits such as a more granular and accurate view of potential vulnerabilities including more information on the scale, age, and relevance of a debt and the ability to cross-check information from different sources to build a clearer picture. The checks also provided information that would not ordinarily be disclosed by customers, which was valuable in coming to a judgement about potential financial vulnerability.
Typically, checks were well integrated into existing processes, the regulator said. Operators reported positive effects, including more proactive customer engagement, earlier intervention, and better quality customer interactions.
Some challenges were noted by a very small number of operators. Some noted customer frustration and/or complaints and concerns about potential displacement to other operators when action was taken once risk flags such as bankruptcy were identified. Some expressed concern about unnecessary friction, particularly where their processes were automated following risk flags being identified by the check. However, most operators did not observe any unintended consequences, the Gambling Commission said.
Implementation lessons for potential financial vulnerability. check rollout
The Gambling Commission concluded that the data request highlighted a few areas where there may be a lack of awareness or clarity regarding how checks are implemented. Some of the responses from operators indicated a lack of knowledge about what is included in a check.
A financial vulnerability. check may only include publicly available information about significant risk flags. That means:
- a bankruptcy order or equivalent
- a County Court Judgment (CCJ)
- an Individual Voluntary Arrangement (IVA)
- High Court Judgment (HCJ)
- an Administrative Order (AO) or decree
- a Debt Relief Order or equivalent.
“Unnecessary friction” from misunderstanding on credit reference data
However, some operators were under the incorrect impression that they were receiving credit reference data as part of a financial vulnerability check. As the sharing of such data is not permitted as part of a financial vulnerability check, this is likely to be a misunderstanding by those completing the data returns, the regulator suggested.
It said it has since met with relevant data providers to discuss misunderstandings and ask them to support continued education of operators and clarity to consumers that only publicly available information is available as part of a financial vulnerability. check.
“Although the number of operators indicating a potential lack of knowledge in this area was relatively small, we think it’s appropriate to promote opportunities for continued education through communications such as this blog, and at industry events, compliance engagement, and through the use of advice or formal guidance to the sector to reiterate these points,” the Gambling Commission said.
It added: “We note that some operator responses indicate that automated responses to a financial vulnerability check in relation to CCJs may lead to unnecessary friction in cases where the risk flag is not severe or there are no other indicators of harm. Operators are reminded that they are not required to offer automated solutions that introduce significant friction – such as putting a stop on a customer account – particularly in cases which relate solely to a single CCJ that may indicate lower levels of risk.
“Where automated solutions are preferred, alternatives might be to to take into account spend levels, to consider automated deposit limits at a level to reduce the risk of significant harm, which could be the ultimate action taken or a temporary measure while manual checks on the level of risk associated with the CCJ are undertaken. Where you are taking action in response to an overall picture of risk, rather than the FVC alone, it would be important to avoid solely attributing your action of the FVC to the customer.”
What’s next for financial checks?
Financial Vulnerability Checks remain in place, and the regulator says the findings show positive indicators that they are seen as an important tool. However, it recognised that this evaluation only assessed feedback on how checks were implemented at the initial £500 threshold. It intends to continue to monitor the impact of checks over time and, both directly and through the NatCen’s wider evaluation of Gambling Act Review measures, at the lower £150 threshold.
Meanwhile, the proposal for more detailed FRAs remains a subject of heated debate, with strong opposition from the gambling and horseracing sectors. Several MPs have also called for the measure to be paused pending a detailed evaluation of a six-month pilot run last year. The Gambling Commission has insisted that no final decision has been made on whether they will be made permanent.
