Financial Risk Assessments would increase World Cup betting on black market, BGC warns
The BGC believes FRAs would see the UK gambling sector lose an additional £50m in World Cup bets to the black market.
UK.- With FIFA World Cup 2026 underway, The Betting and Gaming Council (BGC), the UK gambling sector lobby group, has reiterated its warnings over the size of the country’s gambling black market. It reckons that unlicensed operators could take around £200m in bets on this year’s tournament, although it didn’t specify how it arrived at this estimate. It says the implementation of Financial Risk Assessments would have made this figure even higher.
The group forecasts that one third of all British betting account holders will place a bet on the World Cup and that the amount wagered with Gambling Commission-licensed betting operators will top £1bn. A September 2025 report by gambling intelligence platform Yield Sec estimated that illegal operators account for nine per cent of Britain’s online betting market, which extrapolated to the World Cup would mean a black market handle of £90m.
However, different studies have arrived at wildly different figures on the real scale of the unlicensed market in the UK. Licensed operators fear that the amount of advertising for unlicensed competition could help black-market operators take advantage of the World Cup to gain more traction. The BGC published findings from a WARC study in April that suggested that unlicensed gambling operators now accounted for almost half of the gambling advertising spend in the UK.
BGC CEO Grainne Hurst said: “During the World Cup, millions of customers will enjoy a flutter safely with regulated operators throughout the tournament. But while football fans back their teams, the criminal black market will also be looking to cash in, targeting customers with illegal gambling that offers none of the protections available in the regulated sector.
“At a time when illegal operators are already expected to take hundreds of millions of pounds in bets during the World Cup, policies that make it harder for regulated operators to compete, are strengthening the hand of the black market. The priority must be keeping customers in the regulated market, where robust protections are in place, rather than pushing them towards illegal operators.”
How would Financial Risk Assessments change the equation?
The BGC also took the opportunity to reiterate its concerns about the Gambling Commission’s proposed Financial Risk Assessments (FRAs). The association claims that, according to its modelling, the amount of bets placed with illegal operators during the World Cup would be up to £50m higher, assuming the scheme were implemented in the same way as tested during the Gambling Commission’s pilot last year..
Its analysis indicates that the initiative would lead to more than 400,000 customers being subjected to intrusive financial risk checks, with over 50,000 potentially shifting their custom to the black market as a result.
The Gambling Commission has defended its proposed FRAs. Although it has delayed making a final decision on whether to introduce them as a permanent measure, it says there is a wide base of evidence supporting the checks, which it insists would affect only a small fraction of gamblers. It has also criticised industry stakeholders for referring to the assessments as “affordability checks,” which the regulator believes is a misleading description.
Speaking at the Clarion Payments Providers event last month, Ian Angus, the commission’s Director of Policy, said: “Financial Risk Assessments are not affordability checks by another name. The checks we have been piloting will not even attempt to make an assessment of what each customer can afford to gamble.
“Nor do the proposed thresholds for an assessment limit or cap customer spend. FRAs were identified in the 2023 white paper as the best way to bring a frictionless and consistent method for gambling firms to check whether a consumer is in financial difficulties. This proposal was supported by the former government then and is also supported by the current government today. ”
The white paper proposal was for two types of checks: lighter Financial Vulnerability Checks, which are already in force, and more detailed Financial Risk Assessments, which were the subject of the six‑month pilot carried out last year. Critics in the industry have argued that the pilot showed the checks to be less frictionless than intended and that different credit agencies produced different results. The Gambling Commission sticks by the government’s target that less than 3 per cent of active customer accounts should trigger any steps by an operator.
The BGC recently presented a new five-point plan proposing measures against the gambling black market. The plan outlines the steps the group believes must be taken to protect the regulated sector from illegal competition. It
