Financial risk assessments pilot – Update
The pilot test for the UK Gambling Commission’s (UKGC) financial risk assessments has received an official update.
Risk assessments were originally proposed as part of the 2023 Gambling White Paper Review, and they’ve proven controversial to say the least.
The ultimate intent is that these assessments identify at-risk players and prevent irresponsible gambling by carrying out financial checks on customers. The vast majority of the checks would be ‘frictionless’ according to the UKGC.
The pilot design
The three-phase pilot began in late 2024. It is not yet in a “live environment”, and a full roll-out is still under consideration.
Stage One saw approximately 1 million assessments take place across the 3 credit reference agencies.
Stage Two of the pilot was completed in early 2025. It expanded the scope to 1.7 million assessments carried out on 860,000 different player accounts.
Controversy and opposition
The proposal of financial risk assessments has caused no end of controversy. From the get-go concerns were raised about player privacy and the logistics of carrying out assessments on this scale.
Some voiced concerns that the Commission would inadvertently drive players towards the already-flourishing black market, thereby likely increasing gambling-related harms.
Buried data and public rejection
The regulator didn’t help its cause by burying statistics that revealed a damning public rejection of the assessments. Ultimately, a Freedom of Information request resulted in the publication of the figures that had been withheld.
The Commission’s general response to critics is that it intends for the vast majority of these assessments to be frictionless, thereby balancing consumer protection with minimal levels of disruption.
Gambling Commission publishes update
The new update reveals the progress which has been made from Stage 1 to Stage 2, and outlines some of the key plans for Stage 3.
- The number of assessments carried out increased from 1 million to 1.7 million
- The proportion of these which were ‘frictionless’ increased from 95% to 97%
- The number of ‘thin files’ (those players with little credit data) remained around 3%
- The number of assessments that couldn’t be matched decreased from 5% to 3%
It’s mostly good news. Stage 2 has seen some significant improvements on Stage 1, especially with a reduction in the percentage of assessments that involved friction – a disruption to the player.
Based on Stage 2 findings, if the proposed thresholds were applied and rolled out, only 0.1% of accounts would receive a non-frictionless assessment.
Risk profiling appears to be reasonably accurate. The accounts that were flagged as a result of assessments were “between twice and four times more likely to have a debt management plan and between twice and five times more likely to have a default in the last 12 months”.
Financial risk assessments vs. affordability checks
The new update stresses that the UKGC is not proposing ‘affordability checks’ and maintains that these are not the same thing as ‘risk assessments’. It says that financial risk assessments are “a much more targeted way of identifying potentially financially vulnerable customers”.
Whilst the Commission did use the term ‘affordability checks’ in early discussions, this was never formally defined, and it seems that ‘financial risk assessments’ is now the preferred term, despite the actual, practical difference between the two, if any, being vague.
Terminology change
The shift in terminology appears to be an attempt to deflect accusations of invasiveness. Whereas ‘affordability checks’ has connotations of judgment and restriction, ‘risk assessments’ sounds like a supportive service being supplied even if it’s only really a softer reframing of what is essentially the same thing.
It seems possible that, by using semantics this way, the Commission is attempting to distance itself from criticism, and to brush over the fact that it buried survey data that showed public disapproval. Ultimately, however, changing the language is unlikely to change public opinion much.
What next?
Data collection for Stage 3 has already been completed, and this data is now being analysed.
This analysis process will take place through the summer, so we can expect another update in a few months.
The objective of Stage 3 is to determine how the targeting process can be refined, so that only the most at-risk individuals are flagged, further minimising friction for others.
Given the Commission’s determination in seeing through its proposals regardless of the industry’s stance and public apathy (or even antipathy), it’s safe to assume that some version of the risk assessments will be rolled out properly after Stage 3 is completed.
Summary
The ‘risk assessments’ are no less contentious than when they were first proposed 2 years ago, and the Commission has had little success in convincing the industry of their value.
Despite a decidedly lukewarm response from many, the UKGC has pushed ahead. Hopefully this decision to ignore stakeholders will not result in a fracturing of the industry, or a worsening of the already-worrying black market situation.
As much as this pilot does shed some light, only time will tell how the public will react if and when the assessments are introduced in a live environment.