The UK Gambling Commission has defended its financial risk checks programme and reassured the sector that high-spending gamblers will not need to hand over detailed financial documents as part of the programme.
This follows a pilot study that suggested financial risk assessments (FRAs) would only impact only a small minority of consumers and could be largely frictionless.
In a keynote speech delivered at the Ethical Gambling Forum in London on Tuesday, UKGC Executive Director Tim Miller clarified the Commission’s interpretation as illustrated in the 2023 Gambling Act Review white paper.
Miller sought to address recent pushback on FRAs from parliamentarians and sector stakeholders, emphasising that the process aims to protect vulnerable consumers without imposing intrusive or blanket measures.
Financial documents not required following an FRA
Crucially, Miller insisted that operators would not be required to ask for supplementary financial documents such as bank statements, following an FRA.
He also said that “the checks we have been piloting will not even attempt to make an assessment of what each customer can afford to gamble”.
Miller acknowledged that requests for financial documents have been among the most controversial aspects of recent regulatory proposals. Critics have argued such requests are invasive and disproportionate.
One such voice was the Betting and Gaming Council (BGC), where CEO Grainne Hurst previously said of the scheme: “Forcing punters to hand over bank statements isn’t ‘frictionless’, it’s intrusive and will drive customers to the illegal market, where there are no safeguards at all.”
According to a YouGov survey published by the BGC, 65% of UK bettors would refuse to provide personal financial documents if it was a requirement in order to continue betting.
Rebranded affordability checks?
The pilot was launched in August 2024, amid industry claims it was a rebrand of the heavily scrutinised affordability checks. During stage one, checks were triggered when a player’s net monthly deposit hit £500. Tier one operators in the UK participated in the checks, which could also trigger the use of credit reference agencies to assess a player’s financial history.
A second phase from February 2025 lowered the net deposit to a threshold of £150 or above.
The Commission had previously stressed the checks were not intended as spending limits or “affordability checks” in the conventional sense.
Miller highlighted the pilot cohort’s financial vulnerability. He noted they were two to five times more likely than average customers to have defaulted on debts or enrolled in debt management plans within the past year.
He told the audience that less than 3% of active customers would trigger intervention steps based on the new pilot. Meanwhile 97% would undergo a frictionless assessment, without disruption.
The figure is above the originally forecasted 80% estimated in the white paper. In response to the pilot, Commission Director of Major Policy Projects Helen Rhodes had suggested that it “helped us understand the extent that assessments could be conducted in a frictionless manner.”
The pilot suggested only 0.1% of active accounts, around one in a thousand, would be unable to complete the assessment without additional support. This is a markedly lower figure than the 0.6% initially estimated in the white paper.
Clear guidance to come
Responding to these concerns, Miller stated the Commission intended to recommend clear guidance preventing operators from seeking additional documentation post-FRA. He described such requests as lacking “a legitimate regulatory purpose”.
The Gambling Commission board has yet to decide on implementation of the checks, following the pilot scheme. Miller indicated that any decision will be evidence-based and contingent on ongoing government support.
Should the board approve, a joint implementation group would be established with the Department for Digital, Culture, Media and Sport (DCMS), operators and credit reference agencies to develop a practical rollout plan and proportionate operational guidance.
Tackling illegal gambling
Beyond FRAs, Miller outlined recent enforcement activities targeting illegal gambling sites. Between 2025 and 2026, the commission issued 741 cease-and-desist notices. They also reported nearly 398,000 illegal URLs to search engines (with about 267,000 removed), referred 1,068 websites for delisting and disrupted 1,134 websites via takedown or geo-blocking measures.
With additional funding of £26 million from the treasury over three years, the Commission plans to intensify efforts alongside a government-established illegal gambling task force.
“One of the areas that my own subgroup is working on at the moment is the publication of a national risk assessment on the illegal market to help ensure that we are all focussed on the main risks that might arise,” Miller told the audience.
A summer 2026 consultation response is also expected on gaming machine compliance and operator obligations to remove non-compliant machines from 29 July 2026.
Miller emphasised collaboration, expressing openness to credible industry proposals aligned with licensing objectives. He affirmed that the UK’s licensed gambling sector remained commercially successful and must continue to balance innovation with responsible consumer protection.
“Now is a moment where we need to also look at what we can do to help keep the consumer experience positive and competitive, especially when viewed against the illegal market.”
Kathryn Evans
Kathryn covers bitesize breaking news with a primary focus on EMEA and US legislation. A proud North Walian, fluent Welsh speaker and lifelong Wrexham FC fan – long before Hollywood came calling.
Original article: https://igamingbusiness.com/legal-compliance/regulation/document-checks-not-required-for-financial-risk-assessments/
