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Request date: 29 April 2026
This version was printed or saved on: 4 June 2026
Online version: https://www.gamblingcommission.gov.uk/about-us/freedomofinformation/development-implementation-and-evaluation-of-affordability-checks
Please provide copies of all correspondence, documents, and communications held by the Gambling Commission relating to the development, implementation, and evaluation of "affordability checks" (including but not limited to financial risk assessments and financial vulnerability checks).
For the avoidance of doubt, this request includes (but is not limited to):
This request specifically covers communications between the Gambling Commission and one or both of:
To ensure completeness, please include material referencing any of the following terms (including historic or alternative terminology):
Any predecessor or working terminology used prior to the adoption of the term "financial risk assessments"
The request covers material relating to:
5.NatCen evaluation
Please provide:
Please provide information from 1 January 2020 to the present date (23 April 2026).
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have requested the following information:
Please provide copies of all correspondence, documents, and communications held by the Gambling Commission relating to the development, implementation, and evaluation of "affordability checks" (including but not limited to financial risk assessments and financial vulnerability checks).
For the avoidance of doubt, this request includes (but is not limited to):
This request specifically covers communications between the Gambling Commission and one or both of:
To ensure completeness, please include material referencing any of the following terms (including historic or alternative terminology):
Any predecessor or working terminology used prior to the adoption of the term "financial risk assessments"
The request covers material relating to:
5.NatCen evaluation
Please provide:
Please provide information from 1 January 2020 to the present date (23 April 2026).
The Gambling Commission can confirm that information is held falling within the scope of your request.
However, the Gambling Commission refuse to proceed with your request under section 14(1) (vexation requests) of the FOIA. Our considerations for relying on the section 14(1) exemption are detailed below.
Section 14(1)
Firstly, Section 14(1) states:
“Section 1(1) does not oblige a public authority to comply with a request for information if the request is vexatious.”
This exemption is designed to protect public authorities, particularly in terms of resources, by allowing authorities to refuse any requests which have the potential to cause a disproportionate or unjustified level of disruption, irritation or stress.
In order to determine if a request is vexatious, the circumstances surrounding that request must be considered.
The word “vexatious” is not defined in FOIA. However, the Information Commissioner’s Office (ICO) guidance defines vexatious as “manifestly unjustified, inappropriate or improper use of a formal procedure.” This definition establishes that a public authority must consider the proportionality and justification of the FOIA request in question when determining if the section 14(1) exemption applies.
The FOIA provides individuals with a greater right of access to official information in order to make public authorities more transparent and accountable. As such, it is an important constitutional right. However, the ICO also recognises that dealing with unreasonable requests can cause a strain on resources, with the potential to interfere with the delivery of other services or answering legitimate requests. Vexatious requests can also be damaging to the reputation of the legislation itself, and therefore there is an emphasis on protecting public authorities’ resources from unreasonable requests.
The ICO advise that four broad themes should be considered when determining if the section 14(1) exemption applies:
Please note, these themes are for guidance only and are not an exhaustive list. As mentioned, all circumstances of the case need to be considered in reaching an ultimate judgement as to whether the request is vexatious.
There is no obligation for a public authority to explain why the request is vexatious. The code of practice issued by the Cabinet Office under section 45 states that when refusing a request under s14(1), a public authority is not required to explain why the request is vexatious, but comments that a public authority may wish to do so as part of its duty under section 16. Therefore, although we are not legally obliged to provide advice and assistance where a request is vexatious, we have decided to explain our considerations for refusing the request as follows.
The Burden of Complying with the Request
In accordance with ICO guidance, a single FOIA request taken in isolation may be vexatious solely on the grounds of burden. That is, where complying with the request would place a grossly oppressive burden on a public authority’s resources which outweighs any value or serious purpose the request may have.
Under the section 12 exemption, you can refuse a request if it would cost more than a set limit to find and extract the requested information. Whilst the Commission has considered applying the section 12 exemption to your request, we believe that the burden of complying with the request is sufficient in itself to justify characterising the request as vexatious under section 14(1).
A public authority can apply section 14(1) where the amount of time required to review and prepare the information for disclosure would impose a grossly oppressive burden on the organisation. This includes the cost and effort associated with considering exemptions or redacting exempt information.
There is a high threshold for refusing a request under this exemption. We believe that we have a viable case to refuse this request on the following grounds:
The scope of your request covers all correspondence, documents, and communications in relation to the subject matter. We would therefore be required to review large volumes of information stored across several systems, including mailboxes, in order to fulfil your request. The date range for your request was also taken into account, as you have requested the information from January 2020 to present date.
To review, edit and redact the volume of complex information across a six-year period would generate a significant workload for the Commission resulting in a diversion of resources, particularly as different individuals across the Commission will need to be contacted for their assistance to action your request.
As you are aware, public authorities have a duty to respond to FOIA requests within the statutory deadline of twenty working days. The diversion and strain on resources caused by answering your request will therefore have the potential to interfere with the delivery of other services in the immediate term.
Public Interest in the Subject
The public interest in the subject matter of a request is a consideration that too needs to be balanced against the resource implications of the request.
The Commission recognises that there is a legitimate public interest in promoting the transparency of the Commission and in making information available to the public. Further to this, the quality of advice and the content of deliberations by officials may improve if there was an expectation that the information would be made publicly available.
We recognise that the subject of your request is a live matter of public interest which is the reason we have planned to continue to provide details of our decisions and the reasons for those decisions- through policy consultations, consultation response documents and through publishing other updates.
For example, the Commission has previously released information about the pilot of financial risk assessments and insights from implementation of financial vulnerability checks through a series of blogs which you may find useful, such as:
Blog - Financial risk assessments pilot update
Blog - Financial risk assessments pilot – update on progress
Blog - Financial risk assessments pilot – update on Stage two
Blog - Financial risk assessments pilot – update on post-pilot analysis
Blog - Financial vulnerability checks: Insights from implementation
However, the Commission must ensure that officials can exchange informal views and advice and reach decisions, free from external interference and distraction. Premature publication of information could lead to an incomplete and confusing picture emerging and would be likely to cause prejudice to ongoing work, particularly where there is an intention to publish information in the future. This, in conjunction with balancing the public interest against the resource implications of your request which have been discussed above, we conclude that the section 14(1) exemption applies.
Therefore, the Commission determines that continuing to respond to your request would impose a grossly oppressive burden on the Commission and would cause a disproportionate level of disruption to its resources, diverting staff time away from carrying out its regulatory functions.
If you are unhappy with the service you have received in relation to your Freedom of Information request you are entitled to an internal review of our decision. You should write to FOI Team, Gambling Commission, 4th floor, Victoria Square House, Victoria Square, Birmingham, B2 4BP or by reply to this email.
Please note, internal review requests should be made within 40 working days of the initial response. Requests made outside this timeframe will not be processed.
If you are not content with the outcome of our review, you may then apply directly to the Information Commissioner (ICO) for a decision. Generally, the ICO cannot make a decision unless you have already exhausted the review procedure provided by the Gambling Commission.
It should be noted that if you wish to raise a complaint with the ICO about the Commission’s handling of your request for information, then you are required to do so within six weeks of receiving your final response or last substantive contact with us.
The ICO can be contacted at: The Information Commissioner’s Office (opens in a new tab), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Information Management Team
Gambling Commission