Financial risk assessments pilot – update on post-pilot analysis
Our Director of Major Policy Projects and Evaluation Helen Rhodes provides an update on the post-pilot analysis of financial risk assessments.
Posted 16 April 2026 by Helen Rhodes
Here at the Gambling Commission we have been continuing to dig into the data from last year’s pilot of financial risk assessments (FRAs) and our further pilot analysis phase. We have been considering how assessments match up to the outcomes and impacts set out for them in the 2023 Gambling Act Review White Paper and how they could be used in a practical way to make gambling safer for high spenders who are in current financial difficulties.
Currently, consumers who gamble experience a patchwork of different approaches by gambling operators as to how they identify financial difficulties and the data they use to do so. This means that operators are often reliant on asking their customers for documents when there may be little real need to do so. At the same time, our casework found too many examples of operators not providing support for high spending customers who may be at financial risk. Financial Risk Assessments were identified by the previous government as the best way to bring a frictionless and consistent method to the market for gambling firms to check whether a consumer is in financial difficulties. This proposal is also supported by the current government.
There has been a lot of recent commentary about financial risk assessments and sadly much of it has been ill informed or inaccurate. For example, some coverage has suggested that consumers are currently being driven to use illegal operators as a result of financial risk assessments. This is despite the fact that the assessments are not live and not a single consumer has had any action taken based on one – even during the pilot. Operators may have asked customers for documents or carried out other checks but those were not financial risk assessments. Such checks could be for a range of reasons such as anti money-laundering, commercial reasons or where there were safer gambling concerns from the gambling business.
Similarly, we have seen suggestions that we are introducing spending limits or caps on customer spend. This is not the case. Instead, we proposed that when a customer hits thresholds that put them in the top 3 per cent of gambling spenders they can continue to gamble, but that this is the trigger to check whether they are in financial difficulties.
It is essential that everyone has an accurate picture of what was proposed by the white paper and our consultation and so this blog reiterates some key points, provides an update on where we are and sets out what the next steps will be.
Background
Financial Risk Assessments are a proposed way of identifying high-spending remote gambling customers who may be in financial difficulties, in order to help support them. This is not an “affordability check” as the check proposed would make no assessment of a customer’s income or how much an individual could afford to gamble. There are no proposals or plans to introduce affordability checks. Instead financial risk assessments would be a much more targeted and proportionate way of identifying customers who are in current significant or imminently worsening financial difficulties by flagging customers who are, for example, in significant or multiple arrears, defaults or bankruptcy. The assessments would be triggered automatically, when certain spend thresholds are met, with an assessment made based on data held by credit reference agencies. For the vast majority of people who receive a check, this would happen behind the scenes, with no change to their customer experience.
This way of identifying vulnerable people could, over time, be used to support these customers and prevent some of the very damaging cases we have seen where customers have been able to gamble large amounts without any checks or support.
The pilot was a means of proceeding cautiously as set out in our consultation response. We wanted to test whether - and how – Financial Risk Assessments could be introduced in a way that supports high-spending customers in financial difficulties but also removes any unnecessary friction in the customer journey for the vast majority of customers. You can read more about the pilot in our Stage 1 and Stage 2 update blogs.
Financial risk assessments would not affect a customer’s credit score if they were introduced in the future. In contrast to some of the confused coverage, financial risk assessments would be frictionless for customers who have not built up a significant credit file through lending (sometimes referred to as “thin file” customers). These customers would also not have the flags for financial difficulties such as arrears and defaults and so would not be identified as high risk.
Where are we now
The pilot gave us very encouraging findings on how frictionless and speedy assessments could be and we have been investigating further the practical issues that gambling businesses raised.
We are collating all of these considerations to inform decisions on whether and, if so, how to introduce financial risk assessments. And it’s important to state that by the outcomes set out in the White Paper the pilot shows financial risk assessments can work and work in a frictionless way:
Based on the White Paper and the consultation proposals, less than 3 per cent of active customer accounts would trigger any steps by an operator under these proposals. In formulating recommendations, we will be mindful of this important targeting of the measure at the highest spending accounts. It is important to measure the percentage of customer accounts in this way because this is the consumer perspective - consumers need to understand how likely it is that they as a participating customer would be subject to a financial risk assessment
Of these 3 per cent that would undergo an assessment, the pilot showed 97 per cent would have a frictionless assessment process – obtaining the assessment would be frictionless and not require the customer to take any actions, including providing documents. This is far better than what government estimated when they published the White Paper, which was that 80 per cent of assessments would be frictionless
Only a very small proportion of active accounts would receive an assessment and be unable do so in a frictionless manner. The White Paper estimated approximately 0.6 per cent of active accounts would fall into this category but the pilot showed that we could significantly improve on that expectation with just 0.1 per cent of accounts that would both require an assessment and be unable to receive an assessment in a frictionless manner. In other words, based on these estimates, when considering the impact of the introduction of the consulted measure, operators would only be unable to conduct an assessment in a frictionless way for 1 customer in every 1,000 accounts on average across the remote sector
It is important to remember the proposed thresholds for an assessment are not limits or caps on customer spend. They are simply the triggers for the assessment to ensure a greater consistency of approach. And operators would look at other risk evidence available to them in tandem with those assessments when coming to a decision on next steps
Lastly and importantly, there would be no need to require document checks following a financial risk assessment and we would support operators, such as through guidance, on how to avoid choosing to build in unnecessary friction for consumers.
Further insights from the pilot data
We’ve learned more from digging into the pilot data. The pilot showed that operators can significantly improve their own frictionless rate of assessment by making sure their identity and age verification processes which they are already required to do by the Act and our rulebook, the Licence Conditions and Codes of Practice (LCCP), are compliant. The pilot found that a better match rate could be reached by improving upfront identity verification procedures and meeting existing requirements properly. For example, allowing a customer to register with an initial instead of a full name or using a commercial address does not deliver age or identify verification properly - fixing these cases will support frictionless customer journeys later on. We will shortly publish more information on this to support operators to be compliant with existing requirements on age and identity verification.
Operators rightly point out that the customers who undergo an assessment are those who are the highest spending customers and therefore any action taken to support those customers who are in financial difficulties could have a bigger impact than the low percentage of active accounts undergoing assessments might at first appear. The Commission agrees that it is important to consider the impact and ongoing evaluation of financial risk assessments taking into account that higher spending customers are involved. Forms of support for customers will be most effective if they support customers to gamble sustainably rather than simply move to the land based, bricks and mortar market, between operators or to the illegal market.
Operators have also pointed out that the action they might take to support a customer when financial vulnerability is identified can be seen as friction in the journey. But we cannot forget that interaction or support for a customer who is found to be in financial difficulties is what the policy is intended to deliver.
This is important because there are a set of vulnerable customers that are not currently being identified - customers in the pilot cohort 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 than comparable consumers in the population. Some of these customers are being supported by operators now, but not all. And this support for consumers who are at financial risk can be through many ways, for example, setting deposit limits with or for the customer or reduced marketing. It is really important that customers are supported rather than experiencing a knee-jerk reaction to a financial risk assessment by an operator defaulting to requesting documents (such as bank statements) or closing an account in every case. We want better outcomes for consumers, not for them to be unnecessarily pushed out of the licensed market by a risk averse response to indicators of risk.
We know from the financial sector that there are some differences between the data sources and timings of different credit reference agencies and are pleased that action is being taken by the FCA to mitigate these differences, such as mandatory reporting. Operators have nevertheless expressed some concern about consistency of data between credit reference agencies. We are therefore pleased that the pilot has given us useful information about data difference between credit reference agencies. This information can help inform comparisons to the consistency of the data and processes that operators currently use, and practical steps that can be considered if the decision is to proceed to implementation. We can reassure operators and stakeholders that the Commission in no way would expect operators to validate the findings of a financial risk assessment through document checks - this would be largely meaningless and unnecessary friction for consumers. An operator should only be expected to act on the basis of information that is available to them - and consider all of that evidence in the round.
Next steps
We are now approaching the point where we will be taking what we’ve learned from the financial risk pilot to the Gambling Commission Board for consideration on next steps. And despite the success of the pilot in informing those considerations, no one should pre-judge what comes next. If the decision is made to introduce these assessments, we will work closely with the industry and credit reference agencies on the details of a sensible implementation plan. We are mindful of the risk of over implementation or overly quick implementation of regulatory requirements which could lead to unnecessary friction for consumers. The Commission would also look to work with operators on guidance that will help operators take a proportionate approach when offering support to consumers where financial risk is present and the customer continues to spend at a high level.
We want to emphasise the importance of ongoing evaluation - NatCen has been working with us as evaluation partner for the pilot and their reports will be published in due course alongside our decisions on next steps. We and DCMS also consider it vital to build in ongoing evaluation to support effective implementation of any measure it may be decided on and this will give us the ability to amend and adapt to ensure that our outcomes are delivered - frictionless assessments leading to support to customers in financial difficulties where high spending could lead to significant financial harm.