Financial risk assessments update – July 2026
Our Director of Major Policy Projects and Evaluation Helen Rhodes provides an update following the Gambling Commission Board’s decision to proceed with the staged implementation of Financial Risk Assessments and responds to some common questions.
Posted 7 July 2026 by Helen Rhodes
It was the end of 2023 when it was agreed that the gambling industry could have access to some data from the credit information system (the system that the financial services sector uses to make lending decisions), initially for a pilot to test how they could identify and enable support for high spending customers in financial difficulties.
Following extensive consultation, engagement with stakeholders and piloting, the Commission has decided on a careful, staged approach to implementation of financial risk assessments.
This new financial risk information will identify high spending customers in current financial difficulties. This will supplement information gambling businesses currently use to understand the risk of gambling harm to best support vulnerable customers, streamlining some operator processes to identify customers in financial difficulties.
The vast majority of customers will never require a Financial Risk Assessment, which means people who place an occasional bet, are a recent winning customer or even regularly spends hundreds of pounds would be unlikely to need a check. Those who do will have a frictionless, document-free assessment provided by Credit Reference Agencies, with no impact on their credit score.
Why are the assessments needed?
There is evidence that some high-spending gambling customers are experiencing current financial difficulties but are not being identified or supported by gambling businesses.
High-spending customers are between two and four times more likely to have a debt management plan and between two and five times more likely to have a default in the previous 12 months than consumers in the wider population. Without being identified, they may continue to receive marketing and promotional offers encouraging further gambling despite being financially vulnerable.
We continue to see issues in our casework, such as those set out in our public statements: All public statements. Taking into account all the evidence, we consider the assessments to be the best and most proportionate way to identify customers at risk of harm but also streamline some processes.
Can gambling businesses identify customers in financial difficulty through other means?
Gambling businesses have other things they can do to identify customers at risk of harm, but none of those measures can identify high spending customers in current financial difficulties in the same way. And none of the other measures can reduce the need for unnecessary document checks.
Financial Risk Assessments were always intended to be part of a package of measures that worked together to reduce harm. For example, Financial Vulnerability Checks and Financial Risk Assessments were designed to work together to help minimise harm for those gambling who were in current financial difficulties.
How does a Financial Risk Assessment work?
Assessments provide gambling businesses with access to limited credit reference data for the first time. The assessments will not affect a customer’s credit rating. Customers who hold the highest spending accounts will have a frictionless assessment, and if that flags financial difficulties taking account of defaults, multiple/significant arrears, the business will consider whether it is right to offer some support to the customer, taking into account other things they know.
Less than 3 percent of customer accounts would need an assessment when fully implemented. For these high-spending consumers who receive an assessment but who are not experiencing financial difficulties, the introduction of financial risk assessments should reduce friction – where a business asks for documents or acts based on a generic level of spend.
Where there are financial difficulties, the business can make informed decisions to support that customer in a proportionate way.
Is there a risk that operators will use consumer data inappropriately?
The Commission’s requirements will specify that Financial Risk Assessments must only be undertaken at the appropriate time and for regulatory purposes. The information must not be used for any commercial purposes, in line with data protection law. There are strong powers to take compliance and enforcement action should there be a breach of the proposed licence condition or data protection law more generally.
What type of action might be offered to support a customer in financial difficulties?
Even where a high-spending customer is in financial difficulties, we will back operators to take appropriate and proportionate action. They should consider everything they know about the customer (including things that reduce risk) and use all options. These can include actions such as reducing marketing to vulnerable consumers, supporting customers to set deposit limits or more where needed for the individual.
Who won’t be able to get a frictionless assessment and why?
The vast majority of customers won’t need an assessment at all. For those that do need an assessment, 97 percent of these will be frictionless. This means that less than 3 percent of accounts would have an assessment and less than 0.1 percent (1 in 1,000 accounts) would need one and be unable to get one in a frictionless manner. In the pilot, we found some of these customers had not had their identity verified properly by the operator meaning that the operator had not properly verified the age or identify of these high-spending customers, potentially in breach of current requirements.
Some customers might not be able to get a frictionless assessment because they have recently moved to Britain or changed their name or address without it appearing on the credit reference systems yet.
For both of these sets of customers, their identity needs to be verified properly and this also might mean assessing financial risk through other processes such as open banking or document checks.
If a Financial Risk Assessment flags financial difficulties, will there be friction?
There will be support for high-spending customers who are in financial difficulties – what this support will be depends on what else is known by the business. The key aim of introducing Financial Risk Assessments is to identify and then support those high spending customers in current financial difficulties.
We will engage with implementation groups on guidance to support operators to take proportionate action to the overall risk identified.
What is the staged implementation?
The first stage of implementation will see Financial Risk Assessments carried out by the largest operators, where there is high spend of multiple thousands of pounds over a 24-hour period. For most, this means £5,000 net deposit in a rolling 24-hour period, which is a very unusually high spend pattern that less than 0.5 percent of customers exceed.
Once fully implemented in due course, Financial Risk Assessments will be applied to customers aged 25 years or older with net deposits exceeding £1,000 in a rolling 24 hour period or £3,000 over a rolling 90-day period; for those under 25 these thresholds will be reduced to £750 in a rolling 24 hours or £2,000 in a rolling 90 days.
| Stage of implementation | Consumers 25 years old and over | High risk groups such as consumers under 25 |
|---|---|---|
| Stage 1 implementation | Exceeds £5,000 net deposit in a rolling 24-hour period | Exceeds £2,500 net deposit in a rolling 24-hour period |
| Interim stages of implementation | To be set following further engagement with implementation groups and stakeholders | To be set following further engagement with implementation groups and stakeholders |
| Final stage of implementation | Exceeds £1,000 net deposit in a rolling 24-hour period or exceeds £3,000 net deposit in a rolling 90-day period | Exceeds £750 net deposit in a rolling 24-hour period or exceeds £2,000 net deposit in a rolling 90-day period |
What is the timeline for implementation?
Credit reference agencies and gambling businesses will need some time to prepare for Stage 1 of implementation. To discuss these practical steps, implementation groups will be established over the summer.
The start date for Stage 1 will be confirmed in the formal consultation response document following engagement with industry and other stakeholders, including through these implementation groups.
How can operators be certain that any action they take will be considered compliant? What if the Commission takes a different view?
We have heard concerns from businesses that they might be expected to take more action for an individual that they consider appropriate. To support operators to build proportionate approaches to implementation we have stated that no enforcement action will be taken for a failure to act following an assessment during the early stages of roll out, so long as existing requirements are met.
We recognise that there is a fine balance to be struck between giving clear expectations and being overly “prescriptive” in requirements or setting out detailed guidance that might be misinterpreted as requirement. The guidance will aim to support businesses to take a proportionate approach to implementing assessments as part of their wider customer interaction approach.
Will these assessments push consumers to other forms of gambling or even to the black market where there is no safety?
The way in which operators implement action following a check is key – and this is why we are taking a careful, staged approach. Where the action taken is proportionate, the risk of moving customers to other operators/products is lower. That’s why we will work with stakeholders to develop guidance that supports proportionate responses and the most appropriate approach for each consumer.
Industry and others have told us that current document checks used by many operators risk driving consumers to the illegal market. Our proposed approach, which reduces document checks for socially responsible purposes, will decrease the risk of these consumers going to the illegal market because they do not want to provide financial documents.
It is vital that work continues to tackle the illegal market and that we continue our work to understand and evaluate the impact of our work.
Will there be an impact on the industry’s Gross Gambling Yield (GGY)?
High-spending customers are a small proportion of customers, but they contribute a significant proportion of GGY. When the Government proposed Financial Risk Assessments they were clear that there would be an impact on GGY but that this was necessary to reduce harm. We have continued to assess the potential impact taking into account the findings from the pilot - the positive frictionless rate and the level of risk in the high spending customer cohort. The exact impact depends however on how assessments are implemented and this is why we are taking a careful, staged approach to implementation. To be clear, any reduction in GGY will primarily come from a reduction in spend from high-spending customers who are in financial difficulties. One of the objectives of the Gambling Act is to protect children and the vulnerable, so protecting this group falls squarely with the Government’s, Commission’s and operators’ remit to uphold the licensing objectives in the Gambling Act.
These assessments focus only on the spend of a customer. What about other factors to consider when assessing risk such as time spent gambling?
The Commission already requires operators through our Customer Interaction requirements (3.4.3) to use a range of indicators to identify harm. These include patterns of spend; time spent gambling; use of gambling management tools and account indicators such as multiple or changing payment methods.
The assessments will provide additional insight in relation to the highest spending customers to help inform an overall understanding of risk.
The credit reference agencies do not always hold consistent data. How can operators make decisions based on different results about customers?
We are confident that the Credit Reference Agencies hold the best quality data available on customers in financial difficulties, the same data that is used in the financial sector to inform lending decisions and identify vulnerable customers. No other tool has the same relevant data. In contrast, current operator approaches are highly inconsistent – using different data sources and interpreting those differently. These assessments are considerably better than the status quo and other available tools.
Where there are differences between credit reference agencies, this is most likely to be an underestimation of the financial difficulties or reflect different timescales for loading and removing risk flags. Consistency between credit reference agencies is likely to continue to improve due to the work of the Financial Conduct Authority (FCA) and the new Credit Information Governance Body (CIGB).
However, we have heard that operators consider they would need to understand better how recent and severe financial difficulties identified by an assessment are to inform good quality decision making. We will support the refinement of credit reference agency models to improve understanding of these aspects.
Will operators get enough information about the type of risk a customer faces? Will they have to request documents to get more detail or to verify what is in an assessment?
Operators will be provided with an overall financial risk assessment together with information in relation to four data points – defaults; multiple arrears; significant arrears and whether the customer has a Debt Management Plan. One missed payment on a mobile phone account would not have the same impact on the overall financial risk score as 12 months of missed mortgage payments so operators can be confident that if a customer is flagged as being at risk they can rely upon that information. We will support operators to avoid unnecessary document checks for socially responsible purposes - to do routinely following an assessment would serve no regulatory purpose.
These checks will only capture people spending extremely high amounts of money. What about considering harm caused at much lower levels of spending?
The Government and the Commission determined that it would be proportionate for a gambling operator to be required to understand more about a customer’s financial risk when they exceeded the threshold levels. Operators are required to monitor for gambling harm across all their customers but because the financial risk information is sensitive it is only appropriate for gambling operators to access that information at higher levels of spend.
You don’t have financial risk checks when you buy a car or clothes, why should you have one for gambling?
While most people that gamble enjoy gambling and don’t experience harm, Parliament has long determined that gambling should be a regulated industry partly because of the harm that gambling products can cause. The pilot identified that high-spending customers are more likely to be in financial difficulties than the credit reference agency comparator populations and that they are not always being identified or supported.
(You can also read more about the Commission’s work in this space in earlier blogs: Blog - Your questions answered on the financial risk checks consultation).
What happens next for financial risk assessments?
We will continue our extensive engagement with stakeholders. We will set up implementation groups to discuss practical steps for implementation. Implementation groups will be set up over the summer. Following this engagement, we will publish our formal consultation response document, setting out the timeline for Stage 1.