Financial vulnerability checks: Insights from implementation
Our Senior Policy Officer Sarah Webster and Senior Policy Evaluation Manager Richard Sutcliffe discuss light touch financial vulnerability checks which we introduced as a requirement on remote gambling businesses for the first time in August 2024.
Posted 14 May 2026 by Sarah Webster, Richard Sutcliffe
What is a Financial Vulnerability Check (FVC)?
These checks use publicly available information to identify customers who may be particularly financially vulnerable (such as where there is bankruptcy) and were already in use by a number of remote gambling operators before they were required. The introduction of requirements was designed to ensure that financial vulnerability checks were conducted by all operators at a consistent level and in a consistent manner across the remote sector.
Light touch vulnerability checks using publicly available data are separate from, and do not form part of financial risk assessments, which have not been introduced at this time.
Financial vulnerability checks are a targeted and non-intrusive way of using publicly available information to establish if a customer is subject to bankruptcy orders or has a history of unpaid debts.
Initially, these checks were applied when a customer’s net deposits with a gambling business reached a threshold of £500 over a rolling 30-day period.
As part of our commitment to reviewing the impact of new policies, the Gambling Commission requested data from remote operators on how these checks were being implemented. We also ran a session at our Operator Engagement Forum to hear more about operator views about implementation of financial vulnerability checks. In this blog, we share what we’ve learned about the introduction of checks at the £500 net deposit threshold.
Since the data request, the lower threshold of £150 net deposits over a 30-day period has come into effect and over time we plan to carry out further research on the impact of checks over a longer period and at this lower threshold.
How to read this blog
We want to be open with stakeholders and provide updates on the findings, but we emphasise that these are initial findings developed largely from a single data source. Future findings may be different as we continue to gather data and evidence can be triangulated.
The Commission’s approach to the data request
The Commission asked operators to provide data on their processes and outcomes, to gather consistent, comparable information that could help us understand the effectiveness of these checks and operators’ implementation practices.
The request focused on:
- implementation details – how and when checks were applied
- customer impact – the proportion of accounts subject to checks
- operational experience – feedback on benefits, challenges, and unintended consequences.
The responses to the data request are representative of the remote online sector. Operators included in the data request account for approximately 90 percent of consumers in Great Britain, and the sample reflects a representative mix of both smaller and larger operators.
What we learned about financial vulnerability checks
68 percent of operators already had a form of financial vulnerability check in place for a number of years ahead of the policy change, on a completely voluntary basis. A further 26 percent had introduced them in anticipation of the rule changes.
On average, operators undertook financial vulnerability checks on 7 percent of their active customer accounts during the three month period following the introduction of the requirement to conduct financial vulnerability checks (at a minimum when £500 net deposits were reached).
Generally, checks were delivered quickly, with many returned almost instantly. 78 percent were delivered within 10 minutes with a further 10 percent within 2 hours. Operators found this speed of return helpful for their processes.
The majority of operators (63 percent) delivered checks when a customer hit the threshold, but 36 percent made checks at earlier points in the customer journey (including at registration and/or first deposit). The threshold level is when operators are required to undertake a financial vulnerability check but operators can choose to do so earlier in the customer journey as a check is valid for 6 months even when a customer reaches the threshold on multiple occasions.
Most respondents agreed that financial vulnerability checks provided useful additional information. This helped them tailor interactions and monitor customers over time, often prompting earlier engagement with those who are indicated to be at risk.
There were good examples of how these checks added insight beyond existing data which helped operators build a more complete picture of customer vulnerability.
Operators highlighted benefits such as:
- granularity and historic nature of data – as a retrospective check of individual circumstances, FVCs provide a more granular and accurate view of potential vulnerabilities including more information on the scale, age and relevance of a debt
- ability to cross-check information from different sources to build a clearer picture - the fact that checks were not just related to gambling provided greater insight into customer behaviour and potential risk
- minimising non-disclosure - FVCs provided information that would not ordinarily be disclosed by customers, which was valuable in coming to a judgement about potential financial vulnerability
- speed - the speed of the check was valuable, compared with other processes such as source of funds checks.
Typically, checks were well integrated into existing processes. Operators reported positive effects, including more proactive customer engagement, earlier intervention and better quality customer interactions.
There were also some challenges noted by a very small number of operators. Some noted customer frustration and/or complaints and concerns about potential displacement to other operators when action was taken once risk flags such as bankruptcy were identified. Some expressed concern about unnecessary friction, particularly where their processes were automated following risk flags being identified by the check.
However, most operators did not observe any unintended consequences.
Implementation lessons
The data request highlighted a few areas where there may be lack of awareness or clarity regarding how checks are implemented.
Some of the responses from operators indicated a lack of knowledge about what is included in a financial vulnerability check. A financial vulnerability check may only include publicly available information about significant risk flags for financial vulnerability:
- a bankruptcy order or equivalent
- a County Court Judgment (CCJ)
- an Individual Voluntary Arrangement (IVA)
- High Court Judgment (HCJ)
- an Administrative Order (AO) or decree
- a Debt Relief Order or equivalent.
However, some operators were under the incorrect impression that they were receiving credit reference data as part of a financial vulnerability check. As the sharing of such data is not permitted as part of a financial vulnerability check, this is likely to be a misunderstanding by those completing the data returns to the Commission.
Further to these findings, we met with relevant data providers to discuss these misunderstandings and ask them to support continued education of operators and clarity to consumers that only publicly available information is available as part of a financial vulnerability check. Although the number of operators indicating a potential lack of knowledge in this area was relatively small, we think it's appropriate to promote opportunities for continued education through communications such as this blog and at industry events, compliance engagement and through the use of advice or formal guidance to the sector to reiterate these points.
Financial vulnerability checks can include publicly available information about significant risk flags such as bankruptcy or debt relief orders. They can also include information about risk flags that could be significant such as County Court Judgments. However, CCJs can relate to significant debts or smaller debts and/or disputed bills. We note that some operator responses indicate that automated responses to a financial vulnerability check in relation to CCJs may lead to unnecessary friction in cases where the risk flag is not severe or there are no other indicators of harm. Operators are reminded that they are not required to offer automated solutions that introduce significant friction - such as putting a stop on a customer account – particularly in cases which relate solely to a single CCJ which may indicate lower levels of risk.
Where automated solutions are preferred, alternatives might be to take into account spend levels, to consider automated deposit limits at a level to reduce the risk of significant harm, which could be the ultimate action taken or a temporary measure while manual checks on the level of risk associated with the CCJ are undertaken. Where you are taking action in response to an overall picture of risk, rather than the FVC alone, it would be important to avoid solely attributing your action of the FVC to the customer.
We are interested in whether guidance on this matter would be beneficial for operators over time and have begun engagement with businesses through our Operator Engagement Forum and with the Betting and Gaming Council to discuss this further.
What’s next
The findings show positive indicators that financial vulnerability checks are seen as an important tool. Operators consider that they give an additional way to strengthen customer interaction processes and, most importantly, help protect consumers who may be in particularly financially vulnerable situations such as bankruptcy. We note that financial vulnerability checks can only identify these particularly financially vulnerable situations and cannot identify financial difficulties or stress such as defaults and arrears.
These findings give an early view of how checks have been implemented at the £500 threshold. We will continue to monitor the impact of checks over time and, both directly and through the NatCen’s wider evaluation of Gambling Act Review measures, at the lower £150 threshold and share what we learn as more data becomes available.
As our work on this in ongoing, we will publish a full findings report following further consideration of the change to the lower £150 threshold.