Report
Exploring gambler attitudes towards Financial Vulnerability and Financial Risk Check proposals
The Gambling Commission’s report on the attitudes and opinions of online gamblers regarding the proposals for financial vulnerability and financial risk checks.
5 - Financial Risk Assessment: detailed insights
This section documents gamblers’ reactions to detailed elements of the Financial Risk Assessment including net loss thresholds (for ‘binge gambling’, £1000 over a 24-hour period and for 'unaffordable losses over time’, £2000 over a 90-day period), the use of credit reference agency data to determine risk, and the 6 month duration and validity period. Lower threshold limits for younger, 18 to 24 year old, gamblers were also explored (for ‘binge gambling’, £500 over a 24-hour period, and for ‘unaffordable losses over time’, £1000 over a 90-day period).
Preceding positions
In the qualitative phase, online gamblers were asked to evaluate proposals that take into account preceding positions (net loss, considering their preceding position over a specific timeframe) when assessing financial risk. Participants thought that the idea of considering a customer’s preceding position makes sense and feels sensible and reflective of ‘real’ gambling behaviours, wherein you might gain a substantial win and re-stake the amount. Most say they would continue gambling with some, if not the majority, of any winnings and do not count this as ‘real’ money. Online gamblers agree it should count in the net loss calculation as an individual would still be ‘up’:
- 7 days for £1000 loss in 24 hours – there was some pushback that this timeframe is too short, and a gambler’s position should be considered for 14 days or a month. However, most agree that 7 days is proportionate given the severity of a £1000 loss
- 90 days for £2000 loss in 365 days – there was no resistance on this timeframe, online gamblers felt that this feels fair and imagine how it allows more serious online gamblers to ride their ups and downs.
"When I gamble, I gamble what I can afford to lose - so the winnings is fair game to lose - I do not need those winnings necessarily so they should be able to be lost and not make an impact, if that makes sense"
25 to 55 years old, low income, range of gambling activity from daily to monthly, range of deposit amounts from £10 to £100 or more a month
‘Binge Gambling’: proposed thresholds
The quantitative survey results revealed that 51 percent of online gamblers felt that the ‘net loss’ threshold for ‘binge gambling’ (£1000 in 24 hours) is ‘the right amount’, as proposed in the consultation.
However, there was a minority (35 percent) who considered the threshold ‘too high’. This may reflect an instinct among some gamblers that the threshold could be lowered in order to protect the most vulnerable gamblers.
Table 5.1 Perceptions of the £1000 in 24 hours threshold for the Financial Risk Assessment (all gamblers) 1
| Gambler response | Total (percentage) |
|---|---|
| Too high | 35% |
| The right amount | 51% |
| Too low | 6% |
| Do not know | 8% |
The qualitative phase evidenced that for all online gamblers, even those with higher income and deposit levels, the loss of £1000 in 24 hours is extreme and indicative of worrying behaviour, and should result in some kind of check or intervention.
"If you are gambling like this, you need someone watching your back, this could help save somebody. I have no problem with a financial assessment for someone who lost £1000 in 24 hours, I think it’s due diligence to stop and help people recklessly losing money, I’m all for it."
50 to 70 years old, range of gambling activity from daily to monthly, range of deposit amounts from £10 to £150 or more a month
Whilst most have not been in this situation, it is easy to visualise themselves or others getting into this kind of situation by chasing their losses.
"That for me is binge gambling, I’ve gambled a lot of money before and it leaves this massive, horrible feeling inside yourself, £1000 is a massive feeling, that person needs help."
Frequent gambler, £500 or more monthly deposit amount
Therefore, for this level of loss, the proposed check to target binge gambling behaviour feels proportionate and warranted. Gamblers felt that it is difficult for anyone to argue against it, even for those who are initially opposed to the overarching principle of a financial check. In alignment with quantitative phase, a significant proportion of gamblers also feel that the threshold could be lowered to £500 or £750 in 24 hours, as that would still be concerning and an unaffordable amount for most.
"I think that 1000 pounds is a lot before this is triggered... that's like a significant amount of money. And so, if you lost net loss of 500 pounds in 24 hours, it’d probably be a nicer figure for me."
Frequent gambler, £500 or more monthly deposit amount
‘Unaffordable losses over time’: proposed thresholds
The quantitative survey data showed that over half of online gamblers believe the current threshold of £2000 in 90 days is a reasonable one. 51 percent of those surveyed answered that the threshold was ‘the right amount’. However, a large minority (30 percent) answered that the threshold was ‘too high’, again perhaps reflecting an instinct that those who are at financial risk could be identified sooner through a lower threshold.
Table 5.2 Perceptions of the £2000 in 90 days threshold for the Financial Risk Assessment (all gamblers) 2
| Gambler response | Total (percentage) |
|---|---|
| Too high | 30% |
| The right amount | 51% |
| Too low | 10% |
| Do not know | 9% |
The qualitative phase delivered a more nuanced story, revealing a difficulty among most gamblers in relating to both the amount lost and time period. The concept of ‘unaffordable losses over time’, as expressed through the £2000 in 90-day threshold, and the sustained heavy-loss gambler it was targeting, was far more difficult than ‘binge gambling’ to personally relate to.
Indeed, the £2000 net-loss threshold was high for many gamblers, who struggled to imagine the patterns of play that the 6 month timeframe encompasses (90 days preceding position, 90 days loss period). All described how they think on a shorter-term basis, typically month by month (a typical pay-cheque timeframe for many people) rather than over an extended window of time.
"I feel you could easily lose £2000 in 90 days, actually maybe that would be concerning… to be honest I have no idea what I lose in 90 days… I do not know about this one, it’s fine, but it feels weaker than the binge gambling. I understand there needs to be a longitudinal view but 90 days is not working for me."
Frequent gambler, £500 or more monthly deposit amount
So, whilst the quantitative results suggest that there is considerable support for lowering the proposed threshold, what also emerges is the need to communicate the nature of gambling risk over extended time periods which is less apparent to gamblers than binge gambling. Indeed, the fact that most gamblers in the qualitative phase had little to no idea of what their 3 or 6 month position might look like is further evidence that unaffordable losses over time requires enhanced levels of explanation relative to the other proposed checks.
Lower thresholds for younger gamblers
Gamblers were also asked the extent to which they agreed or disagreed with the idea of lower ‘net loss’ thresholds for 18 to 24 year olds, compared to those aged 25 and over.
At a total level, quantitative results show there is widespread support for the idea: three quarters (74 percent) agreed with the idea, compared to over 1 in 10 (15 percent) who disagreed.
Analysis by age group revealed broad consistency of opinion; indeed, those aged 18 to 24 were statistically just as likely to support the idea of lower thresholds as the total sample (76 percent compared to 74 percent at a total level) and, similarly, were just as likely to oppose the idea (15 percent for both 18 to 24 year olds and the total).
Table 5.3 Agreement with a lower ‘net loss’ threshold for those aged 18 to 24 (all gamblers and by age group) 3
| Gambler response | Total (percentage) | 18 to 24 years old (percentage) | 25 to 34 years old (percentage) | 35 to 44 years old (percentage) | 45 to 54 years old (percentage) | 55 to 64 years old (percentage) | 65 years old or more (percentage) |
|---|---|---|---|---|---|---|---|
| Agree | 74% | 76% | 72% | 73% | 73% | 77% | 82% |
| Disagree | 15% | 15% | 15% | 18% | 16% | 11% | 13% |
| Do not know | 10% | 9% | 13% | 8% | 11% | 12% | 5% |
In the qualitative discussions, the findings were more nuanced. There was some pushback from the age group in question and older online gamblers about the principles for a lower threshold, namely based on their own experience or their children’s experience that these younger individuals tend to have more disposable income, with less responsibility and less to jeopardize with a loss. Despite those reflections there is an appreciation that younger adults could be more vulnerable to ‘irresponsible’ gambling and less likely to have established protective behaviours. Overall, none were strongly opposed to the lower threshold amounts, suggesting that these levels felt appropriate for protecting younger gamblers, even if the underlying rationale for lower levels did not resonate.
"I think it's a big problem for young ones these days. When my son turned 18, the first thing he wanted was a betting account. I think is a big problem out there for younger generation."
50 to 70 years old, range of gambling activity from daily to monthly, range of deposit amounts from £10 to £150 or more a month
"Does not make sense, I get it that if you're under 25 you’re more likely to live with parents and you may have more [disposable] income to lose but after this stage you have more commitments and responsibilities and can afford to lose even less, so it should be lower for older people too."
18 to 24 years old, range of gambling activity from daily to monthly, range of deposit amounts from £10 to £100 or more a month
How the Assessment is conducted: Use of data and friction
In the quantitative survey, there was broad support for the proposed use of credit reference agency data to perform the assessment at a total level. Around two thirds of gamblers (65 percent) reported that they were favourable towards its use. However, there were also considerable proportions of either direct opposition (14 percent), or else uncertainty, ambivalence, or indifference (21 percent answering ‘neither nor’ or ‘do not know’).
Further analysis by gambling subgroup reveals higher levels of objection to the use of credit reference agency data among more active gamblers. Those with 4 or more active accounts were significantly more likely to be unfavourable than the total sample (20 percent, compared to 14 percent at a total level).
Table 5.4 Favourability towards the use of credit reference agency data to perform a Financial Risk Assessment (all gamblers and by number of active accounts) 4
| Gambler response | Total (percentage) | 1 to 3 active accounts (percentage) | 4 or more active accounts (percentage) |
|---|---|---|---|
| NET: Favourable (scoring 4 or 5) | 65% | 69% | 56% |
| Neither favourable nor unfavourable | 18% | 17% | 23% |
| NET: Unfavourable (scoring 1 or 2) | 14% | 12% | 20% |
| Do not know | 3% | 2% | 1% |
Quantitatively, there were clear concerns about the disruptiveness of the Financial Risk Assessment voiced by large proportions of the sample. Although the largest group believed the Assessment would not be disruptive (45 percent), over a fifth of gamblers (21 percent) believed that the Financial Risk Assessment would be disruptive to their gambling activity, which is almost double the proportion who felt that way about the Financial Vulnerability Check (11 percent). Furthermore, around a third (34 percent) were uncertain, ambivalent, or indifferent (answering ‘neither nor’ or ‘do not know’).
Yet again, quantitative data revealed that more active gamblers are more likely to be concerned. 3 in 10 (31 percent) of those with 4 or more active accounts believed the Financial Risk Assessment would be disruptive, compared to 21 percent of the total, a statistically significant difference.
Table 5.5 Perceived disruptiveness of the Financial Risk Assessment to gambling activity (all gamblers and by number of active accounts) 5
| Gambler response | Total (percentage) | 1 to 3 active accounts (percentage) | 4 or more active accounts (percentage) |
|---|---|---|---|
| NET: Undisruptive (scoring 4 or 5) | 45% | 47% | 42% |
| Neither disruptive nor undisruptive | 29% | 30% | 25% |
| NET: Disruptive (scoring 1 or 2) | 21% | 19% | 31% |
| Do not know | 5% | 4% | 2% |
In the qualitative phase, the use of credit reference agency data was generally understood, being familiar to customers and an established measure of affordability that is commonly experienced (used across a range of industries from applying for a mortgage through to buying a sofa on finance).
Even though gamblers may not like the idea of being subjected to this type of check, they recognised the need and believed it is an effective assessment of whether someone is in financial trouble. This aspect of the proposal was therefore seen to be proportionate and fit for purpose.
The primary concern over these checks was whether it would impact an individual’s credit score and/or whether it being performed by a gambling company would be visible anywhere on that individual’s credit record. Gamblers were indeed wary of there being any record of their relationship with a gambling company that other service providers may see and use against them, such as being visible when applying for a mortgage.
"I do not have a problem with it IF it’s not going to impact your credit score at all, I would not want any trace that this had happened to be online. I’m trying to get my credit score up, I do not need something like that impacting it when I have not done anything wrong."
25 to 55 years old, low income, range of gambling activity from daily to monthly, range of deposit amounts from £10 to £100 or more a month
There are further concerns raised in the event of open banking or sharing of bank accounts being required if the Financial Risk Assessment cannot be completed in a frictionless manner. Gamblers felt that this was incredibly invasive and a much more personal level of private information than the credit check which a company can perform without additional information.
Most gamblers would not be comfortable sharing this type of data with a gambling company due to an inherent lack of trust.
"I do not trust gambling companies with my data, I trust my bank with my data. It really does not leave me with confidence that they [gambling companies] would be handling my data."
25 to 55 years old, gamble several times a week or daily, £250 or more monthly deposit amount
Ultimately qualitative results suggest that the higher level of perceived disruption associated with the Financial Risk Assessment versus the Financial Vulnerability Check can be attributed to a lack of clarity amongst gamblers about what a Financial Risk Assessment would involve and concerns that it would impact a gambler’s credit score, or leave a trace on their credit report, combined with deposits being paused whilst checks take place.
However, this is not to say that gamblers feel opposed to this type of check but merely that some disruption is inevitable and warranted in the event of significant net loss thresholds being exceeded. Indeed, here, some feel this could go further and gambling on one’s account should also be paused to prevent further harm.
"It’s really good that the deposits are halted during this, because people obviously chase their tails at these times."
Frequent gambler, £500 or more monthly deposit amount
"Only thing I disagree with is that they are letting you play with what you have in your account, it is good that they are freezing deposits, but it does not go far enough, I think it should automatically withdraw what you have left if you lose this type of amount."
Frequent gambler, £500 or more monthly deposit amount
Results from both quantitative and qualitative phases show that there is a strong degree of favourability towards the use of credit reference agency data to carry out a Financial Risk Assessment, and a broad acceptance that the Assessment would not be disruptive. However, the presence of a large proportion of either opposition or uncertainty in the quantitative phase, alongside specific concerns voiced in qualitative phase, points to a need to provide reassurance that the Assessment would not impact a gambler’s credit score, in addition to clear communication around how and why this data would be used. Specifically, clarifying that these checks would occur under the supervision of a third-party regulator or government for player protection purposes, and not the gambling companies themselves would help address concerns. The existence of higher levels of opposition, uncertainty, and concern towards the Financial Risk Assessment compared to the Financial Vulnerability Check indicates that this would be the measure around which public understanding and support would be lowest, and therefore where specific focus should be applied in making sure communications sufficiently address concerns.
Validity period
Results from the quantitative survey revealed broad agreement with the 6 month timeframe. Just under two thirds (64 percent) responded that this timeframe is ‘the right amount of time’.
Of those who did not agree with this timeframe, gamblers were split between believing it was ‘too short’ or ‘too long’ (12 percent and 14 percent respectively). Whilst this shows some objection to the timeframe as proposed (around a quarter of the sample overall), there is no clear consensus on what an alternative should be.
Table 5.6 Perceptions of the 6 month validity period for the Financial Risk Assessment (all gamblers) 6
| Gambler response | Total (percentage) |
|---|---|
| Too long | 14% |
| The right amount of time | 64% |
| Too short | 12% |
| Do not know | 9% |
In the qualitative phase, the shorter 6 month timeframe was felt to be in keeping with the increased severity and risk of the loss levels.
Taken together, qualitative and quantitative findings therefore provide evidence that the shorter 6 month timeframe is generally considered reasonable given the heightened levels of harm associated with gamblers losing high amounts over short periods of time. However, the presence of a large degree of uncertainty also suggests that focus would need to be applied in communicating why this validity period is considered appropriate.
References
1 'In your opinion, does this seem too high, the right amount, or too low to identify those customers who are financially at risk?' Base: All gamblers (1000)
2 'In your opinion, does this seem too high, the right amount, or too low to identify those customers who are financially at risk?' Base: All gamblers (1000)
3 'Do you agree or disagree that customers aged 18 to 24 years old should have a lower ‘net loss threshold’ than those aged over 25?' Base: All gamblers (1000), 18 to 24 (126), 25 to 34 (256), 35 to 44 (215), 45 to 54 (193), 55 to 64 (127), 65 or older (83 - Caution, low base)
4 'How favourable or unfavourable would you be towards gambling companies a having access to a customer’s credit reference agency data to perform a Financial Risk Assessment?' Base: All gamblers (1000), Active accounts: 1 to 3 (741), Active accounts: 4 or more (206)
5 'On a scale of 1 to 5, where 1 means completely disruptive and 5 means completely undisruptive, how disruptive or undisruptive do you think these checks would be to the gambling experience?' Base: All gamblers (1000), Active accounts: 1 to 3 (741), Active accounts: 4 or more (206)
6 'Does the period of 6 months for a Financial Risk Assessment staying valid seem too long, the right amount of time, or too short?' Base: All gamblers (1000)
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Check outcomes - Gambler attitudes towards Financial Vulnerability and Financial Risk Check proposals
Last updated: 1 May 2024
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