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Commission updates on the financial risk assessments pilot

21 May 2025

Today the Gambling Commission has published a further update on the ongoing pilot of financial risk assessments.

Written by the Director of Major Policy Projects who is leading the pilot, Helen Rhodes, this update provides information on Stage two of the pilot and the issues being explored in the final stages of the pilot.

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 the same as “affordability checks” - the Commission does not have any regulatory requirements for affordability checks and is not proposing any. Financial risk assessments would be a much more targeted way of identifying potentially financially vulnerable customers. They would not affect a customer’s credit score if they were introduced in the future.

Key points covered by the update are:

  • the Commission is carefully piloting financial risk assessments to assess how they could be used to support financially vulnerable customers, before making final decisions on whether - and how - they could be introduced. The pilot is not in a live environment. It is being conducted in three stages, plus an analysis period at the end to finalise the review of the findings.

  • in Stage two of the pilot, there were approximately 1.7 million financial risk assessments across three credit reference agencies, in relation to approximately 860,000 accounts. This is an increased number of risk assessments compared to Stage one due to the design of Stage two, but this is not indicative of how many accounts might be assessed if the assessments were introduced in a live environment.

  • in Stage one, approximately 95 percent of assessments were possible in a frictionless manner, and for Stage two this increased to 97 percent. The findings from Stage one and two are favourable, compared to the 80 percent which was estimated in the 2023 Government White Paper (opens in new tab). Included in this category is the “thin file” rate. “Thin files” are where the customer could be identified but there was limited information and no adverse information. We consider these “thin files” to show no financial risk in the gambling context. This “thin file” rate stayed at approximately 3 percent of the assessments in both Stages one and two.

  • approximately 3 percent of the assessments were not matched in this stage – this compares to 5 percent in Stage one of the pilot. Stage two of the pilot used a more recent period and this may have contributed to a reduction in the unmatched category as the operators’ data may have been more up to date. A frictionless assessment was not possible in these cases – this is favourable compared to the estimated 20 percent who would not have a frictionless assessment as set out in the 2023 Government White Paper.

  • if the proposed thresholds from the Commission’s 2023 consultation were introduced, Stage two findings lead to an estimated 0.1 percent of accounts that would both require an assessment and be unable to receive an assessment in a frictionless manner. This would mean that an operator would only be unable to meet the requirements in a frictionless way for 1 customer in every 1,000 accounts.

  • we are beginning to understand more about the financial risk profile of the customers who met the thresholds for the pilot. Two credit reference agencies shared data to indicate that the customers who met the thresholds for the pilot where they conducted assessments were more likely to have one of the direct risk flags on which operators are permitted to receive data in comparison to their separate wider UK populations. The results vary across operators with customers in the pilot cohort 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 the type of consumer in their comparison UK populations.

  • NatCen is continuing to work as our evaluation partner on this pilot and post-pilot analysis work.

Stage three of the pilot is now at reporting stage. The Commission is using Stage three and post-pilot analysis to further explore how the assessments could be targeted where there is most financial risk. We will also explore how any unnecessary inconsistency between credit reference agencies could be reduced and how operators could be supported in any future implementation.

Director of Major Policy Projects, Helen Rhodes said: “These further findings from the pilot have helped us understand the extent that assessments could be conducted in a frictionless manner.

“Building on our staged approach to the pilot, we will now further explore data consistency across credit reference agencies, as well as how to support operators to identify the severity of financial difficulties that a customer may be experiencing and how they could support these customers.”

Data-sharing for Stage three of the pilot completed on 30 April, and the Commission has moved to an analysis phase which will run into the summer period.

Last updated: 21 May 2025

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