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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.

Published: 1 May 2024

Last updated: 1 May 2024

This version was printed or saved on: 20 July 2024

Online version: https://www.gamblingcommission.gov.uk/report/exploring-gambler-attitudes-towards-financial-vulnerability-and-financial

Executive summary

This summary contains findings from new research commissioned by the Gambling Commission, exploring online gamblers’ attitudes towards the proposed financial risk assessments and financial vulnerability checks that were consulted upon in the Summer 2023 public consultation.

The consultation sought views on 2 types of checks:

The first was putting in place a standard approach to a light-touch check to identify customers who may be particularly financially vulnerable (financial vulnerability checks). Government and the Commission proposed that these checks are conducted at £125 net loss within a rolling 30-day period or £500 within a rolling 365-day period. This would identify significant financial vulnerability such as where a customer is subject to a bankruptcy order.

The second was a more detailed financial risk assessment at unusually high loss levels where it seems proportionate to understand more about the potential risk of harm. These assessments are proposed to be informed primarily by credit reference agency data. Government and the Commission proposed that these checks apply where there are losses greater than £1,000 within a rolling 24 hours or £2,000 within 90 days. They also proposed that the triggers for enhanced assessments should be lower for those aged 18 to 24 years old.

The research has been conducted by Yonder Consulting as part of the Commission’s Consumer Voice research programme and took the form of a mixed-methodology (qualitative and quantitative) project.

Purpose and approach

The research was designed to:

Yonder designed a deliberative research approach to enable participants to reflect upon the proposed policies in an environment free from media influence where information could be explained and explored. The qualitative phase consisted of 4 focus groups (2 held in person, and 2 carried out online) and 4 in-depth interviews (a total of 28 participants) with a cross-section of online gamblers and was conducted in August 2023. The reflections from the qualitative sessions were used to inform a quantitative survey phase. Data was collected from 1,000 online gamblers in November 2023.

The findings

Overall response to the proposals

Yonder found high levels of overall support for the proposals in both the qualitative and quantitative stages, and a recognition that the proposals are necessary to protect online gamblers from harm. Despite some variation between types of online gamblers, the majority across all groups still support the proposals being implemented.

Key findings include:

Financial Vulnerability Checks

For Financial Vulnerability Checks, Yonder found broad support for the current proposals:

Financial Risk Assessments

For Financial Risk Assessments, Yonder again found broad support for the current proposals:

Research implications

Overall response to the proposals:

Introduction

Background to the policy

In April 2023, the government published its White Paper High stakes: gambling reform for the digital age (opens in new tab), which set out a plan for reform of gambling regulation following the review of the Gambling Act 2005. This included a commitment that the Gambling Commission would consult on 2 forms of financial risk check.

In line with its regulatory duties, the Commission launched a public consultation in July 2023 to gather views on a proposed set of new obligations on gambling companies to conduct checks. These checks would be to understand if a customer’s gambling is likely to be harmful in the context of their financial circumstances, in the form of financial vulnerability checks and financial risk assessments. All stakeholders, including gambling companies and members of the public, were invited to share their views on these proposals.

The Commission identified 3 key risks of gambling harm in their casework with remote gambling companies connected with financial indicators:

To tackle these risks, the Commission worked with the government, and proposed 2 checks:

Financial vulnerability checks

The first was putting in place a standard approach to a light-touch check to identify customers who may be particularly financially vulnerable. These are unintrusive checks, using publicly available data at moderate levels of spend (in the highest 20 percent of customer accounts).

Some larger gambling companies already conduct such checks for all customers at registration, and others do so at some point in the customer journey. The Commission proposed these are conducted at £125 net loss within a rolling 30-day period, or £500 within a rolling 365-day period, which the Commission estimated would reach approximately 20 percent of customer accounts and identify vulnerability such as where a customer is subject to bankruptcy orders or has a history of unpaid debts. At these moderate levels of spend, the Commission considered light-touch checks for financial vulnerabilities necessary, suitable, and proportionate.

Financial risk assessments

The second is an enhanced financial risk assessment at unusually high loss levels where the risks are greater. These assessments were proposed to be informed primarily by credit reference agency data. The Commission proposed them to apply where there are losses greater than £1,000 within a rolling 24 hours or £2,000 within 90 days. The Commission also proposed that the triggers for enhanced assessments should be lower for those aged 18 to 24 years old.

Alongside the public consultation, the Commission commissioned its own research, in the form of a mixed-methodology (quantitative and qualitative) project, to explore the attitudes of online gamblers regarding the package of proposals for financial vulnerability checks and financial risk assessments.

The research was designed to:

The views gathered through the research and expressed through the consultation responses will be used to inform the Commission’s considerations of the consultation and the potential shape and scope of financial vulnerability checks and financial risk assessments.

This report outlines findings from both the qualitative and quantitative phases of the research project commissioned by the Commission and conducted by Yonder.

Research approach

Both quantitative and qualitative approaches were used to explore the views of online gamblers, beginning with a qualitative phase where fieldwork was conducted between 16 and 22 August 2023, followed by a quantitative survey where data was collected between 9 and 14 November 2023.

Overarching principles of approach

Yonder were concerned that the volume of specialist media coverage that the Financial Risk Assessment consultation had commanded might bias response from some types of respondents, so determined that a ‘deliberative’ approach would be most suited to engage gamblers’ decision-making in a meaningful way.

Deliberative research is an approach where people consider relevant facts from multiple points of view, converse with one another to think critically about options presented, before coming to a series of collective or individual judgements.

Accordingly, Yonder developed research materials for each of the proposals (which included a clear definition of net loss thresholds, what the checks would involve and potential outcomes delivered by gambling companies from the consultation proposals) to share with online gamblers to ensure that complexity and preconception were not a barrier to eliciting informed views.

These ‘deliberative’ research materials were shared with gamblers via a slide-based presentation including but not limited to the purpose of the proposals, the detail of the proposals themselves including proposed net loss thresholds, check type, data use and validity period, and potential outcomes of checks.

For the quantitative phase the Gambling Commission created a series of short, informational videos, providing core information on the background to the checks, the types of check that were being proposed, and the types of gambler they were designed to protect. 3 videos in total were shown to respondents at various points throughout the survey. These were intended to ensure respondents’ answers were well informed.

Yonder conducted the qualitative phase first, to identify and address any challenges that gamblers had in understanding the complex nature of the proposals ahead of the quantitative survey (where miscomprehension could not be overcome by researcher and/or moderator assistance). For the purposes of reporting, the narrative has been structured to reference quantitative data first, followed by qualitative insight, to allow for deeper insight gathered in the qualitative phase to provide context to the headline quantitative figures.

Qualitative phase

A combination of 4 online focus groups (2 held in person, and 2 carried out online) and 4 online depth interviews (a total of 28 participants) were conducted with a cross-section of gamblers: younger gamblers (18 to 25 years old), financially vulnerable gamblers (defined by low income or those in receipt of benefits), gamblers with a £100 to £250 monthly deposit level, and gamblers with a £250 or more monthly deposit level.

Yonder also conducted depth interviews with higher spend gamblers making £500 or more in monthly deposits and experiencing a £500 or more single occasion net loss within the past 12 months. A spread of age, location (NB: representation throughout UK but location was skewed to Birmingham and London due to the location of the 2 face to face focus groups), demographics, and gambling activities were integrated into the qualitative sample frame.

Quantitative phase

Yonder conducted an ad hoc online survey with a sample of 1,000 online gamblers who had gambled at least once in the last 12 months, excluding those who had only gambled in-person, or only on any combination of specific activities (National Lottery, scratchcards, instant wins or ‘any other gambling’).

Respondents were recruited to be representative of the target population, using a quota-based sampling approach. Quotas were placed on 4 key demographics: age, gender, UK region, and social grade, to match the incidence of those gamblers who fit the specific criteria as occurring in the general population, and were taken from the nationally representative ‘Cost of Living’ survey. Weights were applied to the data after fieldwork (matching the quotas) to correct any imbalance that occurred due to sampling.

Limitations of this research

While Yonder took care to ensure the robustness of findings through research design, there were a number of limitations inherent to both the quantitative and qualitative phases which should be considered when reading this report.

Qualitative and Quantitative

Reported attitudes and/or behaviours: since the proposals are currently under consultation, the infrastructure was not in place to test respondents’ reactions to elements of the proposals in practice. As such, results relied on respondents’ remembered and/or claimed behaviours, and/or reactions to hypothetical scenarios, which should be considered when interpreting results. Further research conducted in a live environment is recommended to gain a deeper understanding of respondents’ reactions to the proposals.

Qualitative

Sampling: qualitative sample sizes are by their very nature small, so conclusions can only be directional, unless contextualised by quantitative data (as in this instance). For example, whilst Yonder took care to target heavier deposit and net loss gamblers, ‘professional gamblers’ were not explicitly targeted.

General limitations of qualitative research: given small sample sizes qualitative research heavily relies on the skills and experience of researchers, introducing potential researcher bias although this is mitigated by employing a grounded theory approach, where excel grids are used to capture qualitative data and notes and where narratives are developed through rigorous analysis of this data.

Quantitative

Length of survey: 15 minutes was chosen to limit respondent fatigue but resulted in inherent limitations on the amount of information provided to, and questions asked of, gamblers about the proposals. To maximise engagement and efficiency, video stimuli were used to provide overviews of the proposals, but these were reliant on gamblers’ comprehension and the amount of information they were able to absorb in the timeframe.

General limitations of quantitative research: results provide a snapshot of attitudes and opinions but provide little insight into why respondents feel the way they do, and the specific drivers behind responses. Research design included a qualitative element to allow deeper insight into the ‘why’ behind respondents’ responses. Respondents tend to be provided with pre-coded lists of responses which may not have captured the full range of responses that exist. To mitigate against this, open-ended responses were included to allow respondents to provide more detail on the reasons for their responses.

A note on reporting: for the purpose of consistency in reporting, the term ‘respondents’ has henceforth been replaced with ‘gamblers’.

Summary of findings

Financial check context

In the quantitative survey, few gamblers reported experience or awareness of having undergone financial checks prior to research (14 percent). In the qualitative research there was confusion and conflation over what a financial check might be, including age and identity checks, or even app wellbeing reminders to take a break.

Overall response to the proposals

In the quantitative research, at a total level, there was widespread agreement with the necessity of, and support for, the package of proposals (78 percent agreed the proposals are necessary, and 74 percent agreed that the proposals are something they would support being implemented). This was supported by the qualitative research, where even the more active and higher spend gamblers supported the underlying need to protect those in a financially vulnerable position through financial checks of some kind.

Financial Vulnerability Check

Proposed threshold perceptions

For the Financial Vulnerability Check the majority of survey participants agreed that the proposed thresholds are appropriate (56 percent that £125 in 30 days is appropriate, 52 percent that £500 in 12 months is appropriate). However, there was a significant proportion who felt the threshold too low (30 percent for £125 in 30 days and 31 percent for £500 in 12 months). Concern that the proposed thresholds are too low was reflected in the qualitative phase. Here, some gamblers felt that the proposed thresholds would not be targeted enough, amounting to a check on every gambler rather than those that were truly financially vulnerable. After being presented with the full proposal and frictionless nature of the proposed checks, some gamblers felt it would be better as a blanket check conducted at account opening for all customers.

Potential use of publicly available data, and perceived disruptiveness

For the Financial Vulnerability Check, there was a high proportion of acceptance (68 percent NET ‘favourable’) but also some opposition or uncertainty (11 percent NET ‘unfavourable’ and 17 percent ‘neither favourable nor unfavourable’) about the potential use of publicly available data. Similarly, when gamblers were asked about the perceived disruption of the checks, most felt they would be undisruptive (58 percent NET ‘undisruptive’), but 1 in 10 felt that they would be disruptive (11 percent NET ‘disruptive’), and a quarter could not give a firm answer (24 percent ‘neither undisruptive nor disruptive’).

Meanwhile, in the qualitative phase, whilst some gamblers felt public domain data including bankruptcy and County Court Judgments (CCJs) are a good, unobtrusive ‘first line of defence’, others were unsure that they are in fact publicly available and what their application would involve, until fully explained. There is also concern over whether this type of data would miss people who are financially vulnerable but do not have these public records.

Financial Risk Assessment

Proposed threshold perceptions

For the Financial Risk Assessment, the majority of survey participants agreed that the proposed thresholds are appropriate (51 percent for both ‘binge gambling’, £1000 in 24 hours and ‘unaffordable losses over time’, £2000 in 90 days). However, in these cases considerable proportions answered that the proposed thresholds are too high for both checks (35 percent for ‘binge gambling’, £1000 in 24 hours and 30 percent for ‘unaffordable losses over time’, £2000 in 90 days).

Qualitatively, findings suggested a more nuanced picture. Gamblers were largely comfortable with the ‘binge gambling’ proposed threshold (£1000 in 24 hours) as this felt like a concerning amount to lose in such a short time period, and clearly indicative of worrying behaviour.

However, when it came to unaffordable losses over time (£2000 in 90 days), gamblers struggled to connect with the notion of losses over such a time period (also taking into account losses in the 90 days previous). This was because they were more likely to think of their gambling, and indeed wider spending, on a weekly or calendar-month basis. So, whilst £2000 felt like a lot of money to lose it was difficult for gamblers to correlate this easily with their own spending and/or gambling.

Potential use of credit reference data and perceived disruptiveness

There was broad support in the quantitative phase for the use of credit reference agency data to perform the Financial Risk Assessment (65 percent NET ‘favourable). Yet again, however, there were considerable proportions of either uncertainty (18 percent ‘neither favourable nor unfavourable’) or direct opposition (14 percent NET ‘unfavourable’). In the qualitative phase, the use of this data was accepted and well-understood as an effective, established indicator of affordability, however there were strong concerns voiced over whether these checks would impact an individual’s credit score and whether it being performed by a gambling company would be visible anywhere on that individual’s credit record.

In terms of disruptiveness, more people believed the Financial Risk Assessment would be undisruptive (45 percent NET ‘undisruptive’) but there were higher degrees of uncertainty (29 percent ‘neither undisruptive nor disruptive’) or concern (21 percent NET ‘disruptive’) compared to the Financial Vulnerability Check. In the qualitative phase gamblers considered the use of credit reference agency data to be relatively invasive, with most voicing discomfort at this type of data being shared with a gambling company due to a lack of trust.

Perceptions of proposed lower threshold for gamblers aged 18 to 24 years old

When asked to consider whether a lower ‘net loss’ threshold was appropriate for gamblers aged 18 to 24 years old, quantitatively there was widespread support for the idea and little difference of opinion based on gambler age. However, the qualitative phase revealed some objection to the idea since those aged 18 to 24 years old were considered to have higher disposable income and less responsibility than older people. Different treatment therefore felt unnecessary. Despite these mild objections, qualitative participants were not opposed to specific protections for younger gamblers. Taken together, findings suggest that there would be widespread support for the proposed lower thresholds for this age group among the gambler population.

Difference of opinion based on gambling activity

Throughout quantitative research, a difference of opinion based on gambling activity (a higher number of active accounts or higher Problem Gambling Severity Index (PGSI) score) was observed. Those with 4 or more active accounts, or scoring 8 or more on the PGSI, were consistently more negative about the proposals. Nevertheless, results from more active and higher risk gambler groups tended to align broadly with those of the wider gambler population. For example, where a majority of the gambler population showed overall support for the package of proposals (70 percent), a majority of more active and higher risk gamblers also showed support (56 percent of those with 4 or more active accounts, and 54 percent of those scoring 8 or more on the PGSI).

In the qualitative research, where there was more time and space to immerse in details of the proposals, there was consistent acceptance across gambling activity levels. It was often those who had higher gambling activity who could more readily recognise the need for some protections to be put in place, especially if they had lost large amounts in the past themselves. Results suggest that there may be higher initial opposition to the proposals among these groups, but that if provided with adequate detail around the need, mechanics and effectiveness of proposals, these types of gamblers would display similar levels of support to the wider gambler population.

The Financial Check context

This section outlines gamblers’ prior experiences and understanding of financial checks when gambling.

In the quantitative survey, gamblers were asked whether, to the best of their knowledge, they had been required to provide details on their financial situation to a gambling company, in the last 12 months. As such, the data provided here relates to reported or claimed experience which relies on gamblers’ memories of having undergone checks and recognising the purpose of the check that they had experienced, which should be kept in mind when interpreting results.

Gamblers were only asked to consider checks on their financial situation, not checks that may have been carried out on their identity, or on where their money comes from (anti-money laundering checks). Any previous experience gamblers had with financial checks relates to checks which were not frictionless and were not mandated by the Gambling Commission. This is separate from the financial vulnerability and financial risk check proposals the Commission was consulting on, which would involve requirements not currently in place.

Among all gamblers who took part in the survey, just over 1 in 10 (14 percent) claim to have undergone checks by gambling companies on their financial situation in the last 12 months. In contrast 80 percent claim not to have undergone checks on their financial situation in the last 12 months, with a further 7 percent reporting that they ‘do not know’. These figures are shown in Table 2.1.

Table 2.1 Reported experience of financial checks (all gamblers) 1

Reported experience of financial checks (all gamblers)
Gambler response Total (percentage)
Yes 14%
No 80%
Do not know 7%

There were some subgroups within the data, based on gambling behaviour or demographic characteristics, which were statistically more likely than the overall gambler population to report undergoing financial checks in the last 12 months.

Subgroups based on gambling behaviour were:

Subgroups based on demographic characteristics were:

Table 2.2.1 and 2.2.2 show the results of these subgroups compared to the overall gambler population. All subgroup data are statistically significant compared to the total.

Table 2.2.1 Reported experience of financial checks – those answering ‘yes’ (by all gamblers) 2

Reported experience of financial checks – those answering ‘yes’ (by all gamblers)
Total Total (percentage)
All gamblers 14%

Table 2.2.2 Reported experience of financial checks – those answering ‘yes’ (by gambler subgroups) 2

Reported experience of financial checks – those answering ‘yes’ (by gambler subgroups)
Subgroup Subgroup (percentage)
PGSI Score: 3 to 7 20%
PGSI Score: 8 or more 36%
Gambling frequency: Daily 32%
Gambling activity: Any online gambling or betting in the last 4 weeks 16%
Number of active online accounts: 4 or more 28%
Age: 18 to 34 years old 20%
Income: NET £50,001 or more 17%

In the qualitative phase, gamblers were asked about their experience of ‘financial checks’ with no qualification of what this might or might not involve (unlike the quantitative phase).

Here, gamblers cited any of the following as being linked to some form of ‘financial’ scrutiny:

In both research methodologies there was a marked lack of awareness and clarity about the current checks.

Consequently, gamblers should be ‘introduced’ to the new proposals with clear information on their rationale and purpose to counter the idea that the new financial checks would be a gambling company method for delaying pay out and any further confusion surrounding the intent and suspicion of positive outcomes.

Furthermore, it would be beneficial to communicate that these checks would be as a requirement of the Commission and government for player protection purposes and are not conducted by gambling companies for commercial purposes.


1 Source: Financial Risk – Quantitative Survey: 'Thinking back over the last 12 months, to the best of your knowledge, have you been required to provide details on your financial situation to a gambling company?' Base: All gamblers (1000). Figures rounded up to whole numbers.

2 Source: Financial Risk – Quantitative Survey: 'Thinking back over the last 12 months, to the best of your knowledge, have you been required to provide details on your financial situation to a gambling company?' Base: All gamblers (1000), PGSI Score 3 to 7 (140), PGSI Score 8 or more (181), Daily gamblers (97), Any online gambling or betting in the last 4 weeks (657), 4 or more active accounts (206), 18 to 34 years old (382), NET Income £50,001 or more (279).

Overall response to the proposals

This section covers overall levels of support for, and the perceived effectiveness and disruptiveness of, both proposals as a package, and individually.

In the quantitative phase, respondents were asked the extent to which they agreed or disagreed with 4 statements (listed in Tables 3.1 and 3.2) regarding the package of proposals. In order to maximise engagement, gamblers were provided with a mixture of positive and negative statements.

Looking first at the positive statements (Table 3.1), just under 8 in 10 (78 percent) gamblers agreed that the package is necessary to protect people from gambling harm, compared to 6 percent who disagreed. While over 7 in 10 (74 percent) agreed that the package is something they would support being implemented, compared to 7 percent who disagreed.

Table 3.1 Agreement with key statements about the package of proposals (all gamblers) – positive statements 1

Agreement with key statements about the package of proposals (all gamblers) – positive statements
Gambler response Is necessary to protect people from gambling harm (percentage) Is something I would support being implemented (percentage)
NET: Agree 78% 74%
Neither agree or disagree 13% 16%
NET: Disagree 6% 7%
Do not know 2% 3%

Turning to the negative statements (Table 3.2), results suggest that over 4 in 10 (46 percent) agreed with the sentiment that the package of proposals is a proportionate response to the challenge of protecting people from gambling harm. This compares to around 2 in 10 (21 percent) who disagreed with this sentiment. Furthermore, results suggest that 6 in 10 (61 percent) agreed with the sentiment that the package is clear in its aim and/or purpose, compared to 16 percent who disagreed. While the largest share of gamblers in the survey agreed that the package is a proportionate response, or that it is clear in its aim and purpose, the proportion who do not (between 1 in 10 and 2 in 10) highlight a clear need for future communication around the proposals to address these concerns in order to build understanding and support among the gambler population.

Table 3.2 Agreement with key statements about the package of proposals (all gamblers) – negative statements 2

Agreement with key statements about the package of proposals (all gamblers) – negative statements
Gambler response Is a disproportionate response to the challenge of protecting people from gambling harm (percentage) Is unclear in its aim and/or purpose of protecting people from gambling harm (percentage)
NET: Agree 21% 16%
Neither agree or disagree 26% 20%
NET: Disagree 46% 61%
Do not know 6% 3%

On the whole, however, results suggest there was widespread agreement that the package of proposals is necessary. Clear majorities agreed that the package is necessary to protect people from gambling harm, and that the package was something they would support being implemented. Meanwhile, a further clear majority agreed that the package was clear in its aim or purpose, and the largest share of respondents agreed that the package was a proportionate response.

Subgroup analysis has revealed statistically significant differences related to gambling behaviour, with more engaged or active gamblers displaying lower levels of support compared to the overall sample. Those who have a higher number of active online gambling accounts (4 or more accounts), as shown in table 3.3, or who score highest (8 or more) on the Problem Gambling Severity Index (PGSI), as shown in table 3.4, have more negative opinions of the proposals package overall, compared to the total sample. Conversely, those who have fewer active accounts (3 or less), or who score lowest (0) on the PGSI, have more positive opinions overall compared to the total.

It is important to note, however, that although the respondents that reported more active accounts and scored higher on the PGSI were less likely to be positive about the policies, there was still greater than 50 percent support amongst those groups. Therefore, the majority (more than half) in each case agrees that the package is something they would support being implemented.

Table 3.3 Agreement with key statements about the package of proposals (by all online gamblers and number of active accounts) 3

Table 3.3.1 Statement: 'Is necessary to protect people from gambling harm' (positive statement)

Agreement with 'Is necessary to protect people from gambling harm' (positive statement) (by all gamblers and number of active accounts)
Gambler response All gamblers (percentage) 1 to 3 active accounts (percentage) 4 or more active accounts (percentage)
NET: Agree (percentage) 78% 82% 65%
Neither agree nor disagree (percentage) 13% 10% 24%
NET: Disagree (percentage) 6% 6% 8%
Do not know (percentage) 2% 2% 3%

Table 3.3.2 Statement: 'Is something I would support being implemented' (positive statement)

Agreement with 'Is something I would support being implemented' (positive statement) (by all gamblers and number of active accounts)
Gambler response All gamblers (percentage) 1 to 3 active accounts (percentage) 4 or more active accounts (percentage)
NET: Agree (percentage) 74% 78% 59%
Neither agree nor disagree (percentage) 16% 13% 27%
NET: Disagree (percentage) 7% 6% 12%
Do not know (percentage) 3% 2% 2%

Table 3.3.3 Statement: 'Is a disproportionate response to the challenge of protecting people from gambling harm' (negative statement)

Agreement with 'Is a disproportionate response to the challenge of protecting people from gambling harm' (negative statement) (by all gamblers and number of active accounts)
Gambler response All gamblers (percentage) 1 to 3 active accounts (percentage) 4 or more active accounts (percentage)
NET: Agree (percentage) 21% 19% 33%
Neither agree nor disagree (percentage) 26% 25% 29%
NET: Disagree (percentage) 46% 51% 33%
Do not know (percentage) 6% 6% 5%

Table 3.3.4 Statement: 'Is unclear in its aim and/or purpose of protecting people from gambling harm' (negative statement)

Agreement with 'Is a disproportionate response to the challenge of protecting people from gambling harm' (negative statement) (by all gamblers and number of active accounts)
Gambler response All gamblers (percentage) 1 to 3 active accounts (percentage) 4 or more active accounts (percentage)
NET: Agree (percentage) 16% 14% 26%
Neither agree nor disagree (percentage) 20% 20% 21%
NET: Disagree (percentage) 61% 64% 52%
Do not know (percentage) 3% 2% 2%

Table 3.4 Agreement with key statements about the package of proposals (by all gamblers and PGSI score) 4

Table 3.4.1 Statement: 'Is necessary to protect people from gambling harm' (positive statement)

Agreement with 'Is necessary to protect people from gambling harm' (positive statement) (by all gamblers and PGSI score)
Gambler response All gamblers (percentage) PGSI score 0 (percentage) PGSI score 8 or more (percentage)
NET: Agree (percentage) 78% 81% 70%
Neither agree nor disagree (percentage) 13% 10% 22%
NET: Disagree (percentage) 6% 6% 7%
Do not know (percentage) 2% 2% 1%

Table 3.4.2 Statement: 'Is something I would support being implemented' (positive statement)

Agreement with 'Is something I would support being implemented' (positive statement) (by all gamblers and PGSI score)
Gambler response All gamblers (percentage) PGSI score 0 (percentage) PGSI score 8 or more (percentage)
NET: Agree (percentage) 74% 77% 64%
Neither agree nor disagree (percentage) 16% 13% 26%
NET: Disagree (percentage) 7% 7% 8%
Do not know (percentage) 3% 3% 2%

Table 3.4.3 Statement: 'Is a disproportionate response to the challenge of protecting people from gambling harm' (negative statement)

Agreement with 'Is a disproportionate response to the challenge of protecting people from gambling harm' (negative statement) (by all gamblers and PGSI score)
Gambler response All gamblers (percentage) PGSI score 0 (percentage) PGSI score 8 or more (percentage)
NET: Agree (percentage) 21% 14% 42%
Neither agree nor disagree (percentage) 26% 24% 29%
NET: Disagree (percentage) 46% 56% 24%
Do not know (percentage) 6% 7% 4%

Table 3.4.4 Statement: 'Is unclear in its aim and/or purpose of protecting people from gambling harm' (negative statement)

Agreement with 'Is a disproportionate response to the challenge of protecting people from gambling harm' (negative statement) (by all gamblers and PGSI score)
Gambler response All gamblers (percentage) PGSI score 0 (percentage) PGSI score 8 or more (percentage)
NET: Agree (percentage) 16% 9% 34%
Neither agree nor disagree (percentage) 20% 17% 26%
NET: Disagree (percentage) 61% 71% 39%
Do not know (percentage) 3% 3% 2%

These levels of overall support were reflected in the qualitative phase, where responses to the proposals were consistent across customer types and levels of gambling activity, including those depositing upwards of £500 monthly and experiencing a £500 or more single occasion net loss within the past 12 months. Indeed, even in the minority of cases where there was an initial negative stance against financial checks, due to a perceived intrusion of privacy, many quickly accepted the idea of some level of protection once at-risk online gamblers, and the financial position in which they can find themselves, was considered. It was also clear that many online gamblers, especially those aged 39 years old and under, are accustomed to some kind of credit check to access services, financial or otherwise.

“I understand people can get into trouble, you can chase your losses and you can lose control, I’ll admit I’ve got into some situations and chased my tail in the past and you do need some help in those moments. I might not have appreciated it at the time because I thought the next bet would win, but looking back I wish something was there to snap me out of it and limit the damage.”
Frequent gambler, £500 or more monthly deposit amount

"At our age we're used to getting checked for everything… phone contracts, mortgages, credit cards"
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

Alongside support for the use of financial checks to protect financially vulnerable gamblers, there was limited belief that gamblers would be personally subject to the checks. A majority of gamblers in the quantitative survey did not perceive the package of proposals as being ‘relevant to [them] and [their] gambling activity’ (as shown in table 3.5, 57 percent). Whilst it is true that most gamblers would not exceed the proposed thresholds associated with the Financial Risk Assessment, greater numbers (although still in the minority, estimated at 20 percent of accounts) would exceed the lower proposed thresholds associated with the Financial Vulnerability Check. It would therefore be important to make clear that possibility to gamblers from the outset, in order to prevent possible frustration that may occur if gamblers are subject to checks they do not believe are relevant to them.

Table 3.5 Agreement with key statements about the package of proposals (all gamblers) – perceived relevance of the package of proposals 5

Agreement with key statements about the package of proposals (all gamblers) – perceived relevance of the package of proposals
Gambler response Is relevant to me and my gambling activity (percentage)
NET: Agree 22%
Neither agree or disagree 19%
NET: Disagree 57%
Do not know 2%

Results from both quantitative and qualitative phases reveal that there are high levels of overall support for the package of proposals, with only a minority feeling that the package does not constitute a proportionate response and could have greater clarity around its aim and purpose. As such, results suggest gamblers strongly agree with the principle of protecting gamblers from gambling-related financial harm with financial checks, even if they do not believe that the proposed checks would apply to or benefit themselves.


1 'Knowing what you now know about each of the proposals (both the Financial Vulnerability Check and the Financial Risk Assessment), how much do you agree or disagree with the following statements?' Base: All gamblers (1000) Figures rounded to whole numbers

2 'Knowing what you now know about each of the proposals (both the Financial Vulnerability Check and the Financial Risk Assessment), how much do you agree or disagree with the following statements?' Base: All gamblers (1000)

3 'Knowing what you now know about each of the proposals (both the Financial Vulnerability Check and the Financial Risk Assessment), how much do you agree or disagree with the following statements?' Base: All respondents (1000), Active accounts: 1 to 3 (741), Active accounts: 4 or more (206), PGSI: 0 (481), PGSI 8 or more (181)

4 'Knowing what you now know about each of the proposals (both the Financial Vulnerability Check and the Financial Risk Assessment), how much do you agree or disagree with the following statements?' Base: All respondents (1000), PGSI: 0 (481), PGSI 8 or more (181)

5 'Knowing what you now know about each of the proposals (both the Financial Vulnerability Check and the Financial Risk Assessment), how much do you agree or disagree with the following statements?' Base: All gamblers (1000)

Financial Vulnerability Check: detailed insights

This section documents gamblers’ reactions to detailed elements of the Financial Vulnerability Check proposal, including the £125 (30-day period) and £500 (365-day period) net loss thresholds, the use of publicly available data to determine risk, the 12-month duration and the validity period.

Check type and proposed thresholds

In the quantitative survey gamblers were more likely to suggest that the ‘net loss’ thresholds are appropriate as currently proposed, than to suggest they were too high or too low. Over half considered each threshold appropriate: 56 percent considered the £125 in 30 days threshold appropriate, while 52 percent considered the £500 in 365 days threshold appropriate.

However, there was a large share of gamblers for whom the proposed thresholds are too low as proposed. 3 in 10 (30 percent) answered that the £125 in 30 days threshold is too low, and a similar proportion (31 percent) answered that the £500 in 365 days threshold is too low (compared with just 5 percent and 8 percent respectively who consider them too high).

Table 4.1 Perceptions of the Financial Vulnerability Check proposed thresholds 1

Perceptions of the Financial Vulnerability Check proposed thresholds
Gambler response £125 in 30 days (percentage) £500 in 365 days (percentage)
Too high 5% 8%
The right amount 56% 52%
Too low 30% 31%
Do not know 9% 9%

This concern was strongly reflected in the qualitative phase. Most gamblers agreed that those who are financially vulnerable need protecting, but both proposed thresholds felt surprisingly low to trigger a check as they did not strike gamblers as worrying amounts of money to lose over the time periods specified – irrespective of their income or gambling spend.

For gamblers, £125 did not feel like a significant or concerning amount of money to lose over a 30-day period, and was often compared to other experiences that would not be ‘under scrutiny’, such as a dinner out or rounds of drinks at the pub. Indeed, many felt that they could easily lose this amount over this time period, as could most gamblers.

"Overall I think the figures are out of whack, I do not think they are realistic – I think it will trigger most people."
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.

The £500 in 365-day threshold caused similar concerns of being too low and not seemingly indicative of troubling behaviour or vulnerability. It was almost always viewed as £500 spread evenly over a 1-year period which is calculated as less than £42 per month.

Due to the perception of thresholds being low, this proposal is therefore seen as a ‘blunt instrument’ that would affect everyone without adequately targeting specific concerning behaviours indicative of financially vulnerable customers. This perception was prevalent, in spite of the GambleAware-funded Patterns of Play research (opens in new tab) led by NatCen, which evidenced that from 1 July 2018 to 30 June 2019, 81 percent of active accounts lost less than £200, being shared ahead of the proposal. Indeed, should the proposals continue in their current form, it was felt that the proposed figures are so universal that the proposal would be better conceived as a blanket check across all customers at either account opening or at set time increments.

However, many in the qualitative phase believed that the threshold figures should be increased. Doubling to £250 in 30 days and £1000 in 365 days felt more appropriate as amounts that should warrant a check.

"£500 in a year feels low - equates to £10 a week, that's not a lot of money. It’s difficult because the thing is, a loss of 125 pounds in a month to someone might be substantial, it might actually affect their life, but for other people, it's nothing, you know."
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.

Taken together results from the quantitative and qualitative phases suggest broad support for Financial Vulnerability Check thresholds as proposed in the consultation. However, there was also clear concern voiced by approximately one third of gamblers in both phases that the proposed thresholds for Financial Vulnerability Checks are too low and, as such, insufficiently targeted at the financially vulnerable. There is an argument, voiced by some in the qualitative phase, to reframe and refocus these as universal checks to be carried out for all customers at account setup. However, clear communication would be needed as to the rationale for setting them at this level, combined with reassurance concerning their effectiveness.

How the Check is conducted: Use of data and friction

Quantitatively, there was majority support for the consideration of a bankruptcy order or County Court Judgements (CCJs) as part of a Financial Vulnerability Check, but the data also revealed considerable minorities who either felt a sense of uncertainty, ambivalence, or indifference to the idea, or who were in direct opposition to it.

At a total level, over two thirds of gamblers (68 percent) answered that the use of this data was ‘favourable’ (scoring 4 or 5 on a 5-point scale2 ). Meanwhile, over a fifth (21 percent) answered ‘neither favourable nor unfavourable’ or ‘do not know, while 1 in 10 (11 percent) answered that they were ‘unfavourable’ (scoring 1 or 2 on a 5-point scale)’.

The proposed use of this data receives lower support from more active gamblers. Gamblers who had 4 or more active online accounts were more likely to be unfavourable towards the use of publicly available data in carrying out the Financial Vulnerability Check (17 percent, compared to 11 percent of the total sample).

Table 4.2 Favourability towards the use of publicly available data to perform a Financial Vulnerability Check (all gamblers and by number of active accounts) 3

Favourability towards the use of publicly available data to perform a Financial Vulnerability Check (all gamblers and by number of active accounts)
Gambler response Total (percentage) 1 to 3 active accounts (percentage) 4 or more active accounts (percentage)
NET: Favourable (scoring 4 or 5) 68% 71% 59%
Neither favourable nor unfavourable 17% 17% 22%
NET: Unfavourable (scoring 1 or 2) 11% 9% 17%
Do not know 4% 3% 2%

The majority of gamblers (58 percent) believed that the check would not be disruptive to gambling activity. However, there was again a considerable proportion who did not share these beliefs, or who were unable to give a firm answer: 1 in 10 (11 percent) answered that the check would be disruptive, while 3 in 10 (30 percent) selected ‘neither nor’ or ‘do not know’. Above all, this suggests there is a lack of understanding around the mechanics of how the checks would be carried out, which is understandable as checks do not currently exist in this form. It would therefore be crucial to provide such information in future communications, ahead of bringing proposed checks into operation, in order to build understanding and associated support.

Further analysis by subgroup also supported the notion that more engaged gamblers are significantly more likely to believe that the Financial Vulnerability Check would be disruptive. Around a fifth (19 percent) of those with 4 or more accounts believed that the Financial Vulnerability Check would be disruptive, compared to 11 percent of the total sample. However, it is again important to note that although the respondents that reported more active accounts were more likely to consider the Check disruptive, there was still greater than 50 percent amongst those groups (51 percent of those with 4 or more accounts) who believed the Financial Vulnerability Check would be frictionless.

Table 4.3 Perceived disruptiveness of the Financial Vulnerability Check to gambling activity (all gamblers and by number of active accounts) 2

Perceived disruptiveness of the Financial Vulnerability Check to gambling activity (all gamblers and by number of active accounts)
Gambler response Total (percentage) 1 to 3 active accounts (percentage) 4 or more active accounts (percentage)
NET: Undisruptive (scoring 4 or 5) 58% 62% 51%
Neither disruptive nor undisruptive 24% 24% 26%
NET: Disruptive (scoring 1 or 2) 11% 9% 19%
Do not know 6% 5% 3%

In the qualitative research, some believed a bankruptcy order, CCJ or similar was a good ‘first line of defence’, and that those with outstanding debts should not be gambling with money they do not have or need to put elsewhere.

Here, the qualitative phase also evidenced an appreciation of the frictionless nature of this check as it goes on in the ‘background’, utilises data from the public domain and has no impact on the individual. Indeed, for this lighter-touch proposal, being able to continue gambling and depositing funds into one’s account feels proportionate to the level of risk. Gamblers reported they would find it frustrating and ‘overkill’ for gambling or deposits to be paused mid-play at these levels.

"It's doing the check against a bankruptcy order and CCJs and stuff like that, then as you said, it's checking you are ok and if yeah, then you're good to go. So, it's checking for the really vulnerable gamblers I guess, those where they are at risk of maybe losing their home."
Frequent gambler, £500 or more monthly deposit amount

However, some gamblers find the use of this data confusing as they are unaware it is publicly available. Or question its effectiveness as a marker for financial vulnerability (since most gamblers believed that most people would exceed the thresholds) and are concerned there would be vulnerable people missed who would ‘fall through the net’.

"Using these types of data, this feels like a check for financial irresponsibility versus vulnerability."
Frequent gambler, £500 or more monthly deposit amount

Overall, quantitative, and qualitative results indicate general acceptance of the use of publicly available data to carry out the Financial Vulnerability Check, and that its use would not cause disruption to gambling activity. However, the qualitative phase revealed a degree of confusion around the types of data that would be used, and its effectiveness at identifying those who are financially vulnerable. Furthermore, support in the qualitative phase was contingent upon the checks being truly frictionless. Confusion around which data would be used, its effectiveness as a marker for financial vulnerability, and question around player friction would need to be addressed directly ahead of implementation, with clear communication around how these checks would be conducted without any disruption to play or the need for gambler co-operation.

Validity period

Results from the quantitative survey revealed agreement with the 12-month timeframe overall. Just over 6 in 10 (62 percent) responded that this timeframe is ‘the right amount of time’.

However, a noticeable proportion of gamblers (19 percent) believe the timeframe is ‘too long’, more than double the proportion of those who believe it ‘too short’ (9 percent).

Table 4.4 Perceptions of the 12-month validity period for the Financial Vulnerability Check (all gamblers) 4

Perceptions of the 12-month validity period for the Financial Vulnerability Check (all gamblers)
Gambler response Total (percentage)
Too long 19%
The right amount of time 62%
Too short 9%
Do not know 10%

Within the qualitative discussions, most felt that a 12-month timeframe was reasonable as court orders, such as bankruptcy, are not considered frequent events. However, mirroring the quantitative findings, some felt that this timeframe is too long, since much can change in 12 months for the most financially vulnerable and some expressed concern that someone vulnerable could find themselves in financial difficulty directly after passing a check and be unidentified for 11 months. As the check is in the ‘background’ and has no impact on the customer unless risk is found, some believe it should be refreshed at 6 or 3 months, or even checked at any point when the threshold is crossed.

"I'd actually change the 12 months - I think that's quite a long period actually, I think it should be shorter maybe refreshed every 3 to 6 months or something like that. A lot can change in 12 months - your personal circumstances, you could split from your partner, lose your job, go off the rails - so every 12 months does not really give that current view."
Frequent gambler, £500 or more monthly deposit amount

Results from both the quantitative and qualitative phases indicate general support for the validity period as currently proposed. Where gamblers disagreed with the period, it was more likely to be because they considered it too long than too short. Detail from the qualitative phase suggests that gamblers would be happy for this kind of check to be carried out more frequently, as long as it is carried out in the background and does not cause friction to gambling behaviour.


1 'In your opinion, does this seem too high, the right amount, or too low to identify those customers who are financially vulnerable?' Base: All gamblers (1000)

2 '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)

3 'How favourable or unfavourable would you be towards gambling companies accessing publicly available data regarding debt history to check if a customer was financially vulnerable?' Base: All gamblers (1000), Active accounts: 1 to 3 (741), Active accounts: 4 or more (206)

4 'Does the period of 12 months for a Financial Vulnerability Check staying valid seem too long, the right amount of time, or too short?' Base: All gamblers (1000)

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’:

"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

Perceptions of the £1000 in 24 hours threshold for the Financial Risk Assessment (all gamblers)
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

Perceptions of the £2000 in 90 days threshold for the Financial Risk Assessment (all gamblers)
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

Agreement with a lower ‘net loss’ threshold for those aged 18 to 24 (all gamblers and by age group)
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

Favourability towards the use of credit reference agency data to perform a Financial Risk Assessment (all gamblers and by number of active accounts)
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

Perceived disruptiveness of the Financial Risk Assessment to gambling activity (all gamblers and by number of active accounts)
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

Perceptions of the 6-month validity period for the Financial Risk Assessment (all gamblers)
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.


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)

Check outcomes

This section details gamblers’ opinions as to the perceived suitability of potential actions that may be taken by gambling companies should the proposed thresholds for financial vulnerability or risk be exceeded.

In the quantitative survey, gamblers were presented with a range of potential actions which might be taken by gambling companies, including 4 potential actions should ‘mild’ signs of vulnerability or risk be revealed, and 4 potential actions should more ‘serious’ signs be revealed. Gamblers were then asked to decide whether the actions went ‘too far’, ‘were enough’, or ‘did not go far enough’. The range of potential measures provided to gamblers was the same for both the Financial Vulnerability Check and Financial Risk Assessment. These are listed in Tables 6.1 and 6.2.

Given the absence of formal guidelines around the actions that gambling companies should take if signs of vulnerability or risk are identified, and the case-dependent nature of assessing a gambler’s vulnerability or risk profile, these questions were intended to provide an initial gauge of the kinds of interventions with which gamblers would be more or less comfortable, rather than feedback on a definitive list, and this should be kept in mind when interpreting results.

Potential outcomes for ‘mild’ signs of vulnerability or risk

In the questionnaire, gamblers were asked to consider individuals who might be showing ‘mild’ signs of vulnerability, such as unpaid debt. In terms of ‘mild’ signs of vulnerability or risk, there was widespread agreement that any of the 4 potential actions would constitute a reasonable response: between 7 in 10 and 8 in 10 (69 percent to 79 percent) answered that each would be sufficient.

However, there are some indications of the type of intervention on the part of gambling companies that would be considered inadequate in addressing signs of vulnerability or risk. When asked in relation to both a Financial Vulnerability Check and a Financial Risk Assessment, a greater proportion of gamblers said that ‘encourag[ing] a customer to set limits on their gambling’ did not go far enough (13 percent for the Financial Vulnerability Check, and 14 percent for the Financial Risk Assessment), compared to the other 3 potential actions (‘contact the customer to discuss their gambling’: 7 percent and 9 percent respectively, ‘monitor the account in case of further signs of vulnerability’: 9 percent and 10 percent respectively, and ‘direct the customer to help and support’: 9 percent and 11 percent respectively).

At the same time, there are also indications of potential actions that gamblers would consider overcautious. For example, a greater proportion of gamblers said that ‘contact[ing] the customer to discuss their gambling’ went too far (15 percent for the Financial Vulnerability Check and 16 percent for the Financial Risk Assessment compared to the other 3 potential actions (‘encourage a customer to set limits on their gambling’: 6 percent respectively, ‘monitor the account in case of further signs of vulnerability’: 7 percent respectively, and ‘direct the customer to help and support’: 7 percent and 8 percent respectively).

Table 6.1 Perceptions of the potential outcomes of a Financial Vulnerability Check (FVC) or Financial Risk Assessment (FRA) if ‘mild’ signs of vulnerability or risk are identified (all gamblers) 1

Perceptions of the potential outcomes of a Financial Vulnerability Check (FVC) or Financial Risk Assessment (FRA) if ‘mild’ signs of vulnerability or risk are identified (all gamblers)
Gambler response Monitor the account in case of further signs of vulnerability (percentage): FVC Monitor the account in case of further signs of vulnerability (percentage): FRA Contact the customer to discuss their gambling (percentage): FVC Contact the customer to discuss their gambling (percentage): FRA Encourage a customer to set limits on their gambling (deposit limits or self-exclusion) (percentage): FVC Encourage a customer to set limits on their gambling (deposit limits or self-exclusion) (percentage): FRA Direct the customer to help and support (percentage): FVC Direct the customer to help and support (percentage): FRA
Does not go far enough 9% 10% 7% 9% 13% 14% 9% 11%
Is enough 79% 77% 71% 69% 76% 76% 77% 75%
Goes too far 7% 7% 15% 16% 6% 6% 7% 8%
Do not know 5% 6% 7% 7% 5% 5% 6% 7%

Potential outcomes for ‘serious’ signs of vulnerability or risk

In the questionnaire, gamblers were asked to consider individuals who might be showing ‘serious’ signs of vulnerability, such as bankruptcy. When it came to ‘serious’ signs of vulnerability or risk, again there was widespread agreement that any of the 4 potential actions would constitute a reasonable response: between around 6 in 10 and 7 in 10 (56 percent to 71 percent) answered that each would be sufficient. However, in comparison to the ‘mild’ signs of vulnerability or risk, there was a higher degree of variation in responses, suggesting stronger opinions on what constitutes too little or too much.

There are signs of potential actions that gamblers would consider inadequate in response to ‘serious’ signs of vulnerability or risk. A quarter of gamblers (25 percent for the Financial Vulnerability Check and 27 percent for the Financial Risk Assessment) said that ‘limit[ing] the amount of advertising the customer sees’ did not go far enough, which was a statistically higher proportion than all of the other 3 potential actions (‘terminate the customer's account’: 5 percent and 6 percent respectively, ‘stop a customer gambling temporarily’: 12 percent and 13 percent respectively, ‘set a deposit or loss limit on behalf of the customer’: 16 percent respectively).

At the same time, there were also indications of where potential actions are considered overcautious. A quarter of gamblers (27 percent for the Financial Vulnerability Check and 26 percent for the Financial Risk Assessment) said that ‘terminat[ing] a customer’s account’ constituted too strong a response, a proportion that was statistically higher than for the 3 other potential actions (‘limit the amount of advertising the customer sees’: 8 percent respectively, ‘set a deposit or loss limit on behalf of the customer’: 9 percent and 8 percent respectively, ‘stop a customer gambling temporarily’: 13 percent and 12 percent respectively).

Table 6.2 Perceptions of the potential outcomes of a Financial Vulnerability Check (FVC) or Financial Risk Assessment (FRA) if 'serious’ signs of vulnerability or risk are identified (all gamblers) 2

Perceptions of the potential outcomes of a Financial Vulnerability Check (FVC) or Financial Risk Assessment (FRA) if 'serious’ signs of vulnerability or risk are identified (all gamblers)
Gambler response Set a deposit or loss limit on behalf of the customer (percentage): FVC Set a deposit or loss limit on behalf of the customer (percentage): FRA Limit the amount of advertising the customer sees (percentage): FVC Limit the amount of advertising the customer sees (percentage): FRA Stop a customer gambling temporarily (percentage): FVC Stop a customer gambling temporarily (percentage): FRA Terminate the customer's account (percentage): FVC Terminate the customer's account (percentage): FRA
Does not go far enough 16% 16% 25% 27% 12% 13% 5% 6%
Is enough 69% 71% 59% 56% 68% 69% 58% 58%
Goes too far 9% 8% 8% 8% 13% 12% 27% 26%
Do not know 5% 5% 9% 9% 7% 6% 10% 10%

In the qualitative phase, gamblers were introduced to some of the potential actions and asked to give their opinions. Overall, gamblers struggled with the lack of clarity regarding the consequences of a check.

There was a concern that this being left up to gambling companies would mean that those identified as being at risk would not be sufficiently protected and supported.

"Rubbish – why would the gambling company not HAVE to do something, why is it ambiguous? Feels like vulnerable customers are a lamb taken to slaughter."
25 to 55 years old, gamble several times a week or daily, £250 or more monthly deposit amount

"But I’m confused what it would actually do off the back – there should be definite action in place. So, we’re talking about setting deposit limits as a potential action, but is that going to be a percentage of what they normally play? How is that going to be broken down? Yeah, check. I have not got a problem with anyone checking. And if people identify me so be it, but what is not clear is what’s going to happen if they’ll identify me."
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

Quantitative results show that most online gamblers consider all the potential actions to be a reasonable response to ‘mild’ or ‘serious’ signs of vulnerability or risk. Furthermore, these results provide clear indications of the boundaries beyond which online gamblers consider a response to be either inadequate or overcautious. Overall, however, online gamblers felt that to be reassured that the proposals are effective, they require more clarity about what would happen when risks are identified, or a clear rationale for why the gambling companies should retain large amounts of discretion regarding the decision.


1 'Please indicate how suitable you think each of the proposed measures are to protect customers with signs of financial vulnerability.' Base: All gamblers (1000)

2 'Please indicate how suitable you think each of the proposed measures are to protect customers with signs of financial vulnerability.' Base: All gamblers (1000)

Research implications

Context for Financial check proposals

  1. Communication would be required to address the definition and purpose of the financial checks contained within these proposals, to build awareness and counteract confusion or uncertainty.

There is low awareness of existing Financial Vulnerability Checks having taken place. Although frictionless Financial Risk Assessments are not happening currently, there is confusion among gamblers over whether any Financial Risk Assessments are currently taking place and what they entail.

Overall response to the proposals

  1. The consumer perspective suggests that the Gambling Commission (the Commission) should continue forward with this package of proposals, as results from both quantitative and qualitative phases suggest that the proposals, as currently formulated, would receive broad support from the gambling population.

There is widespread agreement with the necessity of, and support for, the package of proposals.

Financial Vulnerability Check

  1. Due to concerns regarding its targeting effectiveness, communication would need to make clear why the proposed financial vulnerability thresholds have been chosen and how they would effectively target at-risk gamblers.

The majority of gamblers support the proposed thresholds, but a considerable proportion feel they are too low and would therefore impact most gamblers rather than at-risk gamblers specifically.

  1. Communication would be required to detail which personal data would be used and how it identifies someone who is financially vulnerable, alongside confirmation that it would not disrupt play, impact gambling activity or gamblers’ credit scores.

There was widespread support for the use of publicly available data and most gamblers did not think it would impact their gambling activity. However, there was uncertainty about what data would be used, and a concern voiced that it would miss people who were vulnerable but do not have the appropriate public records available to indicate financial risk.

Financial Risk Assessment

  1. Whilst ‘binge gambling’ and the related threshold was understood and accepted, the rationale and threshold for ‘unaffordable losses’ would require better explanation to increase acceptance, or results suggest that the time period and amounts should be adjusted to better reflect typical gambling behaviour.

In the quantitative survey, most online gamblers supported both proposed thresholds whilst a proportion felt they could be lowered. But in the qualitative phase, online gamblers struggled to relate to the ‘unaffordable losses over time’ thresholds and correlate the 90-day time period with their typical week or calendar month view of gambling.

  1. Communications would need to provide reassurance that the Financial Risk Assessment would not impact a gambler’s credit score and include specific clarification that they would be under the supervision of a third-party regulator or government for player protection purposes.

There was broad support in the quantitative phase for the use of credit reference agency data to perform the Financial Risk Assessment. However, in the qualitative phase, concerns were voiced over whether these checks would impact an individual’s credit score and/or whether it would be visible anywhere on that individual’s credit record. Similarly, more people in the quantitative survey believed the Financial Risk Assessment would be undisruptive, but strong concerns were raised in the qualitative phase about the level of intrusion required, and about sharing this data with gambling companies, towards whom there is a marked lack of trust shown by many.

Perceptions of proposed lower threshold for gamblers aged 18 to 24 years old

  1. Consumer perspective suggests that the Commission should continue forward with proposed lower thresholds for younger adults due to widespread support for increased protections for this age group among the gambling population.

There was broad support for lower thresholds for younger gamblers in both the quantitative and qualitative phases of research. In the qualitative phase, despite mild objections regarding the reasoning for the lower thresholds being younger gambler’s more vulnerable financial position, there was recognition that younger gamblers may be at greater risk due to fewer protective behaviours established whilst gambling. Framing the need for lower thresholds for this age group around these increased risks versus their financial position could help land this element of the proposals.

Difference of opinion based on gambling activity

  1. The research findings strongly evidence the need for the Commission to take time to provide adequate detail around the need, mechanics, and effectiveness of proposals to overcome initial resistance, and to encourage all types of gamblers to provide similar levels of support to the wider gambling population.

Quantitative research revealed that those with a higher number of active accounts, and/or higher scores on the Problem Gambling Severity Index (PGSI), tended to have more negative opinions of the proposals compared to the total sample of gamblers. Qualitative research revealed that, despite initial resistance, by spending time immersing gamblers in the detail of the proposals there was widespread support of them regardless of gambling behaviour.

Annex: Financial risk stimulus pack

1 Introduction

The following information is from the financial risk stimulus pack prepared by Yonder and shown to participants as part of the qualitative phase of the research. Fieldwork for the qualitative phase was conducted between 16 and 22 August 2023.

The stimulus pack provides background and contextual information relative to the proposals, enabling participants to reflect upon proposed policies in an environment free from media influence. Within the pack, key terms and proposed thresholds are explained and explored. The pack also includes example scenarios to help participants understand how proposed checks would be conducted.

2 Background to the proposals

Some background: where all this is coming from

The government and the gambling regulator want to 'protect the most vulnerable while also allowing everyone else to enjoy gambling without harm'.

They have seen cases where very significant gambling losses took place without any checks.

Therefore, the government have decided some checks are necessary to identify consumers who may be harmed by gambling.

Overview of the consultation and why we are here today

To take forward the government decision that checks are necessary, the gambling regulator has proposed a new targeted system of financial risk checks.

The proposals have been designed to be proportionate to the risk of harm and as frictionless as possible for consumers.

The gambling regulator is consulting on how these checks could work and want your views.

Some of the details can change at the end of the consultation.

The proposals have been designed to tackle 3 key risks of gambling harm, that have been identified by the gambling regulator though their casework, these are:

  1. Financially vulnerable customers
  2. Binge gambling
  3. Significant unaffordable losses over time.

Overview of gambling activity in the UK

Some further context for these proposals is the reality that 'most online gamblers have relatively modest losses’.

This is confirmed in a published report (opens in new tab) of customer account data which found that between July 2018 and July 2019:

These figures have been taken into account in the design of the proposals.

3 Financial vulnerability checks

A basic check using publicly available data to identify significant red flags of financial vulnerability (for example, bankruptcy).

These checks would be conducted when a customer's net loss is more than:

(‘Net loss’ is the loss of deposited money with a particular operator, in the defined timeframe.)

Gambling and deposits may continue while the check takes place.

The customer would not need to provide any information to the gambling operator to support these checks but would be informed.

It would use publicly available data to see if someone is subject to one of the following orders, regarding a history of unpaid debts such as a bankruptcy order or a County Court Judgment (CCJ).

Once completed, it will be valid for the next 12 months, and not need to be repeated unless thresholds were crossed again after the 12 months.

What happens off the back of a check?

For most people who have the check – no risk is identified, and nothing happens at all.

If there are risk flags such as a bankruptcy order, the operator might contact you to discuss and encourage you to set a limit, or if there are serious risk flags, they might set a deposit limit.

What does ‘net loss’ mean?

Net loss is the loss of deposited money with a particular operator, in a defined timeframe:

An example of net loss during a betting period

An example of net loss during a betting period
Activity Winnings Account balance
Deposit £50 £0 £50
Bet (evens) £25 £25 (plus stake returned) £75
Bet (evens) £40 £0 lost bet £35
Bet (evens) £10 £10 (plus stake returned) £45
Bet (evens) £25 £0 lost bet £20

Net loss during betting period: £30

What does the check involve?

Publicly available data will be used to assess if someone is particularly financially vulnerable.

The check will look to see if someone is subject to one of the following orders, regarding a history of unpaid debts:

Scenario 1

Alice enjoys playing online slot games. She tends to play a few times a week, depositing small amounts in her account each time. She has been up and down, with some wins and losses, but overall has not had the best month, and one weekend she gets to the threshold of losing over £125 in a 30-day period.

Because she has passed the threshold, Alice’s online gambling provider has been triggered to conduct a financial vulnerability check. Alice’s gambling provider uses publicly available data to assess if she is financially vulnerable (for example, checks there are no active bankruptcy orders against her). Alice can continue gambling and deposit additional funds into her account whilst the check is taking place.

It turns out Alice’s check is fine, nothing further happens and she will not have to have another check unless she reaches the thresholds again after 12 months have passed.

Scenario 2

Sam places a series of online bets every weekend on the football. He deposits £15 each weekend, and stakes that amount over various different matches. Whilst he has some wins, he mainly has a series of losses whilst his team are not performing well in the league. He ends up losing a total of £520 in 6 months.

Because he has lost over £500 in a 365-day period, Sam’s online gambling provider has been triggered to conduct a financial vulnerability check.

Sam’s gambling provider uses publicly available data to assess if he is financially vulnerable (for example, checks there are no active bankruptcy orders against him).

Sam is able to continue gambling and deposit additional funds into his account whist the check is taking place.

It turns out Sam’s check is fine, nothing further happens and he will not have to have another check unless he reaches the thresholds again after 12 months have passed.

Financial vulnerable customers

An example of where current practices and/or regulation has missed identifying a customer who was at risk due to being financially vulnerable:

There was an individual who never bet more than £50 with an average stake of £8.01, which may seem like a relatively low amount.

However, this gambling was allowed to continue after there were instances of unpaid debt and bankruptcy.

This continued gambling worsened financial issues for this customer at a particularly vulnerable point. 

4 Financial risk assessments

A standard approach for providers to conduct a financial risk assessment for a customer who has lost an unusually high amount over a short period, or over a sustained period, and to inform the action that might take place as a result.

This assessment would occur when a customer’s net loss is more than:

‘Net loss’ would take into account the preceding position of a customer immediately

These assessments would be informed by credit reference data such as a credit check, but this kind of check will not leave a trace or impact your credit score.

Once a check has been completed, it will be valid for the next 6 months and not need to be repeated unless thresholds were crossed again after the 6 months.

What happens following an assessment?

The assessment findings would form part of an operator's risk assessment alongside other known information, including the customer's gambling patterns.

In many cases no risk is identified, and nothing happens at all.

If there are risk flags, the operator might contact you to discuss and encourage you to set a limit, or if there are serious risk flags, they might set a deposit limit.

Taking into account previous winnings

‘Net loss’ may also take into account the position of a customer in a time period immediately before the relevant time period:

Example

A customer places £400 on online slots and wins £5,000 (including initial stake). A few days later, the Cheltenham Festival begins, where they stake and lose a £1,000 during a 24 hour period.

Although in that 24 hour period the net loss is £1,000, the customer still has a net positive position of £3,600 over the week, and this would not therefore trigger a financial risk assessment.

However, if the customer had won £5000 more than 7 days before the Cheltenham festival, the previous winnings would not be taken into account and their £1000 loss would have triggered a financial assessment.

What does an assessment involve?

To conduct a financial risk assessment, gambling operators must gather data, or a risk assessment from a credit-reference provider, for example Experian, which includes:

This kind of check will not impact your credit score.

If the above is not possible (it would be in over 90 percent of cases), gambling operators must gather information about the customer’s income and expenditure to help support their understanding of financial risk. This will be done through:

How can operators use your data?

Gambling operators must be transparent and inform all customers that they will gather information from third parties to support their understanding of financial risk.

Gambling operators must only use data obtained for financial risk assessments to evaluate the risk to the customer and decide what action to take – it must not be used for any other purpose, for example targeted marketing.

Your gambling data would not be shared with credit reference agencies or financial sector organisations, such as your bank.

Scenario 1

John receives an offer for free spins on a particular game from his favourite online gambling account. That evening, he deposits £50 to qualify for the offer. John spends an hour playing slots at 50p per spin, sometimes winning small amounts. Eventually his balance decreases to £0.

Having enjoyed the feeling of winning, John deposits a further £100 to play a familiar game. After 3 sizeable wins, his balance is £1200. Feeling confident of a really big win, John increases his stake to £5 per spin and despite occasional successes, has soon reduced his balance to £0 again. Chasing his losses, John deposits a further £250, which he loses.

Switching games, he deposits £700 and loses a further £600 that evening which triggers the £1000 threshold in a 24 hour period. John’s gambling operator requests a risk assessment from a credit-reference provider. John can continue gambling on his account but is not able to deposit any more funds until the assessment is complete.

It turns out John’s assessment is fine and he can resume as normal, he will not have to have another check unless he reaches the thresholds again after 6 months have passed.

Scenario 2

Pete loves the races and when he cannot go to an event in person, he follows along online and places bets through his favourite online gambling provider. He is used to riding ups and downs, but recently his losses are outweighing his wins most weeks, and he is gradually depositing and losing more and more. Trying to get back up, he ends up losing over £2000 in 2 months.

Because he lost over £2000 in a 90-day period, Pete’s online gambling provider has been triggered to conduct a financial risk assessment. Pete’s gambling operator requests a risk assessment from a credit-reference provider. Pete is able to continue gambling on his account, but is not able to deposit any more funds until the assessment is complete.

Turns out Pete’s assessment is fine, and he can resume as normal, he will not have to have another check unless he reaches the thresholds again after 6 months have passed.

Binge gambling

The following example details an occasion where current practices and/or regulation has missed identifying a customer who was at risk through binge gambling:

A customer lost £36,000 in 4 days without appropriate financial risk assessment being carried out.

This is above the disposable income the Office for National Statistics estimates was available to the median household for an entire year in 2021 (£31,400).

As such, the rate and level of spending would have been unaffordable for most UK households, and likely to indicate harm.

Significant unaffordable losses over time

An example of where current practices and/or regulation has missed identifying a customer who was at risk from significant unaffordable losses over time:

A customer lost approximately £33,000 in 3 months without the operator carrying out any financial risk assessment.

Compliance staff subsequently examined the information held by the operator on this customer, which suggested they had an annual income of £8,500.

This suggests that, if the operator had assessed the customer’s financial circumstances earlier and more effectively, they could have acted to reduce the extent of financial harm suffered.

5 Financial risk assessments: Thresholds for young adults

There are proposed lower net loss thresholds for young adults (18 to 24 years old). The thresholds for customers who are aged 24 years old and under are:

For customers 25 years old and over, the thresholds are:

Why are there enhanced protections for young adults?

Young adults are more vulnerable to gambling harm as they are more likely to have lower levels of financial resources (for example economic independence for the first time), have limited gambling experience and lower motivation to adopt protective behaviours. Young adults are also more likely to have more accounts.

Therefore, to ensure that potential harm does not go undetected by gambling operators, it is recommended that thresholds are set at a lower level for customers 24 years old and under.

6 What the press says about the financial checks

Objections to the new financial checks in the racing press

Headlines from the articles shown to gamblers:

Punters could face affordability checks every six months under new proposals triggered by white paper (opens in new tab)

MP urges racing to make its case against ‘crippling’ Gambling Commission proposals (opens in new tab)

I don’t need to be told how much I can bet (opens in new tab)

‘I don’t think they truly understand a lot of betting’ - concerns raised over Gambling Commission consultation (opens in new tab)

The Gambling commission is waging a war on punters, and this is our last chance to fight back (opens in new tab)

Arguments in the press that changes have been needed much sooner and that thresholds should be lower

Headlines from the articles shown to gamblers:

Gambling addicts will die because of delay to reforms, government warned (opens in new tab)

Gambling white paper not perfect, but a tipping point (opens in new tab)

I run the NHS gambling clinics. The white paper doesn’t go nearly far enough (opens in new tab)

‘There will be more people dying’: mother whose daughter took own life criticises gambling white paper (opens in new tab)