Paddy Power Betfair Findings
A Commission compliance assessment and subsequent regulatory review found:
Failure to comply with paragraphs 1, 4, 7, 8 and 11 of SRCP 3.4.3
Compliance with a SRCP is a condition of the licences by virtue of section 82(1) of the Act.
The review found that, in various periods between August 2023 and May 2024, the Licensees failed to comply with the following requirements relating to remote customer interaction.
SRCP 3.4.3 paragraph 1 which requires that:
"Licensees must implement effective customer interaction systems and processes in a way which minimises the risk of customers experiencing harms associated with gambling. These systems and processes must embed the three elements of customer interaction – identify, act and evaluate – and which reflect that customer interaction is an ongoing process as explained in the Commission’s guidance (see paragraph 2)."
The Licensees had not always ensured that their policies, procedures and controls had been effectively implemented.
The review found that the systems the Licensees had in place were not sensitive enough to identify multiple indicators of harm in all instances. There are clear customer examples of where the systems were not sensitive enough to identify instances of:
- overnight play
- velocity of deposits / exhausting limits.
Customer examples showed that they should have been elevated for a review earlier in the customer journey to enable the Licensees to act more quickly. One customer deposited £12,000 on Betfair in 15 days before being identified for manual review and a two-way interaction being performed, and another customer also on Betfair deposited £25,000 in 25 days before being identified and interacted with.
SRCP 3.4.3 paragraph 4 which requires that:
"Licensees must have in place effective systems and processes to monitor customer activity to identify harm or potential harm associated with gambling, from the point when an account is opened."
During the Compliance Assessment, Commission Officials recognised that the Licensees had several systems in place to identify markers of harm. However, customer examples demonstrated that the velocity of spend, increasing deposits, overnight gambling, and changing betting patterns did not appear to be identified by the Licensees or acted upon until the next day.
One customer lost £12,300 in five weeks on Betfair before being identified for an interaction. On hitting the trigger, an interaction was attempted but was unsuccessful, therefore the Licensees placed a £500 monthly deposit limit on the account but allowed the customer to continue to gamble. The Licensees should have considered if stronger action was needed on hitting the trigger, such as preventing the customer from further depositing until an interaction had taken place.
SRCP 3.4.3 paragraph 7 which requires that:
"A licensee’s systems and processes for customer interaction must flag indicators of risk of harm in a timely manner for manual intervention, and feed into automated processes as required by paragraph 11."
During the Compliance Assessment and as part of the investigation we found that the Licensees were not compliant with paragraph 7. The Licensees’ system and process for customer interaction did not flag some indicators of risk of harm in a timely manner for manual intervention and did not feed into automated processes.
The review identified the issue in the following customer examples:
- a customer staked £86,000 on Betfair between 18 November and 4 December 2023, losing £6,000 during that 16-day period. Despite this high velocity spend, no manual review of the account took place, and the customer only received four automated interactions during this time.
- a customer displayed concerning behaviour on Betfair in that they showed intense spikes in activity (volume / staked amount) but were not interacted with. Their longest session throughout a 17-day period was 7 hours and 46 minutes, during which the customer placed 300+ bets amounting to £20,000. This behaviour was only identified as an indicator of harm when the customer hit a loss trigger, and the account was manually reviewed.
SRCP 3.4.3 paragraph 8 which requires that:
"Licensees must take appropriate action in a timely manner when they have identified the risk of harm."
During the Compliance Assessment and as part of the investigation, we found that, in some instances, the Licensees failed to take appropriate action in a timely manner after identifying behaviours that can be associated with the risk of gambling related harm. Whilst triggers were activated, they were nearly always the day after the gambling session had finished, and no tailored action took place swiftly if indicators were at higher levels.
SRCP 3.4.3 paragraph 11 which requires that:
"Licensees must ensure that strong indicators of harm, as defined within the licensee’s processes, are acted on in a timely manner by implementing automated processes. Where such automated processes are applied, the licensee must manually review their operation in each individual customer’s case, and the licensee must allow the customer the opportunity to contest any automated decision which affects them."
We found during the Compliance Assessment and as part of the investigation that customers were spending large amounts overnight which led us to conclude that the action taken was not sufficiently timely. Commission Officials are of the view that the Licensees did not consider escalation of automated actions; for example, when a customer exhibited high velocity of spend or was gambling regularly for long periods overnight, there was no consideration of an immediate block until a manual interaction took place.
Previous pagePaddy Power Betfair Executive Summary Next page
Paddy Power Betfair Regulatory settlement
Last updated: 17 December 2025
Show updates to this content
No changes to show.