Report
Exploring gambler attitudes towards Financial Vulnerability and Financial Risk Check proposals
The Gambling Commission’s report on the attitudes and opinions of online gamblers regarding the proposals for financial vulnerability and financial risk checks.
4 - 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
| 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
| 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
| 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
| 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.
References
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)
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Financial Risk Assessment - Gambler attitudes towards Financial Vulnerability and Financial Risk Check proposals
Last updated: 1 May 2024
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