Industry stakeholders from all angles have come out this week to condemn the Gambling Commission’s announcement that it is ready to impose Financial Risk Assessments (FRAs) on gambling operators in the UK.
Journalists were told by the Commission in a meeting on Tuesday morning that it was ready to take a “carefully thought-out staged application” of FRAs.
The first phase of the FRA programme will apply to the “largest operators” focused on the assessment of high spend customers with a check set of £5,000 net deposits accumulated over a 24-hour period.
But many across the UK, from punters to operators and law firms to horse racing enthusiasts, have slammed the Commission’s decision to go ahead with this.
A judicial review of FRA implementation?
Sophie Kemp, Partner and Head of Public Law at London-based law firm Kingsley Napley, told SBC News that she believes that “there may be strong grounds for bringing a judicial review challenge” about the approach.
“Many in the industry view the Gambling Commission’s decision to proceed with affordability checks as rushed, flawed and hugely problematic,” she said.
“They have repeatedly warned about the shortcomings of the Government’s approach and the damage it will do with negative consequences for operators as well as individual bettors. However, it seems the Gambling Commission is progressing with the plan regardless.
“Whilst the Commission claims to be satisfied with its pilot, we have yet to see the full details of its consultation response expected in the Autumn and critically its answers to important concerns such as the reliability of credit reference data, customer friction, and the risk of driving customers to unregulated black‑market operators.
“This is absolutely too significant a policy change to introduce without a thorough assessment of the likely impact on gambling operators and customers alike. Hence we believe there may be strong grounds for bringing a judicial review challenge about the Gambling Commission’s misguided approach and will be looking into this question.”
The argument regarding the Commission not releasing the full evidence of its consultation response has been one that has been brought up plenty of times since the decision was announced.
There was not exactly a full reason given by the regulator when questioned on this, citing “commercially sensitive information” and saying that more information will be released in the coming months.
Helen Rhodes, Director of Major Policy Projects and Evaluation at the Gambling Commission, responded by saying: “We have released a great deal of the information from the pilot, for example, we’ve linked all the information about the level of financial risk in the pilot that was identified, and which showed that high spending customers are between two and four times more likely to have a debt management plan and two and five times more likely to have arrears and defaults. This is quite significant levels of financial difficulties.
“We published all the information about the frictionless rates and we will also release more information as part of our consultation response in the autumn.
“However, there is some commercially sensitive information that is specific to individual credit reference agencies and specific to individual gambling businesses, so the information that we release alongside the response document will have some summarising in order to protect the commercial sensitivity of those organisations and not allow competitive advantage between them.
“But as I say, a great deal of the evidence is already in the public.”
“Balance is needed” as racing-focused operators suffer
Flynn Goward, Managing Director at independent bookmaker Star Sports, told SBC News that the Commission’s decision was difficult for licensed operators already facing rising costs following tax increases announced in the Autumn Budget.
As a mid-tier UK operator with a strong horse racing focus, Star Sports may well be one of many bookmakers feeling the brunt of this decision more than the traditional big players within the industry.
Industry analysts and trade bodies widely agree that FRAs will disproportionately impact smaller gambling operators compared to industry giants.
Smaller bookmakers typically rely more heavily on a smaller pool of high-value bettors who generate the majority of their revenue, something which may become even more of a rarity when FRAs reach their final stage.
Goward argued that previous increased regulation and taxation, such as the remote gaming duty tax increase to 40%, inevitably reduced customer value through all kinds of measures.
“Over regulation and increased taxation inspires a business to win at a bigger margin – which could be argued increases problem gambling, given the punters will lose a bigger percentage in the pound,” he said.
“I appreciate this doesn’t sound idyllic to a lot of people, but it’s the very nature of running a business by reacting to the cost of doing so.”
The bookmaker already supports protecting vulnerable customers, but Goward became the latest to question whether the new affordability regime would deliver the ‘frictionless’ experience promised, noting operators would still need to request financial documents to satisfy anti-money laundering (AML) obligations.
Goward continued: “We understand the need to look after the most vulnerable customers and appreciate that punters don’t want to go through intrusive checks. But ultimately, even with these ‘frictionless’ affordability checks, punters will still face operators asking them for documents to satisfy AML requirements…
“Once a bookmaker has a bank statement which was obtained due to AML requirements, we have to use said bank statement to assess affordability. If you have the information to hand, you must use it.”
Goward added that operators already conduct Financial Vulnerability Checks and maintain dedicated Player Safety teams to identify and intervene where customers display markers of harm.
He concluded: “At some stage, there needs to be a realisation that balance is needed. We need a level of regulation that matches common sense…
“In my view, a further affordability check on top of the above, is too much, coupled with the fact that the overall customer experience will not be frictionless.”
Leading racehorse trainer John Gosden also criticised the Commission, arguing it lacked the necessary understanding of either racing or gambling.
He told Racing TV: “Their qualification is to have absolutely no experience of our industry or the gambling industry, and they’ve made this bizarre rule, which will create criminality, and which will cause someone wanting to have a bet to go to the black market. If someone wants to have a bet, you’re not going to stop them.
“They’ll just go to the black market, which is terrible for the industry, terrible for the government, due to them getting no return, but also [there’s] no protection for the person having a bet.”
Gosden described the policy as “the most ridiculous” he had seen and suggested ministers had allowed an unelected regulator to dictate gambling policy without adequate parliamentary oversight.
Strong words from John Gosden
pic.twitter.com/qupog4clh1
— Racing TV (@RacingTV) July 9, 2026
Political figures and industry bodies up in arms
Shadow Gambling Minister Louie French, a member of the opposition Conservative party, accused the Commission of ignoring widespread opposition to the policy.
He said: “This is a really disappointing announcement. MPs have raised a variety of concerns, and so have British horse racing. We’re all deeply concerned about the impact that this decision will have on racing.
“It’s been discussed here in a debate in Parliament. [I’m] deeply concerned, and we think the government must take control of the Gambling Commission. This is a dereliction of duty, as far as I’m concerned.”
French argued that Parliament, rather than the regulator, should determine policy of this significance, calling for the issue to be brought back before MPs for full debate, given its potential impact on both consumers and British sport.
Betting and Gaming Council (BGC) Chief Executive, Grainne Hurst, a long-time opponent of the implementation of FRAs, said the industry remained “deeply disappointed and frustrated” by the Commission’s decision to proceed despite concerns raised over the past 18 months.
Hurst has been one of the most significant voices in the fight against both the introduction of FRAs and the threat of the UK’s black market.
“We are deeply disappointed and frustrated that the Gambling Commission has decided to press ahead with FRAs despite the significant concerns raised over the last 18 months by the BGC, operators, racing, parliamentarians and customers,” she said.
She said changes to the rollout timetable and thresholds demonstrated the Commission had recognised many of those concerns, but argued key issues remained unresolved.
“The fact that the Gambling Commission has delayed implementation, raised thresholds and abandoned its original timetable is a clear recognition that the concerns raised by the BGC and others were well founded,” Hurst added.
“Unfortunately, the central issues around reliability, consumer impact and the practical operation of these checks remain unresolved.
“The Commission has failed to address the fundamental issues identified during its own pilot. It has not demonstrated that the data underpinning these checks is accurate, reliable or consistent enough to support regulatory decisions affecting customers.”
She also argued the checks could not be described as genuinely frictionless if they resulted in customers being restricted or asked to submit additional financial information, warning once more that unresolved problems risked driving bettors towards illegal gambling operators.
British Horseracing Authority (BHA) Chief Executive, Brant Dunshea, said racing had consistently warned ministers about the unintended consequences of the policy.
“We are hugely disappointed that the Gambling Commission will implement affordability checks which will have severe financial implications for British racing and the UK economy and subject racing bettors to unwarranted levels of intrusion,” he said.
Dunshea said concerns raised by racing had been echoed by politicians, campaigners and the betting industry, while arguing the Commission’s own pilot had shown the checks were not fully frictionless.
He mirrored the opinion of many in saying that the policy risks pushing consumers towards the black market, reducing tax revenues and damaging two industries that contribute billions of pounds to the UK economy and support more than 200,000 jobs.
The Department for Culture, Media and Sport (DCMS) was also in Dunshea’s firing line, with him stating that the FRA decision shows “how little the DCMS has done for the country’s second-favourite sport”.
Echoing French’s viewpoint, and perhaps further positioning the Conservatives as an ally of racing in 2026, Dunshea reiterated that a policy of this scale should have been debated in Parliament rather than introduced solely through the Gambling Commission.
Dunshea also expressed concern that stakeholders had not been allowed to review key evidence from the Commission’s pilot before implementation, including the independent NatCen evaluation, and said inconsistencies between Credit Reference Agencies remained unresolved.
Despite opposing the policy, he said racing would continue working with the Commission, DCMS and betting operators to minimise the “deeply unpopular policy’s” impact.
“We would like to thank racing supporters for time and again lending their voice to campaigns against this deeply unpopular policy… We will now seek to work with the DCMS, the Gambling Commission and the betting industry to find ways to mitigate the worst impacts of this policy,” he said.
Commission creates racing and betting’s biggest concern to date?
It seems there is one way traffic for the Commission. Many oppose FRAs and this has been seen in an outpouring of vitriol from a plethora of industry figures.
Concerns for the horse racing and betting industries in the UK were already somewhat peaking, but this introduction of FRAs may just represent the biggest crisis for the two sectors yet.
Stephen Power, a horse racing content creator who has amassed a following of over 234,000 people on X, simply said: “The black market boys are popping champagne open as we speak.
“A grim day for the future of horse racing in Britain. Sponsorship, investment, fan engagement will all suffer, causing the sport to lose in every department.”