Great Britain’s Gambling Commission has reiterated that financial risk assessments (FRAs) will be ‘frictionless for the vast majority of consumers’ amid a wave of scepticism.
Criticism of FRAs, a solution to the long-debated topic of customer affordability checks in gambling, has been particularly fierce among horse racing stakeholders.
This week, Tim Miller, the Gambling Commission’s Executive Director (pictured, main image), spoke at the Ethical Gambling Forum, an industry event hosted at Flutter Entertainment‘s Leeds headquarters. A solid portion of his speech was dedicated towards FRAs – unsurprising given the level of conservation around these measures right now.
In August 2024, the Commission began a six month pilot phase of financial risk checks. The checks had been proposed as a key measure of the Gambling Act review White Paper, published in April 2023 under the Conservative government.
Addressing the UK betting industry, Miller reasserted that the Labour government maintains the same position on FRAs as its Conservative predecessor. He also said that, based on the six month pilot in 2024-2025, “we now have more evidence that makes clear the status quo can’t hold”.
“We have found that there is a group of vulnerable customers that are not currently being identified by other approaches,” he said.
“Customers in the pilot cohort were between twice and four times more likely to have a debt management plan and between twice and five times more likely to have a default in the last 12 months than comparable consumers in the population.
“Some of these customers may be identified and supported by operators now, but too many of them are being missed.”
HKJC Chief warns of checks serving as box-ticking
FRAs are otherwise known as financial risk checks or financial vulnerability checks, but have been labelled ‘affordability checks’ by critics.
The most vocal criticisms from betting and horse racing argue the measures will be overintrusive for consumers and drive people to black market bookmakers.
While Helen Rhodes, the regulator’s Director of Major Policy Projects and Evaluation, provided a detailed update two weeks ago aiming to dispel rumours of overintrusiveness and a black market push, and Miller has now reiterated that stance, backlash has continued to persist in the industry.
Winfried Engelbrecht-Bresges, Chief Executive of the Hong Kong Jockey Club (HKJC), raised concerns over the checks serving as a “box-ticking exercise”.
He commented: “The International Federation of Horseracing Authorities (IFHA) council has provided the Gambling Commission with our findings, and it’s very clear that since you have affordability checks, the number of people who visit websites not based in Great Britain has massively increased.
“The regulators only see the local situation and some of their measures are ill-measured because you have to think about not how you are perceived when you do something, but what the consequences are.
“This measure has clearly driven more people into unregulated markets and that is a problem. Regulators have tried to do their duty and say they’ve taken action to tick a box, but there is the implication that this creates even more harmful behaviour.”
The proposals have faced a wave of ire from across the racing and betting sectors.
More than 400 industry figures recently signed an open letter to Culture Secretary Lisa Nandy, calling for the rollouts to be paused, while key organisations in the UK including the Betting and Gaming Council (BGC) and the British Horseracing Authority (BHA) have been vocal opponents of FRAs.
Conservative Shadow Minister, Nigel Huddleston, also recently told The Sun: “There is already evidence that affordability checks are not always accurate and displacing activity away from the regulated market, with clear signs of gamblers switching to offshore and illegal operators.
“Around 1.5 million Brits are already staking up to £4.3bn a year on the black market, which has grown to as much as 9% of the online sector in recent years.
“The Gambling Commission itself has acknowledged that financial risk checks risk driving consumers towards illegal operators, which is an unintended consequence that none of us desire given the increased risks to consumers and loss of funding for British sports.”
His Conservative Party colleague, Shadow Minister Louie French, also blasted the “anti-Gambling Commission”, as checks will reportedly risk costing horse racing £250m in five years.
Gambling Commission to press on
Yet it is clear that, from Miller’s comments this week and Rhodes’ update two weeks prior, the Gambling Commission is not looking to can the idea of these checks, despite Miller saying that the commission is yet to predetermine next steps.
The Commission has gained a lot of confidence from its pilot. Miller said with confidence that FRAs will be ‘frictionless for the vast majority of consumers who aren’t one of the vulnerable customers’, and that, simply, the measures will work.
Based on Gambling Commission consultations, Miller asserted that less than 3% of active accounts will trigger an FRA, then 97% of the accounts triggered would encounter a ‘frictionless’ experience.
The Gambling Commission has long asserted that only 0.1% of British bettors would ever encounter an FRA. Miller has again stated that this is the case, and is confident that this number ‘could be reduced further’ – but only if operators meet their ‘existing obligations at the start of the consumer relationship’, around identify checking for example, to the highest standard.
“We’ll be taking some recommendations on next steps to our board in the near future,” Miller continued. “Our board will want to be satisfied that there is a strong evidence base for any next steps on financial risk checks and also satisfied that the Government’s public policy approach continues to support such a change.
“But if the decision is made to introduce these assessments, we will work closely with DCMS, the industry and credit reference agencies to establish an implementation group that will jointly develop the details of a sensible implementation plan and timetable.
“It will also help shape the guidance to operators to ensure that they take a proportionate approach to interacting with customers where financial risk is identified.”
Gambling Commission slams toxicity
Nonetheless, the Gambling Commission and its assertions around the frictionlessness of FRAs continues to face criticism. Politicians, British horse racing, international horse racing, and the betting industry itself, have all weighed in to some extent, as outlined above.
The debate around betting regulation in the UK has also been exacerbated by other factors, namely the intense discussion around taxation in the run up to HM Treasury’s Autumn Budget announcement in November 2025. Miller had some choice words for the intensity of debate.
“I and others at the Gambling Commission have talked before about how if anything, the debate around gambling since the white paper has managed to get more high-pitched – more toxic – somehow,” he explained.
“The spreading of misinformation – whether its deliberate or not – is not unique to gambling and is part of the information space we all now live in. But that doesn’t mean we should accept it.”
Whilst Miller has condemned the spread of misinformation, many industry figures are slamming the spread of the black market.
And despite Miller outlining that the Gambling Commission will ‘continue to ramp up our action against the illegal market’, it will be a tough job to convince many operators and organisations alike that implementing FRAs will aid this cause…
Additional reporting by Ted Orme-Claye