The Gambling Commission-Launched 'Affordability' Checks Are Far From That

07 October 2026

The Gambling Commission has launched a consultation on mandatory "affordability" checks for online betting accounts, but the policy is far from a blanket income test.

The two-tier system

The regulator is proposing includes light-touch vulnerability checks at moderate spend levels, with more detailed assessments for high-spending customers. These are called "financial risk checks", not blanket affordability caps.

The government's white paper High Stakes: Gambling Reform for the Digital Age, published in April 2023, proposed two forms of financial risk check: background checks at moderate spend levels and enhanced checks at higher spend levels. The proposed threshold for background checks was £500 net loss within a year or £125 a month.

The proposed threshold for enhanced financial risk assessments was £1,000 net loss within 24 hours or £2,000 within 90 days.

The white paper estimated that the enhanced checks would affect 3% of online gambling accounts. It also proposed that these checks should be frictionless for customers and conducted online, by credit reference agencies or, where needed, through open banking.

In August 2023, the Gambling Commission said the pilot would test how credit reference data could support financially vulnerable high-spending customers and inform a final decision on whether to introduce these assessments. Previously, in February 2023, the regulator stated that financial vulnerability checks would be mandatory at £150 net deposits per rolling 30 days, when introduced in August 2024.

The consultation also laid out how these financial risk checks would work.

The Commission made it clear that the aim was not to put a universal cap on gambling spend. The checks would be frictionless for the vast majority of customers, using publicly available information for low-level screening and credit reference data for higher-risk assessments. Customers would only be asked to provide documents like payslips or bank statements in a small minority of cases, and even then most would not need to.

As the regulator has repeatedly emphasised, the key concern is not just the size of a customer's income but how much risk they are taking relative to their financial circumstances. Someone on a high income is still vulnerable if gambling a large proportion of it.

The light-touch vulnerability checks would look for indicators like County Court Judgments and bankruptcy. But the enhanced financial risk assessments, affecting a small proportion of accounts, would look at a more detailed picture of the customer's financial situation.

Over in Washington, DC, I asked Al Salisbury, the CEO of the American Gaming Association, his thoughts. "We're all watching how this develops in the UK with great interest. Anything that's going to help prevent gambling harm is a good thing. But it's got to be done carefully. If you implement checks in a way that frustrates the vast majority just to catch a tiny few, you won't be doing anyone any favours."

The consultation on the Gambling Commission's proposed mandatory financial risk checks for online customers closes on 14 March 2023. After that, there will be a final decision on whether to implement these assessments.