UK gambling industry rejects the Gambling Commission’s Financial Risk Assessments plan

The UK Gambling Commission has set out plans to introduce Financial Risk Assessments (FRAs) for a defined group of online players with higher spending levels. For PSPs, acquirers, and operators, the catch is less the headline threshold than the operational mess underneath: data quality, customer friction, and unclear compliance expectations.

1. The assessments would kick in when a user exceeds a net deposit of about US$6,300 over a 24-hour period. Credit reference agencies will run the checks, and the Commission says the process will be “simple,” will not require document submission, and will not affect customers’ credit scores.
2. Chris Elliot, a lawyer at Wiggin Partners, called the phased rollout “pragmatic and sensible,” but said the Commission did not resolve the data inconsistencies identified during pilot testing. He noted that the regulator had already acknowledged those inconsistencies during tests last year, yet the announcement did not explain how they will be fixed.
3. Melanie Ellis, partner at Northridge Law, raised the same issue from a different angle: credit reference agency data is not necessarily stable across providers, so two agencies can produce different results for the same customer. In practice, that makes consistency a real problem, not a theoretical one.
4. Elliot also asked for more evidence behind the Commission’s claim that the measure will not reduce gross gambling revenue for operators. His point was straightforward: revenue loss may come not only from financially distressed players, but also from customers who do not want to hand over financial documents or allow bank account analysis, and who may simply reduce activity or move elsewhere.
5. Ellis said a positive sign was the Commission’s promise not to sanction operators that fail to comply during the early stages. Even so, she said more detailed guidance is still needed, and that a large part of the decision-making seems likely to remain at operator discretion. That is usually where friction turns into policy-by-casework.

The British Horseracing Authority (BHA) rejected the FRAs outright. Its CEO, Brant Dunshea, described the measure as “mass self-harm” for the sector and warned of serious financial consequences for horse racing and for the UK economy more broadly.