On 16 April 2026, the Gambling Commission released a post-Pilot update on the Financial Risk Assessments Pilot (“the Pilot”). In this blog, we consider the Gambling Commission’s findings from the final stage of the Pilot.  

Background

The Gambling Commission has been reviewing the results of last year’s financial risk assessments Pilot, and assessing whether the model could meet the aims set out in the 2023 Gambling Act Review White Paper and operate as a practical way of identifying high-spending customers who are in current financial difficulty.

Currently, operators take different approaches to identifying financial difficulties and the information they use to do so. Some operators request documents where this may not be necessary, while others fail to identify and support customers showing signs of financial risk. Financial risk assessments were therefore identified as a more consistent and frictionless means of identifying financial difficulty.

The Gambling Commission says that some commentary on the proposal has been “ill-informed or inaccurate”, including suggestions that consumers are currently being driven to illegal operators as a result of financial risk assessments. The Gambling Commission notes that these checks are not yet in force and no customer has had action taken on the basis of one. Further, they confirm that the proposal does not involve introducing spending caps or limits, and instead, the proposed threshold would act as trigger to check on whether that customer is in financial difficulties.

Financial Risk Assessments and the Pilot

The Gambling Commission summarised financial risk assessments as:

• A way of identifying high-spending remote gambling customers who may be in financial difficulties.
• Not an “affordability check”.
• A targeted and proportionate way of identifying customers who are in current significant or imminently worsening financial difficulties by flagging customers who are, for example, in significant or multiple arrears, defaults or bankruptcy.
• Triggered automatically when certain spend thresholds are met.
• An assessment made based on data held by credit reference agencies which, for the vast majority of people, would happen behind the scenes.

The purpose of the Pilot was to test whether, and how, financial risk assessments could be introduced to support customers in financial difficulties without adding unnecessary friction to the customer journey. You can read more about the background of the Pilot in our stage 1 and stage 2 blogs.

Current Position and Findings

The Gambling Commission states that the Pilot produced encouraging results in terms of speed and frictionless assessments, and it has been investigating into the practical issues that were raised by businesses during the Pilot.

The Gambling Commission is collating its findings to inform decisions on whether and how to introduce financial risk assessments, and set out the following outcomes and commentary:

• Based on the White Paper and the consultation proposals, fewer than 3% of active customer accounts would trigger any operator action under the proposed model.
• Of the 3%, the Pilot found that around 97% would be assessed through a frictionless process, without the customer needing to provide documents or take any action. This represents an improvement on the White Paper’s estimate that 80 per cent of assessments would be frictionless.
• The White Paper had also estimated that approximately 0.6% of active accounts would both trigger an assessment and be unable to be assessed frictionlessly. However, the Pilot suggests that the figure may in fact be closer to 0.1%. Based on these estimates, operators would only be unable to carry out a frictionless assessment for around 1 in every 1,000 accounts across the remote sector.
• The Pilot also showed that better identity and age verification by operators would significantly improve their own frictionless rate. Some operators still allow account details that do not support proper verification, such as allowing customers to register with an initial instead of a full name or using a commercial address, which does not deliver age or identify verification properly. Fixing these cases will support frictionless customer journeys later on. The Gambling Commission will publish further material to assist.
• The Gambling Commission recognises operators’ concerns that the customers most likely to fall within scope are often high-spending customers, meaning the practical impact may be more significant than the headline percentages alone suggest. This is an important consideration and any ongoing evaluation will need to assess whether the forms of support used are effective in helping customers gamble sustainably, rather than simply causing them to shift to land-based gambling, other operators or to the illegal market.
• The Gambling Commission notes that some operators say the real friction may arise after a risk indicator is identified. Its response is that this is the point of the policy, which is not just to identify financially vulnerable customers, but to ensure support follows.
• Customers in the Pilot cohort were found to be more likely to have debt management plans and recent defaults in the last 12 months, comparable consumers in the population. Some of these customers are being supported by operators now, but not all. The Gambling Commission recommends that support could include steps such as deposit limits or reduced marketing, but does not want operators to respond by routinely demanding bank statements or automatically closing accounts as the Gambling Commission wants better outcomes for consumers and not for them to be unnecessarily pushed out of the licensed market by a risk averse response to indicators of risk.
• The Gambling Commission recognises that differences between credit reference agencies and the consistency of their data remain an issue but says the Pilot has provided useful evidence on those variations which can help inform practical steps if financial risk assessments are implemented.

The findings from the Pilot will be presented to the Gambling Commission Board for consideration of next steps, although it is stressed that no final decision has yet been taken.

“Despite the success of the pilot in informing those considerations, no one should pre-judge what comes next”

If the proposal is taken forward, it will work with operators and credit reference agencies on a sensible implementation plan, while being mindful of the risk of over-implementation or unnecessarily rapid implementation creating friction for consumers. Guidance will also be developed to help operators take a proportionate approach when offering support to consumers where financial risk is present and high customer spending continues.

The Gambling Commission further emphasises the importance of ongoing evaluation. NatCen has acted as the evaluation partner for the Pilot, and its reports are expected to be published alongside the Commission’s next steps.

Next steps

Please get in touch with us if you have any questions about the financial risk assessments post-Pilot update.