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Gambling Commission to implement Financial Risk Assessments in staged approach

Home / Anti-Money Laundering / Gambling Commission to implement Financial Risk Assessments in staged approach

Gambling Commission to implement Financial Risk Assessments in staged approach

By James Frudd

On the 7 July 2026, the Gambling Commission announced that Financial Risk Assessments will be introduced through a staged implementation process.

Staged Introduction Following Consultation and Pilot

Following extensive consultation, stakeholder engagement and piloting, the Gambling Commission has decided to introduce Financial Risk Assessments using a staged approach. The introduction of Financial Risk Assessments is one of the more controversial and debated outcomes of the 2023 White Paper. You can read more about the Financial Risk Assessment Pilot in our stage 1, stage 2 and stage 3 blogs.

The Gambling Commission has said that “Financial Risk Assessments will provide operators with a new, more effective and proportionate way of identifying customers in significant financial difficulty, while reducing reliance on the document checks that some operators currently use to seek to identify financial risk and that are unpopular with many customers”.  The Gambling Commission further notes that some such customers are not currently being identified or supported, despite being two to four times more likely to have a debt management plan and two to five times more likely to have had a default in the previous 12 months than the wider population. If unidentified, they may continue receiving marketing and promotional offers despite being financially vulnerable.

It is expected that the majority of customers will never require an assessment due to the high spending nature of the relevant thresholds being introduced. However, where an assessment is required, the process is expected to be frictionless, document-free and carried out by Credit Reference Agencies with no impact on the customer’s credit score.

Stage One Implementation

The first stage of implementation will involve assessments being carried out by the largest operators where customers have a high spend of multiple thousands of pounds over a 24-hour period.

For most customers, Stage One will apply at £5,000 net deposit in a rolling 24-hour period. This has been described as an unusually high spend pattern, exceeded by less than 0.5 percent of customers.

The Gambling Commission will continue working with gambling businesses, Credit Reference Agencies and other stakeholders to refine the assessments, develop guidance and support proportionate implementation.

For the small proportion of customers who may need support, the Gambling Commission will support operators in taking appropriate and proportionate action. This may include reducing marketing to vulnerable consumers, helping customers set deposit limits, or taking further action where needed.

The Gambling Commission has also confirmed that, during the early stages of implementation, it will not take enforcement action for a failure to act following a Financial Risk Assessment. However, operators of course remain subject to all other existing licence requirements.

The timetable for Stage One will be confirmed after engagement with industry and other stakeholders through implementation groups being established over the summer.

Financial Risk Assessment Thresholds

Stage 1 implementation

  • Consumers aged 25 and over: exceeds £5,000 net deposit in a rolling 24-hour period.
  • High-risk groups, such as consumers under 25: exceeds £2,500 net deposit in a rolling 24-hour period.

Interim stages of implementation

  • To be set following further engagement with implementation groups and stakeholders.

Final stage of implementation

  • Consumers aged 25 and over: exceeds £1,000 net deposit in a rolling 24-hour period or exceeds £3,000 net deposit in a rolling 90-day period.
  • High-risk groups, such as consumers under 25: exceeds £750 net deposit in a rolling 24-hour period or exceeds £2,000 net deposit in a rolling 90-day period.

Comments from the Gambling Commission and Government

Sarah Gardner, Acting Chief Executive of the Gambling Commission commented:

“We are confident that our approach, using high-quality data, will enable support for high-spending customers in financial difficulties, while reducing friction for customers who are not in financial difficulties by removing the need for unnecessary and unpopular document checks to understand financial risk.”

“We have listened to feedback throughout the pilot process which has led to us deciding to carefully proceed. We will work with key partners to make sure that they are implemented in the most effective way for consumers and operators.”

Gambling Minister Baroness Twycross also welcomed the decision to implement Financial Risk Assessments by commenting:

“Attention must now turn to successful implementation, so that financial risk assessments work for consumers, gambling operators and the wider ecosystem.”

“The right balance must be struck so that assessments protect those in financial difficulties from the risk of gambling-related harm but do not create unnecessary burdens for the industry or consumers.”

Summary

Please get in touch with us if you have any questions about the first stage of the Financial Risk Assessments implementation.

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