UK Gambling Commission Flags Disconnect Over Risk Checks

Gambling Commission Flags Disconnect With Industry Over Financial Risk Checks – FRA Pilot Highlights Arrears Among Higher-Spending Customers

Key Takeaways

• Gambling Commission executive director Tim Miller said a “disconnect” exists between the regulator and the industry over financial risk assessments.
• A pilot scheme found a cohort of players in arrears that were not identified by operators’ existing processes.
• The second phase of the pilot applied checks at a £150 net monthly deposit threshold, with 97% of checks described as frictionless.
• The Commission has delayed a final decision on full implementation following industry pushback.
• Miller also criticised tech companies, affiliates and B2B suppliers over their role in the black market.

Regulator Highlights Gap Between Policy Intent and Industry Perception

Gambling Commission executive director Tim Miller has acknowledged a “disconnect” between the regulator and the gambling sector over proposed financial risk assessments. Speaking at iGB Live, Miller said the debate around FRAs had shifted away from their original purpose as outlined in the Gambling Act review white paper.

The policy was first proposed as part of the wider review and was later characterised by parts of the industry as “rebranded affordability checks”. Miller stated that this framing has obscured the intended focus of the measure.

According to him, the objective is to concentrate on higher-spending customers where there is evidence of financial distress. He said that some critics have “forgotten the purpose of the policy” and emphasised that the checks are meant to identify risk rather than create unnecessary friction for customers.

Pilot Scheme Identifies Players in Arrears

The Gambling Commission initiated a pilot scheme in August 2024 to test how financial risk assessments would operate in practice. A number of tier one operators took part.

During the initial phase, additional checks were triggered when a player’s net monthly deposit reached £500 under a light touch approach. In February 2025, the second phase lowered the net deposit threshold to £150 or above.

Miller said that data accessed through reference agencies revealed a cohort of players who were in arrears and were not being picked up by operators’ existing monitoring processes. He described this finding as a key outcome of the pilot and indicated that the regulator intends to focus on this group.

In May 2025, the Commission reported that 97% of checks carried out in the second half of the pilot were considered frictionless. According to Miller, the information unlocked through reference agency data provided a clear understanding of financial distress without impeding the customer journey. He stated that, if implemented properly, the checks could improve rather than hinder the overall experience.

Decision on Full Implementation Delayed

Despite the pilot results, the Commission has not yet confirmed when or whether FRAs will be fully implemented. In May 2025, following what was described as a targeted attack against the policy, the regulator delayed its decision.

Miller said the Commission has been criticised both for moving too quickly and for taking too long. He stated that the regulator has deliberately taken its time, noting that regulatory peers in other jurisdictions are closely watching how the UK approaches financial risk checks.

Miller, who announced his departure from the Gambling Commission this week, said he does not yet have a timeline for implementation. He added that more information would be made available in September and that he remains committed to completing a number of policy changes before leaving his role.

Focus on Black Market and Role of Technology Platforms

Beyond financial risk assessments, Miller addressed concerns about the illegal gambling market. He criticised major technology companies for what he described as a failure to act quickly enough to restrict black market sites and related marketing.

According to Miller, tech companies are “failing British consumers” by not responding at sufficient speed. He also said that those combating illegal operators need to become as well connected as the criminal networks running such operations.

Affiliates and B2B suppliers were identified as a significant part of the problem. Miller called on licensed operators to conduct due diligence on suppliers and affiliate partners to ensure there are no links to black market activity.

He noted that some operators are taking proactive steps against illegal gambling, citing Entain’s Simon Zinger as an example of leadership in this area.

What Financial Risk Assessments Mean for Operators and Customers

For operators, the debate around FRAs centres on how to balance consumer protection with customer experience. The pilot demonstrated that the majority of checks can be carried out without friction, according to the Commission’s May 2025 update.

At the same time, the identification of players in arrears who were not detected under existing processes highlights a potential gap in current safeguards. The regulator’s position is that financial risk assessments are designed to address this gap, particularly among higher-spending customers.

For customers, especially those depositing at or above the tested thresholds, the outcome of the policy debate may influence how and when additional checks are triggered in the future. However, no final framework or timeline has yet been confirmed.

Our Assessment

The Gambling Commission’s FRA pilot identified a group of players in arrears not captured by operators’ existing systems and reported that most checks were frictionless at the £150 threshold. Despite these findings, industry pushback has led to a delay in full implementation, and no timeline has been set. The regulator continues to frame FRAs as a targeted measure focused on higher-spending customers with signs of financial distress, while also increasing pressure on operators, affiliates, suppliers and technology platforms in the fight against the black market.