England’s Gambling Commission has been grappling with the rollout of its Financial Risk Assessment scheme, also known as Affordability Checks, for some time now. An initial trial run of the scheme took place last month to mixed success.

Speaking on Luck On Sunday, Racing TV’s daily podcast hosted by Nick Luck, CEO of the Betting and Gaming Council, Grainne Hurst gives her view on the pilot scheme, changes the regulated sector have made in response to the Gambling Act Review and the importance of keeping players on the regulated market.

Thoughts on the Financial Risk Assessments

“We were pleased to see that the Gambling Commission paused and has taken a moment to reflect [on the Affordability Checks]”, said Hurst. For her, this decision marks an important development in the on-going saga as it recognises the widespread concerns voiced by the Betting and Gaming Council (BGC), as well as the British Horseracing Authority (BHA), creating “a coalition of the concerned”, as Hurst put it.

She went on to outline how opinions on the checks have changed since the pilot scheme concluded, making specific mention to Conservative party ministers, Reform UK Leader Nigel Farage and former gambling consultant to the government, Dr James Noyes.

Problems with the pilot

Pressed by Luck, Hurst gives the BGC’s stance on why the Affordability Checks pilot scheme didn’t work. She highlights two main issues.

  1. Lack of Consistency within the data

Hurst outlines how the credit reference agencies give customers a rating of green, amber or red to the bookies. But across those agencies, the match rate, “can be as low as 12%,” Hurst concluded.

  1. Limited Customer Information

Hurst reveals that, for operators, the affordability checks scheme does not extend beyond the traffic light system. Meaning, a customer could be an amber or red, simply because they missed last month’s phone bill. At the same time, they could also be given that rating because they missed 12 months of mortgage payments. 

Operators have no way of knowing. 

This then creates a system where operators are forced to ask for customer documents, or documents by default, which Hurst admits, “we know customers don’t want to give their documents to their bookies”, leading to punters being pushed onto the black market, where there is less friction between them and placing bets. 

What Happens Next

Hurst is clear that when it comes to next steps, she doesn’t know. 

The Gambling Commission has said it wants to further consider the evidence, before another attempt at a roll-out. For her part, Hurst and the BGC will continue to work with the Commission and remain vocal about what’s not working, “I don’t think we’re at the stage yet where we’re able to look for solutions, because we haven’t actually seen the evidence of who might be at risk,” Hurst concluded. 

Hurst is clear that the BGC’s position on Affordability Checks is one of support, but “those checks have to be practical, proportionate and frictionless”.

The Black Market

“It’s not a theoretical threat anymore,” says Hurst, “the black market is growing in visibility, growing in sophistication and becoming more emboldened, using things the regulated industry is no longer allowed to use in their marketing.”

Luck presses Hurst, arguing that, while the threat of Affordability Checks is doing its part to drive customers onto the black market, the regulated sector has also played its part in that exodus of players by enacting account closures against high-stakes bettors, particularly in the horse racing industry.

“There are a range of reasons why players move to the black market,” began Hurst, “better odds, alternative payment methods like Crypto and players who have self-excluded. But on account closures, the vast majority of those cases will be for things like bonus mining, bonus chasing, fraud and money laundering”.

Watch Grainne Hurst’s full interview with Racing TV here.

“A Coalition of the Concerned” – Grainne Hurst speaks on Financial Risk Assessments Delay