Financial Risk Assessments: The Numbers Behind the Affordability Checks

Few gambling policies have generated more noise than affordability checks, and few have been discussed with less reference to the published numbers. The Gambling Commission set out a staged approach in July 2026. Here is what it says.

The thresholds

Financial Risk Assessments are triggered by net deposits, not by turnover or by losses in the colloquial sense. The figures differ by age, and they tighten as the rollout progresses.

Stage one, the opening position, sets the trigger at £5,000 net deposit in a rolling 24 hours for customers aged 25 and over, and £2,500 for those under 25.

At full implementation, the thresholds drop substantially: £1,000 in a rolling 24 hours or £3,000 in a rolling 90 days for the over-25s, and £750 in 24 hours or £2,000 in 90 days for under-25s.

The gap between those two sets of numbers is the entire rollout. Stage one is calibrated to catch very few people; the final position is calibrated to catch considerably more. The interim stages between them have not been defined.

"Frictionless" is a specific claim, not a slogan

The word appears constantly in this debate and it has a precise meaning here. The assessment is carried out by Credit Reference Agencies using data they already hold. It is document-free: the customer is not asked for payslips, bank statements or anything else. And it does not affect the customer's credit score, because it is not a credit application.

The Commission's pilot reported that 97 percent of accounts crossing the threshold could be assessed frictionlessly in this way. For the remaining fraction — around 0.1 percent of accounts overall — operators may fall back to open banking or to requesting documents.

The headline figure worth holding onto is the other one: on the Commission's own numbers, the assessments touch fewer than 3 percent of accounts. The vast majority of people who gamble online will never cross a threshold at all.

What an operator has to do about a result

This is the genuinely uncertain part. A Financial Risk Assessment produces a signal about whether a customer may be in financial difficulty. It does not produce an instruction.

Operators are expected to take proportionate action where risk is identified — reducing marketing to that customer, supporting them to set a deposit limit, and so on. But during early implementation the Commission has said that no enforcement action will be taken for a failure to act on an assessment result. All other licence conditions continue to apply as normal.

In other words: the data-gathering is being switched on well before the obligations attached to it. That is a deliberate sequencing choice, and it is the reason the rollout looks slower than either side of the argument would like.

Why this is not the thing most people are angry about

Much of the public argument about affordability checks describes a different policy: intrusive demands for bank statements, sent to ordinary punters betting modest amounts, with accounts frozen until documents are produced. That behaviour has certainly happened. It was not, however, the Financial Risk Assessment framework, which did not exist yet.

What produced it was operators making their own judgements to satisfy existing anti-money laundering and social responsibility obligations, with no standard threshold to work to and considerable incentive to be cautious. A documented national threshold, delivered by credit reference data, is a response to that problem rather than an extension of it.

Whether it works as intended is a fair question, and MPs have pressed the Commission on the detail. But the design goal is worth stating accurately: replace inconsistent, document-heavy checks applied at operator discretion with a consistent, invisible one applied at a published number.

What the operator can actually do with a result

An assessment returns an indication of financial vulnerability, not a number and not a verdict. The operator is expected to respond proportionately — and "proportionately" is carrying a great deal of weight in that sentence.

In practice the expected responses run from the mild to the significant: reducing or stopping marketing to that customer, prompting them to set or lower a deposit limit, introducing friction before further deposits, and at the far end declining to accept further business. What the framework does not do is mandate any specific one of these at any specific signal. That judgement stays with the licensee.

This is the genuine weakness critics point to, and it is a fair criticism. A national threshold delivers consistency about who gets assessed. It delivers nothing like the same consistency about what happens next, which means two customers with identical circumstances at two operators can still have very different experiences.

The data question

Because the assessment runs through Credit Reference Agencies, a reasonable question is what they see and what they keep. The Commission's position is that these are not credit applications: they leave no footprint that other lenders can see and they do not affect a credit score.

What the operator receives is an assessment output, not the underlying credit file. The operator does not get to browse your accounts. That distinction is the whole reason the process can be described as frictionless — the data never travels to the gambling company in raw form, only the conclusion does.

For the small share of cases the CRA route cannot resolve, the fallback is open banking or a document request, and at that point the friction everyone complains about returns. On the Commission's figures that is roughly one account in a thousand.

What to do with this

If you deposit well under £1,000 in a day and under £3,000 in three months, the framework as finally designed will not reach you. If you regularly exceed those, expect an assessment to happen quietly in the background at some point in the rollout, and expect not to notice it.

The practical advice is unchanged and boring: set a deposit limit yourself. An operator-side limit that you chose is the one intervention in this entire landscape that requires no regulator, no credit reference agency and no threshold, and it takes under a minute in any UK-licensed account.

Sources

Every figure and date above is taken from these. They are primary sources — the regulator and the government, not other coverage.

• Commission to introduce Financial Risk Assessments in staged approach, Gambling Commission
• Financial risk assessments update - July 2026, Gambling Commission