The Gambling Commission’s (GC) call for evidence from operators on proposals to strengthen expectations on assessing the affordability of players’ gambling has garnered attention. The consultation raises questions about how operators monitor and manage affordability risk, given limited available data. Operators lack access to financial data, and there is no defined blueprint for handling it. Each operator’s policies, systems, and skillsets differ, making it difficult to align with blanket requirements and regulations.
Here are some key questions raised by the Gambling Commission’s requirements and how operators can prepare for potential changes:
- How will the Commission set its affordability threshold? The regulator may base thresholds on the average weekly gross earnings in the UK, currently £580. However, the threshold may apply to losses rather than deposits. Operators should be prepared to conduct affordability checks on registration and losses.
- Will different requirements and thresholds apply to different license types? Casino operators might be heavily impacted due to the speed of loss. The recent enforcement report suggested additional checks for customers wanting to spend more than the national average, but this seems contradictory to the current proposal.
- What affordability checks must operators carry out? Operators may have to conduct different checks based on varying loss or deposit thresholds. The checks should be scalable, tailored to individual players, and take a layered approach. Enhanced due diligence and income evidence upon first deposit may be necessary.
- What impact will these changes have? Changes in affordability checks may cause friction in the customer journey. However, if all operators adhere to the same requirements, the conversation becomes easier. Complaints around losses may decrease, benefiting all stakeholders.
To prepare, operators should tighten controls and affordability checks now, or include customer journey changes in their product roadmaps. Affordability checks should be part of the overall player risk profile, and automation and real-time frameworks should be implemented. Effective player communication is crucial, explaining the need for additional checks and the documents required for affordability checks.
Changes are inevitable, and operators should adequately prepare to check player affordability on deposits or losses. It is essential to stay proactive in developing responsible and sustainable businesses through regulatory compliance.
Paul Foster is the managing director of Crucial Compliance, guiding operators in developing responsible and sustainable businesses by providing regulatory, corporate responsibility, compliance, and professional services.
