Concerns regarding the UK Gambling Commission's financial risk assessments have been raised following a recommendation from Dr. James Noyes to halt the policy until a thorough review of the pilot scheme is completed.
In an open letter addressed to UK Culture Secretary Lisa Nandy, Noyes, a prominent advocate for affordability checks for online gamblers, urged for a pause on the proposed checks until there is sufficient evaluation of the pilot scheme designed to assess the practical implementation of these measures, as reported by The Guardian.
The UK Gambling Commission initiated its pilot program for what it calls “financial risk assessments” in September 2024. This study aims to evaluate a two-tier system that seeks to identify potential gambling-related harm while ensuring that the checks can be conducted smoothly, meaning that customers would not have to submit financial documents to continue gambling.
As of now, the regulator has not released a final report on the pilot and has not provided any public updates on its progress since spring 2025. Recent media reports indicate that the commission’s board may consider approving the checks in an upcoming meeting next month.
Noyes expressed his “deep concern over a lack of transparency” regarding the checks, noting that there are increasing reports of inconsistent data, ambiguous outcomes, and unnecessary complications associated with the pilot scheme.
He also highlighted his worries about the potential burdens these checks could impose on horse racing bettors, which could negatively impact the sport.
This sentiment is echoed by senior figures in the horse racing industry, who have cautioned that the proposed checks may disproportionately affect racing bettors. Industry representatives have warned that these measures could lead to significant revenue losses, amounting to tens of millions of pounds, if customers choose not to provide financial information and instead resort to the black market.
Noyes emphasized the government’s responsibility to heed the warnings from the British Horseracing Authority and take appropriate action to safeguard this vital aspect of British culture and social life.
Initially, Noyes was a strong public supporter of affordability checks when the policy was first introduced in 2020. As a senior fellow at the Social Market Foundation, he endorsed the measure in reports released in 2020 and 2021, with several of his recommendations later incorporated into the UK government’s gambling reform white paper published in April 2023.
In his letter, Noyes acknowledged that while affordability checks were “a worthy idea in principle” when first proposed, his backing was contingent upon certain conditions. These included establishing a gambling ombudsman to ensure consumer rights and redress, implementing non-intrusive checks, and creating a system that prevents serious gambling-related harm without hindering the majority of customers from engaging in a lawful activity involving their own funds.
He concluded by stating, “The current state of financial risk checks raises serious questions that the government must address before advancing this policy. Therefore, I urge the government to consider the BHA’s warnings and suspend these checks until a thorough evaluation and scrutiny have been conducted.”
A spokesperson for the UK Gambling Commission stated that the regulator is “continuing to work on financial risk assessments, with a primary focus on minimizing friction for consumers.”
“If implemented, consumers would not need to provide documents for the checks to be completed. As with any regulatory measure, we will assess the potential impacts on consumers and businesses before making a decision regarding financial risk assessments, including how they would function in practice if introduced,” the spokesperson added.