The gambling minister in the last government has called for an urgent pause on financial risk assessments for gamblers, as the British Horseracing Authority warns the industry could lose hundreds of millions of pounds a year and punters flee to an unregulated black market. Stuart Andrew MP, who previously supported affordability checks, has agreed with James Noyes, an initial proponent of the measures, that implementation should be halted. Despite this, the Gambling Commission is expected to approve the formal rollout at a board meeting scheduled for Thursday, ignoring what Noyes has described as a lack of transparency and independent evaluation of the pilot scheme.
Industry warnings of financial damage
The British Horseracing Authority has suggested that the checks could cost the industry £250m annually in revenue as punters refuse to supply personal financial information to licensed operators and shift to unlicensed rivals. The authority has also estimated that the total hit over the first five years could reach £250m, reflecting a sharp and sustained drop in regulated betting activity. The Betting and Gaming Council has warned that more than 44,000 horse racing bettors could move to the illegal market under the current proposals, potentially cutting Levy funding for British racing by £13m. The Horserace Betting Levy, collected from bookmakers as a percentage of their gross profit on British horserace betting, funds prize money, racecourse integrity and equine welfare — meaning any fall in turnover directly reduces the sport’s finances.
The BGC further estimates that 120,000 additional punters could face checks, with a significant proportion likely to migrate to unregulated operators. A YouGov poll commissioned by the council indicated that two-thirds of respondents would refuse to provide financial documents if required to continue betting. The BHA has already attributed a drop in betting revenue in 2024 to the affordability checks, saying punters have moved to unlicensed operators. Modelling by Regulus Partners suggests a potential annual loss of up to £50m for racing, including a £10m–£11m reduction in Levy payments and a 15% decrease in media rights deals.
The close interlinking of racing and betting means that a reduction in regulated wagering directly harms the sport. Racing, for much of the last 20 years, looked the other way as operators used cross-promotion to steer customers recruited via racing and sports betting towards fixed-margin casino games and slots, which carry no risk for the bookmaker. These same operators have already driven thousands of punters on to the black market by restricting bets or closing accounts entirely. Yet despite this history, the financial risk assessments now threaten to accelerate the exodus.
Rationale for checks and concerns over design
The intention behind affordability checks is to identify gamblers at the greatest risk of harm and ensure they receive help. Problem gambling can have devastating consequences: research shows that 40% of gamblers with a Problem Gambling Severity Index score of eight or above — indicating a high level of risk — report experiencing at least one severe consequence, such as relationship breakdown or committing a crime, over the previous 12 months. Only 20% of gamblers in this group have sought help from gambling support services in the same period. Reducing that 80% who do not seek help is an urgent priority, and no form of gambling, including the weekly lottery draw, is entirely safe.
However, a fundamental flaw from racing’s perspective is that the checks are triggered solely by spend, with no additional markers such as frequency or duration. This may be appropriate for repetitive, fixed-margin gaming, but it is wholly inappropriate as a measure of possible harm in betting, which has an entirely different profile of profit, loss and participation. Checks designed for gaming products will, almost by definition, produce significant numbers of false positives when applied to betting. The Gambling Commission’s own annual surveys show that betting on racing is one of the safest gambling products on the market.
James Noyes, who was one of the initial proponents of affordability checks, has been clear that online slots and casino games — several times more likely to be associated with problem gambling — were always intended to be the main target. He has highlighted that the pilot of financial risk assessments, which involved credit reference agencies, has produced inconsistent results for the same customer, undermining the promise that the process would be “frictionless” for all but a minority. MPs have questioned whether checks can remain frictionless if operators still need to request financial documents from some customers. The Gambling Commission claims that the pilot implies less than 3% of active customer accounts would trigger any steps, and that 97% of those would have a frictionless assessment process. But there is no breakdown of whether those customers were largely gaming or betting customers, and in a country where about 8 million adults — 16% of the population — are estimated to gamble online in any four-week period, the potential for a grossly disproportionate impact on betting customers is clear.
The Gambling Commission’s pilot was extended, with analysis continuing into the summer of 2025, and a sporadic blog covering the exercise was not updated between spring 2025 and 18 April this year, when a fresh post — five days after Noyes highlighted the extended silence — suggested that much recent commentary had been “ill informed or inaccurate”. The Commission maintains that financial risk assessments would not affect a customer’s credit score and would be frictionless for individuals with limited credit history.
Regulatory track record and looming decision
The Gambling Commission’s handling of the Football Index scandal has raised questions about its regulatory judgment. The betting platform collapsed in March 2021, costing users more than £100m. The Commission was warned as early as January 2020 that Football Index was “an exceptionally dangerous pyramid scheme”, yet it allowed the platform to continue operating for 14 months and was still “minting” new shares days before the collapse. The Commission’s view is that it did not license a Ponzi scheme, and an independent report found no evidence to contradict that. Nevertheless, the episode has led to scrutiny of the regulator’s due diligence and decision-making.
A nagging concern throughout the extended process of introducing affordability checks — which started during the last government and seems set to conclude two years into the next — has been the extent to which the regulator grasps the issues and potential consequences, or has the ability to change course if required. Even its insistence on referring to “financial risk assessments” rather than “affordability checks” hints at a reluctance to fully engage with the debate. On Thursday, the seven current commissioners will vote on formal rollout. Before they do, the question is whether they can be certain they are not about to commit another regulatory failure.
