UKGC: No Credit Scores in Initial Player Checks
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A Freedom of Information (FOI) disclosure from the UK Gambling Commission (UKGC) has clarified the mechanics of its new financial protection measures, revealing that the initial checks triggered by player deposits will not involve credit scores or data from credit reference agencies.

The response, dated 11 October 2024, addresses consumer concerns about how the widely discussed 'affordability checks' will operate in practice. The Commission distinguishes between two separate systems: live financial vulnerability checks and a pilot for financial risk assessments.

Financial Vulnerability Checks: The First Step

For the vast majority of customers, the first interaction with the new system will be a 'financial vulnerability check'. The UKGC confirmed these are designed to identify significant financial vulnerability at an early stage. Key details revealed include:

  • Thresholds: The checks are triggered at a £500 net deposit within a 30-day period (from August 2024), lowering to £150 net deposit per 30 days in February 2025.
  • Data Source: Crucially, the UKGC states these checks are "based on publicly available data and do not include credit reference bureau data."

This directly answers questions raised in the FOI request about specific credit scores, length of credit history, or the impact of County Court Judgments (CCJs). For these initial, lower-level checks, such information is not used. This means a player's credit file will not be accessed or affected when they cross these first thresholds.

Financial Risk Assessments: A Pilot for High Spenders

The UKGC clarified that what are often called 'affordability checks' are more accurately described as 'financial risk assessments', and these are not yet live. A pilot programme is underway to test how data from credit reference agencies could be used to protect high-spending customers.

The Commission explained the pilot aims to "tackle cases where customers have been able to gamble large amounts without any checks or support where it was later identified that this led to significant harm."

While this pilot will explore the use of credit reference data, the UKGC did not provide specifics on what constitutes a 'pass' or what data points will be used, as this is what the pilot is designed to determine.

Open Banking and Player Consent

The FOI response also provided clarity on the role of Open Banking, a system that allows customers to share their banking data securely.

The Commission confirmed it is not exploring enforced Open Banking. Any use of this technology would be based on customer consent and transparency. Furthermore, the UKGC stated it is "not exploring the use of preventing access to gambling should a customer choose not to share open banking details."

However, it noted that if a customer refuses to share any information required for standard identity verification or anti-money laundering checks, an operator may not be able to allow them to continue gambling.

What This Means for Players

This disclosure confirms a tiered approach to financial risk checks. For most players, the new system will involve a light-touch check using public data that does not impact their credit rating. More detailed, credit-file-based assessments are being reserved for the highest-spending accounts and are still in a testing phase.

The response did not directly address whether operators would be required to share data with each other to prevent players from bypassing thresholds by using multiple gambling sites. The focus remains on assessing risk at the level of a single operator during the pilot phase.

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Written by

Research & Data Lead

PhD in Public Policy, London School of Economics. Member of the Royal Statistical Society. Published in the Journal of Gambling Studies and Addiction Research & Theory.

Dr. Chen holds a PhD in Public Policy from the LSE and has 8 years of experience in quantitative research, including 3 years as a Research Fellow at the Responsible Gambling Trust analysing operator self-exclusion data.

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UKGC affordability checks financial vulnerability regulation safer gambling freedom of information

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