UKGC: No Formula for Risk Check Thresholds
FOI response shows financial risk check levels were not set by a specific calculation, but by 'consideration' of data.
A Freedom of Information request has revealed the UK Gambling Commission did not use a specific mathematical formula to set proposed financial risk check thresholds. The regulator confirmed it 'considered' data on harm, income, and spending but that it was not possible to combine them into a calculation. This indicates the proposed levels were based on judgement rather than a direct statistical model.
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UKGC Confirms No Calculation Method for Financial Risk Check Thresholds
A Freedom of Information (FOI) response has revealed the UK Gambling Commission (UKGC) did not use a specific mathematical formula to determine the proposed thresholds for its new financial risk checks.
The disclosure, made in response to a request dated 7 September 2023, confirms that while multiple data sources were reviewed, they were not combined to produce a calculated figure. Instead, the regulator used the data to "inform consideration" of the proposed levels.
Context: The Push for Financial Risk Checks
Financial risk checks, often referred to as affordability checks, are a central pillar of the government's plan to reform gambling laws as outlined in its recent White Paper. The checks are designed to identify and protect consumers who may be spending more than they can afford and are at risk of harm.
The UKGC's consultation proposed two tiers of checks:
- A light-touch check for customers with a net loss of over £125 within a rolling 30-day period.
- A more detailed check for customers with a net loss of over £1,000 within a rolling 24-hour period or £2,000 within 90 days.
These proposed figures have been a major point of discussion for both consumers and the industry, making the method for their creation a subject of public interest.
Details of the Disclosure
The FOI request asked the UKGC to disclose the exact method used to calculate these thresholds. The request specifically queried how three key data sources cited by the Commission were used:
- Problem gambling rates and other harm-related information.
- Population-level data on discretionary income.
- Data on the amounts customers currently spend on gambling.
In its response, the UKGC stated: "Each of these aspects have a statistical element, but it would not be possible to combine them to arrive at a calculated threshold."
The regulator confirmed that these three elements were used to "inform consideration of threshold levels for consultation," but not as inputs for a specific formula. The Commission directed the requester to its formal advice to the government for further context.
Significance: Judgement Over Formula
This disclosure is significant because it clarifies that the proposed financial risk thresholds are not the output of a direct, replicable statistical model. Instead, they appear to be the result of the Commission's professional judgement, informed by a review of various data points.
For consumers, this means the specific monetary values proposed for checks were not derived from an objective calculation that combines average income, spending patterns, and harm indicators. While the process was data-informed, the final figures were ultimately determined through a qualitative assessment.
This lack of a concrete formula may draw criticism from those who believe the thresholds are arbitrary, but it also highlights the inherent difficulty in creating a single, data-driven rule that can effectively apply to the entire gambling population's diverse financial circumstances.