UKGC Withholds Info on Financial Checks

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UKGC Cites Cost to Withhold Internal Discussions on Financial Checks

A Freedom of Information (FOI) request has revealed that the UK Gambling Commission (UKGC) holds over 1,150 internal records mentioning the 'Regulator's Code' but has declined to confirm whether its leadership ever discussed if financial checks breached this code.

The regulator withheld the information, citing that the cost and time required to search the documents would exceed the legal limit for FOI requests. The response leaves consumers and the industry without confirmation on the internal deliberations of the UKGC's top officials regarding one of its most debated policies.

Context: The Regulator's Code and Financial Checks

The FOI request, dated 28 October 2025, specifically asked if UKGC Commissioners had ever discussed, in writing or verbally, the possibility that implementing financial risk checks could breach sections of the Regulator's Code. This code is a statutory framework that sets out how regulators should engage with those they regulate. Key principles include:

• Supporting compliance and growth (s.1)
• Adopting a risk- and evidence-based approach (s.1.2)

These principles are central to the public debate around financial checks, with critics arguing the measures could be disproportionate and not fully evidence-based. The request sought to discover if the regulator's own leadership shared any of these concerns internally.

Details of the FOI Response

The UKGC refused to provide the requested information by invoking Section 12 of the Freedom of Information Act, which allows public bodies to decline requests if the cost of fulfillment exceeds £450, or 18 hours of staff time.

In its response, the Commission stated:

• A search for the phrase “regulators code” between 1 April 2023 (the month the Gambling White Paper was published) and 28 October 2025 was conducted.
• The search found over 900 records in Commissioners' email accounts.
• A further 250+ records were found in the Commission’s governance document storage area, which holds board meeting minutes and related papers.

According to the UKGC, manually reviewing this volume of material—totalling more than 1,150 documents—to find the specific information would take longer than the 18 hours permitted under the FOIA.

The Commission noted that verbal discussions are not covered by the FOIA, which only applies to recorded information.

Significance: What This Means for Consumers

While the UKGC did not confirm or deny that such discussions took place, its response is significant for two reasons.

First, it reveals that the Regulator's Code is a frequent topic of discussion within the UKGC, appearing in over a thousand high-level emails and governance documents in an approximately 18-month period. This indicates the code is a consistent reference point in the Commission's work.

Second, by withholding the information, the UKGC leaves a critical question unanswered. Consumers and industry stakeholders cannot know whether the regulator's own board ever questioned if the design and implementation of financial checks were compatible with its duty to be a proportionate and evidence-led organisation.

This lack of transparency means that the public remains in the dark about the internal confidence, or potential concerns, the UKGC's leadership held while developing a policy that directly impacts millions of gamblers in the UK.