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Politics Home | Before the Gambling Commission makes any decision on FRAs, it must answer these questions

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With fundamental questions about consistency, fairness and consumer impact still unresolved, the Betting and Gaming Council’s chief executive, Grainne Hurst, argues the Gambling Commission must pause its Financial Risk Assessment proposals before causing serious, irreversible harm

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On the day of the Gambling Commission’s Board meeting on Financial Risk Assessments (FRAs), there are still fundamental questions that remain unanswered.

Do these checks actually work?

What actions will they trigger?

And what will they mean for ordinary punters?

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Until those questions are answered clearly, the Commission should not press ahead.

FRAs were meant to be “frictionless” and workable in practice. The pilot was supposed to test that. Instead, it exposed serious concerns about whether the system is reliable, proportionate or fair, and whether it will genuinely improve protections for consumers.

The biggest issue is what happens after a customer is flagged. The Gambling Commission has focused heavily on the idea that most checks will be technically “frictionless”, but punters care about outcomes, not process. If an assessment leads to intrusive follow-up questions, requests for personal financial documents and account restrictions, then the customer experience will be severely disrupted.

And there are real questions about whether the underlying data can even be trusted. The same customer can receive different outcomes depending on which credit reference agency is used. If operators cannot rely on the consistency of the data being returned, they will be forced to act cautiously. In practice, that means more customers facing restrictions and being asked to provide sensitive financial documents.

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We already know how consumers feel about that. Recent YouGov polling found 65 per cent of bettors would be unwilling to provide documents such as bank statements or payslips in order to continue betting. Faced with intrusive or inconsistent checks, punters will not simply stop betting – many will be driven straight into the arms of the growing illegal gambling black market, which offers none of the protections or safeguards available in the regulated sector.

That should concern everyone. The illegal gambling black market is growing rapidly, doubling in size over the past two years. Any policy that risks driving ordinary punters away from regulated operators and towards illegal sites would be deeply counterproductive. It would harm consumers, damage the regulated industry and cost the taxpayer.

It would also have serious consequences for British horseracing, which relies heavily on regulated betting for funding. Racing’s finances already face significant pressure, and any further migration of customers away from the regulated market risks reducing Levy revenues, sponsorship and media rights income that support the sport, its jobs and its long-term future.

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Concerns about these proposals are no longer limited to the regulated industry. Even former supporters are now calling for a pause and rethink, including Dr James Noyes, who recently resigned from the Gambling Act Review Evaluation Advisory Group in protest over the Government’s approach to Financial Risk Assessments implementation. Parliamentarians from across the political spectrum have also raised serious concerns, alongside former Gambling Minister Stuart Andrew MP, who oversaw the original White Paper reforms. Newspapers including The Sun and the Racing Post, alongside more recently The Guardian and The Telegraph, have repeatedly highlighted the risks around intrusive checks, the threat to horseracing and the growth of the black market.

Which is why recent comments from Tim Miller, the Gambling Commission’s Executive Director of Research and Policy, were so surprising. Speaking at the CMS conference last week, he said: “you can’t evaluate something until you have implemented it.”

But that is precisely what the pilot was supposed to do. Its purpose was to test whether these proposals worked before implementation. What we have seen instead are unresolved concerns around consistency, reliability and customer impact.

The Betting and Gaming Council supports proportionate, evidence-based regulation that protects the vulnerable while allowing the 22.5m adults in Britain who enjoy a bet each month to do so safely. But good regulation must also be workable in practice. At the moment, these proposals do not meet that test and should not proceed in their current form.

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