On May 21st the Gambling Commission released further updates on stage two of the Financial Risk Pilot, providing more data and findings regarding how the process may be. The financial risk assessment aims to identify a way for operators to identify “high-spending remote gambling customers who may be in financial difficulties, in order to help support them”. This will allow anyone experiencing arrears, defaults or bankruptcy to be identified in a more targeted way without affecting their credit score.  

This assessment is ongoing, stage three and the following analysis phase, will provide insights into inconsistencies between credit reference agencies and how risk assessments can better target severe financial risks. This will inform how operators might integrate financial risk assessments into customer interactions. 

Summary of the Pilot’s Overall Approach 

The pilot, launched in September 2024, involves major remote gambling operators and is not a live test—no consumers have been affected. It is structured in three stages, followed by an analysis phase extending into summer 2025. Final reporting will consider pilot findings alongside wider data and evidence. 

The pilot aims to assess whether financial risk assessments can support a smoother customer journey and reduce unnecessary document requests. It explores four success criteria: 

1. Part 1: “What proportion of those high-spending customers checked could get a frictionless financial risk assessment if they were introduced?” – This looked to see if 80% of high spending customers (3% of overall total accounts) can receive a financial risk assessment without friction. 

1. Part 2: “How quickly could credit reference agencies return a financial risk assessment?” – This will test if credit reference agencies are able to return results for matched customers within minutes. 

1. Data Relevance and Accuracy: “Is using credit reference data meaningful for understanding of an individual customer’s current or imminent overall financial risk and financial vulnerability?” – This includes evaluating consistency between agencies and the potential for false positives or negatives. 

1. Implementation: “How could the data be presented to operators to help understand the level of financial risk or vulnerabilities associated with individual customers?” 

Final decisions will also consider additional data, including findings from separate data requests and broader insights into gambling harms and alternative financial risk assessment methods. 

As of now, stage two of the pilot is complete with the commission revealing:  

“In Stage two of the pilot, there were approximately 1.7 million financial risk assessments across the three credit reference agencies, in relation to approximately 860,000 accounts. This is an increased number of risk assessments compared to Stage one due to the design of Stage two, but this is not indicative of how many accounts might be assessed if the assessments were introduced in a live environment. You can read more about how thresholds could be set in our consultation response.” 

“Approximately 3 percent of the assessments were not matched in this stage – this compares to 5 percent in Stage one of the pilot. Stage two of the pilot used a more recent period and this may have contributed to a reduction in the unmatched category as the operators’ data may have been more up to date. A frictionless assessment was not possible in these cases – this is favourable compared to the estimated 20 percent who would not have a frictionless assessment as set out in the 2023 Government White Paper.” 

Stage Two Findings – Key Information for Operators 

Financial Risk Insights:
Data from two credit reference agencies (CRAs) during Stage Two indicated that customers meeting the pilot thresholds were significantly more likely to show financial risk indicators than general UK populations. This being that: 

• Customers in the pilot were more likely to have a debt management plan. 

• They were more likely to have had a default in the last 12 months, defined as when a creditor deems the debt unlikely to be repaid. 

CRA Differences:
Varying results were observed from different CRAs. These being due to: 

• Different data sources used by each CRA. 

• Unique scoring systems and ways of presenting risk. 

While variation is expected, a lack of transparency behind differing results has made it harder for operators to interpret data effectively. Understanding and addressing these inconsistencies will be a “key focus for the post-Stage Three analysis phase.” 

What are the next steps? 

• Post stage analysis following the end of stage three has now commenced will continue through summer. 

• The Commission is further exploring how to focus assessments on the most severe financial risks and support operators embedding risk assessments into broader customer interaction strategies. 

• Operators are reminded that “financial risk assessments are not designed to be acted on in isolation” they must be balanced with other customer information. 

If you wish to discuss Gambling Commission Compliance assessments and the related requirements, feel free to Contact Us for a free consultation.