Don’t let the gambling tax debate distract from what could be going on behind the scenes on affordability checks. We are still waiting for the NatCen report on the financial risk checks pilot, which the Gambling Commission promised “in the autumn”. This is a regulator with a history of withholding data that could have changed its decisions. It is over six years since James Noyes and the Social Market Foundation proposed a £100 a month “soft cap” on net deposits, with affordability checks for anyone wanting to spend more. It is over three years since the April 2023 White Paper committed to financial risk checks. In April this year even Noyes wrote to the Culture Secretary calling for a pause, citing a lack of transparency. On 7 July the Commission announced that Financial Risk Assessments will go ahead. Customers aged 25+ will be checked once net deposits pass £1,000 in 24 hours or £3,000 in 90 days, falling to £750 and £2,000 for under-25s. The decision was made before anyone outside the Commission had seen the full pilot evidence or NatCen’s independent evaluation of it. The pilot ran from September 2024 and data sharing for its final stage finished on 30 April 2025. That is over 17 months ago. In April 2026 the Commission said NatCen’s reports would be published “in due course alongside our decisions on next steps”. The decision came in July. The reports did not. Racing asked for the evidence first. On 28 April the BHA wrote to the Commission’s chair asking for no decision until the Stage 3 report and the NatCen evaluation were public. The BHA also requested them under FOI. The Commission dismissed that request as “vexatious”. On 10 July the Culture, Media and Sport Committee wrote to the Commission with five questions. The first asked whether it would publish the full dataset, evidence base and methodology behind the decision and the thresholds. The acting CEO replied on 22 July that data would be published in the autumn, with some information “aggregated” where commercially sensitive. NatCen is not mentioned once in that reply. This is not new behaviour. In January and February 2021 the Commission ran a consultation survey on affordability checks with 12,125 respondents. 77% said gambling businesses should not be required to assess affordability. Only 14% said they would hand over information to prove they could afford to bet. Only 8.6% were very comfortable with operators pulling data from credit reference agencies, which is exactly how FRAs now work. Those results were not published. In June 2022 the DCMS Committee chair asked the then CEO why, and he said he did not know as it predated him. The White Paper, the 2023 consultation and the February 2024 Westminster Hall debate all went ahead without the data. Regulus Partners asked for it under FOI in October 2023 and was refused, and it only came out in June 2024 after a second FOI. When the evidence is finally published, it needs to answer these questions. Will NatCen’s evaluation be published in full as a standalone report, or only summarised by the Commission? How consistent are the three credit reference agencies with each other when assessing the same customer? What is the false positive rate? What did operators do with customers flagged in Stage 3, and how many were asked for documents anyway? The Commission says 97% of checks will be frictionless. It may be right. But a regulator that wants to be trusted on that number should publish the evidence before the checks go live, not after. We also have no clear answers on what happens after the check is complete. The Commission has said support could include deposit limits or reduced marketing, but the guidance for operators is still being written. Will customers be given deposit limits based on the results? What if a customer disagrees with the limit? Is more information then required, which puts them straight back into the document checks FRAs were supposed to replace? In the meantime, the questions do not only go to the Commission. The pilot was run with the largest operators, who supplied the customer data and received the credit reference results. So why have the big firms and the BGC not published a detailed account of the evidence from their side of how the pilot went? They have criticised the decision loudly, but criticism without their own data leaves bettors relying on the Commission’s version alone, which may never come.

A regulator that worked for punters would protect customer funds, set standards for withdrawals and ID checks, back minimum bet liability, give ordinary punters a seat at the table and publish its evidence. The Gambling Commission has done none of these. The Gambling Commission was created by the Gambling Act 2005 and took over in 2007. Its job is defined by three licensing objectives: keep crime out of gambling, ensure gambling is conducted fairly and openly, and protect children and vulnerable people. Nearly two decades on, it is worth asking a simple question. What has it done for the people who actually bet? The honest answer is very little, and a good deal of harm. It does not protect your money If you deposit with a licensed British bookmaker, the Commission does not require your money to be protected if the firm goes bust. Operators only have to tell you how protected it is, and “not protected” is a perfectly legal answer. There is no compensation scheme like the FSCS that covers bank savings. Football Index showed what this means. When it collapsed in March 2021, customers lost roughly £100m. The independent Sheehan review found the Commission had failed to understand the product it was licensing and acted too slowly when warning signs appeared. Nobody at the Commission lost their job, and no punter got their money back from the regulator. Licences can be suspended overnight, as BresBet and Bet St George found in August 2026, and once an operator surrenders its licence, the Commission’s leverage over it largely disappears. The punter is left as an unsecured creditor. It does not help you get paid The Commission does not resolve disputes between punters and bookmakers. It will not order an operator to pay you. It sends you to an ADR service that judges the case against the bookmaker’s own terms and conditions. Meanwhile, the Commission’s own enforcement has made getting paid harder. It has fined operators tens of millions for failures on anti-money laundering and social responsibility checks. The predictable result is that bookmakers protect themselves by demanding photo ID, payslips and bank statements, very often at the point you try to withdraw. The Commission has set no limit on what operators can ask for or how long they can hold your funds while they decide. It has refused to act on restrictions Ask any half decent punter what the biggest problem with British bookmaking is and they will tell you: getting a bet on. Accounts are cut to pennies or closed simply for looking like they will not lose fast enough. The Commission’s position is that this is a commercial matter. It has proposed no minimum bet liability and no requirement for operators to be transparent about how and why they restrict. For a regulator whose objectives include gambling being conducted “fairly and openly”, that is a remarkable gap. It ignored punters when they told it what they thought In early 2021 the Commission surveyed 12,125 people on affordability checks. 77% said bookmakers should not be required to assess affordability, and only 14% said they would provide information for a check. The Commission did not publish the results. They only came out in June 2024 after a freedom of information request, and by then the policy was already going ahead. Punters are not in the room The Commission takes formal advice from three expert groups, covering academia and public health, digital technology, and lived experience of gambling harm. To sit on the Lived Experience Advisory Panel, you need personal experience of gambling harm, either your own or someone close to you. There is no equivalent panel for the millions of people who bet without a problem. In September 2023 the chair of the Culture, Media and Sport Committee, Caroline Dinenage, asked whether the panel should include people who gamble safely. The Commission’s position is that it hears from other consumers through surveys and research. The one large survey of regular punters it ran, it kept hidden for three years. It dismissed the black market When the industry warned that friction in the licensed market would push customers to unlicensed sites, the Commission’s leadership, including chief executive Andrew Rhodes, said the claims were overstated. Its own survey had already shown that most punters would refuse checks. Those punters still bet. They do it somewhere with no licence, no ADR, no ID rules and no recourse at all. Punters pay the cost, and it hasn’t worked The Commission’s rules are designed around a small minority of gamblers who have a problem, and the rest of us are treated as if we were part of it. Millions of people bet within their means, on racing, football or anything else, and they now face document requests, financial checks and friction at every step. Their experience barely features in the Commission’s thinking. That trade-off might be defensible if it reduced problem gambling. It has not. On the measures used for years, the Health Survey for England and the Commission’s own telephone surveys, problem gambling sat at roughly 0.3% to 0.5% of adults. It did not move after the £2 FOBT stake cut in 2019, the credit card ban in 2020, or the online game design rules in 2021. In 2023 the Commission replaced those measures with a new survey that produces a rate of about 2.5%, and says the new figure cannot be compared with the old ones. The result is that there is now no consistent baseline to test whether any of its policies have worked, while the larger headline number is quoted to justify more restrictions. The majority carry the cost, and there is no measurable benefit for the minority. It has grown while focusing on the wrong things None of this is for lack of resources. In March 2010 the Commission had 222 employees, and its employee costs for 2009/10 were £8.98m. By March 2025 it employed 416 staff, and staff costs had risen to £27.8m. Headcount has almost doubled and the pay bill has more than tripled in cash terms, even allowing for the Commission taking over the National Lottery in 2013. Total operating costs for 2024-25 rose 49% to £60.3m. Legal fees from litigation over the fourth National Lottery licence competition accounted for £14.2m of that, with £13.4m spent defending claims from the losing bidder. More staff and more money have gone into compliance enforcement, consultations and litigation. Customer fund protection, withdrawal standards and account restrictions have received none of it. Were we better off without it? Before 2007, casinos, bingo and machines were overseen by the Gaming Board, and betting was licensed locally. Punters were not asked for bank statements to back a horse. There were no affordability checks, no buried surveys, and no regulator claiming to act in our interests while doing nothing on the issues that affect us most. Punters were better off before the Gambling Commission existed. It has spent eighteen years growing its own budget and regulating punters instead of protecting them.