UKGC Financial Risk Checks Challenged Open Letter from the BHA

How much control should the UK government have over your betting? The UKGC has been extremely active in rolling out new laws to tighten the responsible gambling initiatives, not just in standardizing tools for punters, but also taking action and enforcing limitations to help combat addiction. But as the Financial Risk Assessments pilot programme slowly nears its end, insiders are worried that its implementation into law will drive punters away from the legal betting channels. So much so, that the British Horse Racing Authority sent an open letter, signed by 400 leading figures, to rethink this ongoing pilot program and its potential implementation.

Culture Secretary Lisa Nandy was warned that the checks can be crippling to the sector, which is already reeling from the impact of tightening legislation on the ads, promotional offers and a strong tax hike (from April 2027 for betting operators). It is not just the horse racing community that is up in arms against this scheme, as MPs and commentators have also speculated on the negative impacts of such a move. The question here is whether or not they can gain support strong enough to properly challenge the Gambling Commission and limit the fallout.

BHA Sends Open Letter to Culture Secretary

This letter was coordinated by the British Horseracing Authority, which has been pretty vocal in defending the gambling industry in the past. Last year, the BHA staged a 1 day protest against the Autumn Budget betting tax proposals. It won that round, as horse race betting was excluded from the new category Remote Gaming Duty, which saw a rise from 15% to 25%. Instead, they will keep the flat 15% betting duty, and thus avoid a huge revenue shortfall. However, the backlash from the overall iGaming levy increases in the UK has spread to the horse racing industry. Just a few weeks ago Coral announced it would end its sponsorship of the Cheltenham Festival, in an attempt to cut costs.

So they have every reason to be worried about the financial checks that the UKGC is considering now. Leading figures in the sector, including trainer Lucinda Russell (of the 2023 National Winner Corach Rambler) and Robert Waley-Cohen (owner of Noble Yeats who won the 2022 National), were among the 400+ trainers, owners, jockeys and staff who signed the letter. It is being dubbed the “Save Our Bets” campaign, to help protect the sector from overregulation and losing players to the black market.

It talked about the 350 year interdependent relationship that horse racing has with betting, and that a petition waas signed by over 100,000 people back in 2024 to challenge the laws. Furthermore, it stated that a survey conducted by the UKGC stated two thirds of punters would not feel comfortable about the Commission using credit reference data to perform financial checks. The letter ended with concerns about the safety of the 85,000 jobs and £4 billion industry that horse racing makes in the UK.

UKGC Financial Enforcement and Checks

The centre point of the talks are the financial oversight and enforcement systems that the UKGC is currently planning, adding to the financial vulnerability checks that they enforced last year. These are based on user activity and spending. The UKGC wants to keep a firmer hand on the enforcement protocols and use interventions to deter punters from spending beyond their financial means. It is a just cause, but the counterargument is that this is done at the expense of the betting experience.

Punters shouldn’t have to hand over personal financial documents, or worse, have the UKGC authorities request credit data from their banks. It is intrusive, and can turn punters away from the official and regulated sources. Because there is always the option to turn to the black market sites and offshore regulators, which don’t have UKGC licences and therefore can avoid these regulatory requirements.

Financial Vulnerability Checks

Introduced: August 2024

Status: Fully Launched February 2025

The financial vulnerability checks were made live just over a year ago, back in February 2025. The thresholds were tightened down to £150 per every 30 days, targeting the low-level spending. The goal was to intentionally cast a wider net to pick out active UK punters.

• £150 net deposits over 30 days flag up

A flagged customer will be considered financially vulnerable, and operators are required to check bankruptcy registers, county court judgments and debt relief orders. They also have to monitor the customers’ behavior more closely, sending more safer gambling messages to them and even extend deposit limits on their account. While largely invisible to a player, you wouldn’t know if they were running these checks in the background, you may have encountered prompts to set deposit limits or more calls to use safer gambling tools. These signs may indicate that you are already flagged up in the system, and are being quietly monitored.

Financial Risk Assessments

Introduced: August 2025-March 2025

Status: Still in Pilot Phase

The next stage of the system is financial risk assessments, which is still in a pilot phase. It targets bigger losses, so mainly professional, regular and high rolling punters. There are two thresholds here, a daily and a monthly. Crossing either would immediately see you getting flagged up in the system.

• £1,000 losses over 24 hours
• £2,000 losses over 90 days

The 24 hour threshold is a more niche demographic, but if you consider the £2,000 target across 90 days, that spectrum opens up considerably. It boils down to losing around £155+ every week for 13 weeks. It still seems like a high figure, as this is not based on net spend but losses. So if you are betting around £100 every week, you are not going to flag up. Neither would a £200 weekly bankroll, realistically (barring normal variance). But anyone betting £300+ every week runs the risk of racking up a net loss of £2,000+ and activating this financial risk assessment.

The operators then must analyze your deposit patterns, loss velocity, behavioral changes, and compare this with external data. Data taken from credit reference agencies, financial institutions and debt-related companies. The intervention is also tiered, based on your rating in the assessment.

• Low Risk: Continue monitoring and encourage RG tools
• Medium Risk: Apply deposit limits, stake caps, and restrict promotions
• High Risk: Request financial documents, freeze or suspend account, close account if necessary

It is designed to work behind the scenes, so you may not be directly contacted about any ongoing checks or risk tier changes in your assessment. The UKGC wants to make it frictionless, but at the same time, they risk alienating customers who don’t like the idea of the Commission requesting their personal documents behind their backs and making independent financial risk checks on their spending.

Potential Outcomes of the Movement

We don’t have a deadline date for when the UKGC will decide to fully implement the pilot or rethink its strategy. Pundits put the decision making sometime in 2026, which gives the Commission several months to factor in all the impacts, positive and negative, of mandatory risk assessment.

The most likely scenario is that they go full steam ahead and roll out the checks regardless of the backlash. The UKGC may tweak the thresholds or the methods of intervention slightly, but when they did the Financial Vulnerability Checks, they lowered the thresholds after the pilot. From £500 (August 2024-Feb 2025), down to just £150.

However, if the pressure mounts and more parties get involved, the UKGC may be pushed back to the drawing board. A compromise scenario would see them increasing the thresholds, making the checks less intrusive and more compliant with the player’s needs. A good example of which are the voluntary responsible gambling apps Massachusetts rolled out, PlayWell and PlayMyWay, to help builda more transparent relationship with the customers.

The BHA will be hoping for another win here, and if they can convince Culture Secretary Lisa Nandy, they may just get a delay on the pilot programme, perhaps even a significant reworking of the terms. This scenario would really “save their bets”, and give the BHA a lifeline.

UK’s Black Market Woes

By hitting operators with tighter compliance regulations, the UKGC is suffocating the industry, at the expense of losing customers to the black market. This is an area that the UK has been struggling with for years, and overregulation can backfire in a big way. Many international jurisdictions are introducing tighter legislation, one of the most radical in Europe is Spain, with centralized player protection systems and restrictions on VIP programs, but they have not just dealt iGaming and betting operators a massive tax hike.

In the background, the UK gambling tax hikes are already rocking the industry and operators are reacting by cutting costs, scaling back on promotions and offers, and some are even resorting to drastic measures. We may see more high street shops closing, big brands relocating to other jurisdictions to curb some of the corp tax, and smaller brands considering leaving the UK entirely.

The UK needs to tread carefully here, and make a decision that can unite the market, which is becoming increasingly fragmented and headed towards instability.