What gaming operators need to know about basic financial vulnerability checks

New rules are on the horizon

Operators have long found it challenging to accurately identify customers who are at risk of problem gaming behaviours. To help keep players safe, the GC wants operators to take a more robust approach to identifying financial vulnerability.

Starting from 30 August 2024, all licensed operators that offer remote play in the UK will have to introduce mandatory financial vulnerability screening. If a player deposits £500 within a 30-day period, operators will need to investigate whether they’re at risk of problematic gaming based on their financial situation.

Its intention is to prevent financially vulnerable customers from slipping into problem gaming without support or intervention from operators. Having a pre-defined deposit threshold will make it easier to identify those who aren’t in control of their play and ensure they’re offered the right level of support.

What does this mean?

The new checks are considered ‘light touch’ and designed to be frictionless. They use publicly available information, such as bankruptcies and IVAs, to assess if players are in financial difficulty. This data will give businesses a more nuanced understanding of a player’s financial health, and if levels of play are responsible for each individual.

After investigating, operators must take action in line with the GC’s refreshed Social Responsibility Code, which could include pausing the account or offering the player support for problem play.

The thresholds will initially be higher than the Commission first proposed before dropping to £150 from 28 February 2025. Many operators were surprised by this decision, but it has likely been taken to make implementation within a short timeframe realistic. A higher limit means a smaller pool of customers will need to be checked, reducing the pressure on companies as they increase resources and set processes for compliance. It will also allow operators to refine how they source and process public information en masse.

Other proposals, such as using postcode and employment data, are absent from both the mandatory checks and enhanced pilot. It’s likely that they’ve been deemed unsuitable for something as individual as gaming, potentially failing to protect higher income problem players or unfairly penalising those in financially deprived areas.

Trialling enhanced checks

At the same time, the GC will commence a pilot of enhanced checks with a selection of large operators in the highest three license fee bands. Lasting until 30 April 2025 at the latest, this trial period will ask operators to carry out enhanced checks on customers based on credit reference agency (CRA) data.

Operators will need to work with at least one of the UK’s three CRAs, including Experian, to understand customers’ risk profiles. This will be created based on information held by the CRAs, such as payment history, level of credit utilisation and aggregated current account turnover data (CATO).

In the first two phases, which will begin on 30 August, operators will need to check customers who spend more than £2,000 in a rolling 90-day period. In the third, which currently has no start date, the criteria for checks will also include those who spend £1,000 in 24 hours. These limits will likely be adjusted during and after the pilot to ensure they’re both effective and reasonable.

Easing operators in

As the GC only delivered its public consultation response on 1 May, operators have just a four-month window to comply. The timeline isn’t the only challenge, however. Smaller operators may not have robust or streamlined processes for protecting vulnerable customers. It’s vital they prepare to formalise how they act in customers’ best interests at the right time.

For larger operators who are participating in the pilot, the challenge will be precision to avoid false positives and unnecessary intrusions on play.

With more players flagging up for checks, it will be very important to optimise and analyse the checking process. Players who have missed payments due to carelessness or temporary hardship, such as redundancy, may now be in good financial health. If they enjoy high levels of play but have a strong income and no other signs of vulnerability, intervening could drive customers away unnecessarily.

Preparing for change

Compliance with the new basic check rules (and the pilot for selected operators) will be a condition of their license, so it’s incredibly important that operators are prepared. So, what should gaming operators prioritise as they prepare to meet this short deadline?

Deploying the right solution will help operators comply in the short term and lay foundations for a long-term, strategic approach to player vulnerability checks. Using a plug and play solution from a CRA like Experian is a great way for operators to quickly make sure they’re ready to start checks. A single API-based solution can help them carry out a suite of KYC (know your customer) and anti-money laundering checks, and it can evolve as regulations do.