How no-wagering casinos could help mitigate financial risk without heavy-handed affordability checks

Affordability checks for gamblers are the most controversial issue of the year, and one everyone has an opinion on. The proposals have caused so much concern that Gambling Commission Chief, Andrew Rhodes, even had to pause mid-consultation and release a video to clear up the misinformation among stakeholders.

There are many ways that the Gambling Commission has tried to ensure players gamble within their means without inputting benchmarks for financial checks (having rules for customer interactions, banning credit cards in gambling, threatening to ban VIP schemes that were misused, targeting bonus terms, and more). Still, by and large, the industry has failed in the past, either not reacting to overspending or responding too slowly when consumers spend what is beyond their ability to afford. 

With the implementation of affordability checks now on the horizon, many stakeholders are again looking to other ways gambling sites can help mitigate financial risks without affordability checks.

Proposed checks

The past failures to protect players from overspending at gambling sites have led MPs to address the issue in the Gambling Act Review. The initial proposals published in the White Paper suggested the following benchmarks.

  • Light touch financial vulnerability checks: These would be conducted at £125 net loss within a rolling 30-day period or £500 within a rolling 365-day period.

  • Financial risk assessments: Would be conducted when losses are greater than £1,000 within a rolling 24 hours or £2,000 within 90 days. 

  • The government has also proposed that the thresholds for players aged 18-24 should be lower, with the exact amount established during the Gambling Commission consultations.

Before the Gambling Act Review proposals become official, each is open to public consultation conducted by the GC. The consultations aim to open the proposals to stakeholder opinion and ensure the new regulations are robust and fit for implementation.

The debate

There’s been a fierce and ongoing debate regarding affordability checks in the media and among stakeholders. This has fanned the flames and raised concerns among gamblers and stakeholders about invasive financial checks.

The overriding concern has been that these checks, twinned with low slot stake limits (also suggested in the White Paper), will provide emphasis for gamblers to leave the legal market attempting to avoid checks and expose themselves to greater risk. There is some causal evidence from other jurisdictions that tightening restrictions can coincide with a growth in offshore gambling. Players have expressed concerns about sharing financial information with operators.

The other side of the debate, recently highlighted by GamCare, says the proposed checks are not robust enough, as they do not include a “single customer view” element. According to the gambling addiction charity, this means those who want to evade affordability checks can simply join multiple operators, avoiding the financial benchmarks with each. In the worst-case scenario, this could lead to losses as significant as £10,000 within 24 hours under the current plans.

The Gambling Commission’s position

The concern that affordability checks will cause a rise in offshore gambling has been dismissed by the Commission multiple times, but most recently at the beginning of the month. Addressing industry stakeholders, Commission Chief Andrew Rhodes hit back against this popular narrative, stating, “The debate on gambling has been exceptionally hard to engage in during the past year. We have challenged people where they have misrepresented statistics and we have sought to bring some balance and evidence to the arguments. Everyone is entitled to their opinion, but some of what has gone on has been an unedifying sight. I am not sure [it] is helping anyone.” 

For the most part, the Commission believes that business concerns shouldn’t prevent it from acting to stop gambling harm. They are also working harder to clamp down on access to illegal gambling sites, collaborating with jurisdictions worldwide, and targeting the most popular offshore casinos.

Turning to other approaches

While the public consultation period on affordability checks is officially over, a parliamentary petition against them was instigated by Nevin Truesdale, CEO of The Jockey Club. This week, it reached the 100,000 signature threshold, meaning MPs will again have to consider the issue in parliament. No other area of the White Paper proposals has been similarly challenged.

The petition calls the measures “discriminatory” because bettors may have to prove they can afford a hobby that incurs losses of just £1.37 per day—the aim is to increase the threshold for financial risk assessments.

While it’s unlikely the petition will end affordability checks, it is considerable and shows just how contentious the issue is. With this in mind and the steps taken industry-wide over the last twelve months to improve gambling safety and cut cases of extreme harm, it is essential to consider what other sustainable strategies gambling sites can use to help mitigate financial risks.

No-wagering casinos

No-wagering casinos are a great example of how operators can put player sustainability and safety first. The Gambling Commission has been committed to reforming bonuses and wagering requirements and promoting fairness and transparency for players for a long time.

The core offering at these casinos is no wagering bonus offers, which encourage sensible spending and allow players to gamble at their own pace. In contrast, wagering requirements tend to increase spending frequency so players can use a bonus and meet the subsequent withdrawal restrictions. 

Additionally, no-wagering sites focus on simple terms and conditions that are easy to understand and transparent. This gives players greater autonomy and awareness of their gambling while reducing financial harm. 

Therefore, a no-wagering casino provides players with a safer way to gamble and may mean players can avoid what they view as intrusive and limiting financial checks. Another strategy that would be favorable is giving more extended validity periods on bonuses, as this also encourages a reduced pace of spending and, therefore, potential losses.

Lower stake games and mandatory responsible gambling tools

Casinos can also encourage responsible play in other ways, such as offering lower stake limits on games, lower withdrawal and deposit thresholds, and mandatory opting in or out of responsible gambling tools, like betting and loss limits. 

Large-scale research has found that by making it mandatory to opt in or out of these tools, more players are aware of their spending and use them to their benefit. Those financial check-averse consumers can also use loss limits to monitor when they are approaching the threshold upon which an intervention would be triggered.

Interestingly, despite many repeated calls for responsible gambling tools to be made more attractive to players and more accessible to implement, little action has been taken in this respect.


With most industry stakeholders against the current proposed financial risk assessments, the government must consider this policy more carefully and seek a more balanced approach. 

No-wagering casinos present a promising way to protect players through transparency, fair terms, and greater financial autonomy. But challenges still exist. If the government goes ahead with its current plans, the industry must find a way to address player protection concerns without relying on limiting affordability checks. 

The last year has seen great collaboration between regulators, operators, and responsible gambling organizations, which has caused a reduction in the most severe gambling harms. If this spirit of cooperation continues, centering around ethical practices, it will likely pave the way for a stronger self-governed, player-centric model.