Concerns are mounting within the UK gambling sector that affordability checks introduced by the UK Gambling Commission (UKGC) are accelerating migration of bettors towards unregulated markets, raising wider questions for global regulators balancing player protection with channelisation.
Leading British trainer John Gosden has warned that policymakers are underestimating the scale of black-market growth linked to increased compliance requirements on licensed operators.
Gosden says: “These checks force people to the black market, where there are no protections. With the best will in the world, affordability checks are already pushing people into unprotected places, and that is tragic in itself.”
The debate centres on affordability assessments designed to identify harmful gambling behaviour, a model being closely watched by regulators in multiple jurisdictions exploring similar interventions.
Brant Dunshea, CEO of the British Horseracing Authority, has also criticised the current approach, calling for greater transparency and engagement from regulators as pilot programmes move towards potential wider rollout, adding: “The Gambling Commission needs to be open and honest and engage with stakeholders to understand the realities of this.”
Industry data points to growing resistance among consumers. A survey by the Betting and Gaming Council suggests that two-thirds of bettors would be unwilling to provide documentation if required, while estimates indicate that as much as £100m may have been wagered with black market operators during the Grand National.
The UK government has allocated additional funding to tackle illegal gambling, but enforcement challenges remain significant. Investigations have highlighted the ease of access to unlicensed platforms, including weak identity controls and widespread promotion via social media channels.
The UKGC maintains that its pilot programme has delivered encouraging results, emphasising the potential for frictionless and low impact checks. However, critics argue that even limited intervention can trigger wider account restrictions, undermining the intended user experience.
For the global industry, the UK’s experience is becoming a test case. As regulators seek to tighten controls around player affordability and harm prevention, the risk of unintended consequences, particularly displacement of activity to unregulated markets, is emerging as a central policy challenge.
