Prominent reformist figurehead Dr James Noyes has urged the Department of Culture, Media and Sport “to hit pause” on the use of financial risk checks on gambling.

A senior advisor of cross-party think tank the Social Market Foundation (SMF), Noyes has raised direct concerns to DCMS Secretary Lisa Nandy over the transparency and effectiveness of the pilot scheme that has been rolled out by the Gambling Commission.

Noyes is a vocal former supporter of affordability checks during the long-running Gambling Act review consultation. He is now warning that the current implementation risks are drifting away from its original intent of being “frictionless” and proportionate, as set out in the review’s White Paper in April 2023.

“Despite the White Paper’s claim that financial risk checks would be frictionless, recent reports suggest that the opposite is the case,” Noyes wrote, adding that he is seeing “increasing reports that the pilot scheme has involved inconsistent data, unclear outcomes and unnecessary friction”.

He further cautioned that there has been “no update on the financial risk assessment pilot, or its evaluation, since May 2025”, raising concerns over transparency.

Noyes also highlighted industry claims that “credit reference agencies are yielding different results for the same customer” at an insufficient level of data to accurately assess risk.

Today I sent an open letter to the Secretary of State for Culture, Media and Sport, @lisanandy — calling on the Government to pause the implementation of financial risk assessments for bettors until a proper evaluation of the Gambling Commission’s pilot scheme has been published… pic.twitter.com/75IkUA1rOT

— James Noyes (@jranoyes) April 13, 2026

Losing faith

Beginning in August 2024, the Commission initiated the first phase of its pilot on “light-touch” financial vulnerability checks, set at an initial threshold of £500 net deposits over a 30-day period.

The scheme was tested over six months, before being expanded in February 2025 in which the threshold was lowered to £150 – bringing it in line with player protection measures outlined in the Gambling Act Review White Paper.

Though the Commission has maintained that it has progressed the pilot and its light-touch checks, it has yet to deploy a full rollout of financial risk assessments across online gambling licensees, leaving a key mandate of the Gambling Review incomplete.

Industry stakeholders from across the UK racing space, including the British Horseracing Authority (BHA), have been the most vocal in their objection to such stringent financial checks. 

In the last few weeks, the BHA has particularly emphasised that the measures could reduce betting engagement and inflict economic harm on the sport.

Last week, ahead of the Grand National at Aintree, UK racing once more intensified its opposition to affordability checks. 

Racing stakeholders argue that financial risk checks will reduce betting turnover on smaller fixtures and undermine key funding – which could see UK racing face an annual deficit in the range of between £250m and £300m. 

Westminster Divide

In parliament, the issue has divided opinion. Both DCMS and Labour figures maintain that the Commission must be allowed to test the checks in a live environment. 

Meanwhile critics across the floor have labelled the scheme as being an overreach into consumers’ personal finances, arguing that regulators should prioritise targeted interventions on high-risk harm instead.

On the use of checks, Noyes commented: “While there was a practical benefit to establishing a standardised threshold at which checks would be triggered, my 2021 report argued that such a threshold should not automatically equate to a limit on monthly spend.

“Furthermore, we argued that any threshold should be applied to net losses rather than total stakes – meaning that the actual figure would be significantly higher than the vast majority of gamblers spend.”

Despite his criticism of the current rollout, Noyes emphasised that his support for affordability checks remains rooted in their original design of being frictionless.

“My support for affordability checks was done on the basis that there would be adequate oversight and evaluation of their efficacy, and that the checks would be carried out in a non-intrusive manner,” he said.

No progress on shared data or ombudsman

The SMF has long been a key voice in shaping UK gambling reform, advocating for proportionate, data-led regulation rather than blanket restrictions. 

Its early proposals for affordability checks stressed that measures should be non-intrusive, targeted at a minority of at-risk consumers, and based on net losses rather than total spend.

Beyond affordability checks, the think tank has supported broader structural reforms, including the introduction of a statutory levy which would be brought under public oversight and given stronger separation from industry influence. 

The think-tank has also backed the creation of an independent gambling ombudsman and greater data-sharing between operators and regulators to improve consumer protection outcomes – a scheme that should be safeguarded by an independent body. 

“Our call for affordability checks was made on the basis that an ombudsman would be created, that the checks would be non-intrusive, and that while preventing serious cases of harm from happening they would not impede the majority of gamblers from engaging in a lawful activity which involves inherent risk, economic agency and their own money.”

In its policy direction, the SMF continues to argue that the future of UK gambling regulation must be built on enhanced use of real-time data to identify harmful play and deliver more precise, one-to-one interventions.

Noyes concluded that without greater transparency, consistent data and proper oversight, it remains uncertain whether the current pilot can deliver on the White Paper’s promise of proportionate, frictionless checks.

“Despite the White Paper’s claim that financial risk checks would be frictionless, recent reports in the media suggest that the opposite is the case. There has been no update on the financial risk assessment pilot, or its evaluation, since May 2025.

“Of particular concern is the claim by some betting operators that credit reference agencies are yielding different results for the same customer and at an insufficient level of data to adequately profile risk.”

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