
Almost a quarter of gamblers in the UK would have theoretically triggered affordability checks from operators, as part of a study that ran in the year to March 31, 2024.
Affordability checks were proposed as part of the government’s 2023 White Paper, which suggested a number of gambling regulatory reforms. Light touch vulnerability checks were initially triggered when a player spent £500 in a month as part of a trial that began in August 2024, and from February 28,2025, this decreased to £150 spend in a month. This was higher than the White Paper’s suggestion of £125 in a month or £500 in a year.
Enhanced checks are triggered when a player makes a net spend of £1,000 within 24 hours and £2,000 within 90 days. A pilot scheme ran for six months from August 2024. In the interim period, a new industry code on checks was agreed, detailing financial documents should not be required before net annual deposits of £25,000.
The study aimed to provide information on three key areas; the first was the prevalence of players exceeding the threshold to trigger financial checks; the second was the demographics of players who exceeded the threshold; the third was behavioural subgroups that were identified via a cluster analysis.
The researchers assessed bank transaction data from 243,478 UK-based gamblers, in an attempt to characterise the number that would exceed the £150 spending threshold in any given month. The study found 24% of players met the threshold, and that these players contributed to a majority of the gambling expenditure within the cohort at 92%.
The exceeding threshold gamblers (ETGs) were said to be disproportionately male, younger, and exhibited significantly greater involvement in gambling activity. The cluster analysis revealed three ETG subgroups, with almost half classified as diversified spenders whose gambling appeared proportionate to income and part of broader discretionary spending.
However, others showed patterns that were more consistent with potential financial vulnerability.
The gamblers within the study spent an average of £1,804.47 on gambling over the 12-month study period, with a median of £108 for a total expenditure of £439.3 million across the sample. Gambling spend accounted for about 17% of these users’ overall leisure spending and 7% of their estimated income.
The gamblers were active in gambling-related transactions for less than half the time in the study on average at 5.32 months, making approximately 81 debit transactions and 12 credit transactions.
While the study pre-dates the implementation of affordability checks, it provides an outline of the industry’s base position going into the change in regulations and sheds light on the sheer number of players that could potentially require monitoring when it comes to gambling spend.
The researchers mentioned how open banking data can help lead to greater understanding of consumer behaviour, as it offers the ability to aggregate an individual's financial data across potentially all of their checking, savings, credit, and other accounts.
Regulator the Gambling Commission has singled it out as a method that could provide operators with a potentially more frictionless pathway for the growing number of players who use it.
The study was published in ScienceDirect and is authored by a team of researchers including Charles Cohen, a former Vice President at supplier IGT who is now Founder and CEO of compliance and KYC provider Department of Trust; Cohen is also a member of the Gambling Commission Industry Forum.

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