Prove you’re not a problem: The UX challenge at the heart of regulated gambling

Regulation used to be seen as a back-office concern for gambling industry operators. But over time, it has moved to the very front of the player funnel, and the sign-up journey for potential new customers has become a place where compliance, product and user experience collide.  

Get it right, and player acquisition works smoothly, with new bettors flowing through the doors. Get it wrong and a potential long-term customer never spends a single penny on your product. 

With KYC (know your customer) checks becoming more prominent, along with affordability checks and tighter controls around welcome bonuses, there’s no doubt regulatory change has accelerated across the gambling landscape in recent times – particularly in the UK, where the Government’s 2023 white paper sparked much of this. 

“Today’s regulations are based on yesterday’s failings,” says Midnite’s VP of compliance, Alex Henderson. “It’s very rare that you get a regulator that says, ‘we think we should implement this new rule because we foresee this being a problem’.” 

Henderson admits it would be difficult for regulators to predict future regulation needs and praises them for their reaction speeds, but the fact remains that the onus is on operators to react, and the onboarding journey for players is where that is most visible. 

As part of iGB’s ContentOS Trends series, we previously looked at how operators are going about finding new players following regulatory change. But once they’ve got them onto their sites, how do they ensure that they don’t drop out, and actually become a regular customer? 

Setting the regulatory context 

So what’s changed?  Looking at the UK, where Midnite operates, there has been a shift from the Gambling Commission  to proactive risk prevention, in an attempt to make online gambling slower and harder to binge. Corporate compliance costs and scrutiny have increased, and public-health principles have been embedded into gambling regulation.  

A mandatory statutory levy for harm prevention was introduced last year, while enforcement activity and multi-million pound fines for operators more than doubled between 2023 and 2025.  

Wagering requirements for bonuses have now been capped at 10x, and a pilot for mandatory financial vulnerability checks was tested last year.  

The LCCP (Licence Conditions and Codes of Practice) conditions require operators to keep crime out of gambling (think anti-money laundering), ensure gambling is fair and open (with clear rules and transparent advertising) and protects vulnerable people. 

All of these are honourable purposes, of course, but an array of restrictions can make it difficult for legitimate operators to create an attractive sign-up process for normal people who want to gamble, especially when offshore bookies and casinos can access those same people without following any of said conditions. 

Are affordability checks flawed? 

Affordability frameworks, in particular, are hard to get right. Ian Perrygrove, chief risk officer at another UK-based operator, kwiff, and a former employee of the UKGC, believes the framework’s reliance on historical data including bankruptcies and CCJs (County Court Judgments) is an issue. 

 “Unfortunately, what we’ve found ourselves in currently is a position where we’re looking at data which is incredibly out of date from the moment we find ourselves transacting with a player,” Perrygrove explains. 

CCJs and bankruptcies are processes that can take years to get to the end of, and as Perrygrove puts it: “We’re so far away from when the harm is happening, this feels a very weak approach.  

“That’s where real affordability issues, consideration and risk need to be done, not in historic bankruptcy or CCJ files, which are so out of date.” 

KYC: From back office to front of house 

Identity verification has had to become an integrated part of the onboarding journey, rather than a post-registration check. That can be a problem for UX design when it is bolted on rather than built-in properly.  

A typical KYC process relies on electronic identity checks against details provided by the customer, and if these are inconsistent against third-party databases, manual documents such as ID and proof of address may be needed. 

Tristan Dexter, chief experience officer of Jurnii, a digital agency specialising in UX in the industry, has over 15 years of iGaming experience. He argues: “KYC can’t just be added onto the end of a registration; it has to be holistically reviewed again from scratch. You don’t want to overload sign-up forms or treat it as an extra step of the registration flow.” 

The Jurnii CXO believes to get it right operators should be “setting clear expectations from the get-go and providing progression steps to the user. 

“They need step-by-step instructions indicating where they are in the flow, and real-time feedback. This is one of the biggest issues because if you make a mistake in the upload, you want to know what the reason is and how you can fix it rather than just getting a generic message where you have to figure it all out by yourself,” he adds. 

“Operators should avoid long forms, no guidance and silent failures. It should reduce the uncertainty rather than create complications.” 

One of the reasons some operators get KYC right and others don’t is through proper integration between compliance and product teams. Henderson feels Midnite have got this right, explaining: “In some businesses, decisions will be made around a change to user experience, a change to product – and then compliance will be involved quite late.  

“Here, we’re involved right from the start. You end up with a compliance process that gets what you want, but in a way that is beneficial to the user experience.” 

Perrygrove believes one way to make the journey smoother is by making it more collaborative with the prospective player. “We are putting much more stock and trust into our player and the systems to give them a good journey,” he says. “Regulation does give us the remit for that. It does recognise that you’re going to make mistakes, and that’s quite nice because [previously] we had a position where mistakes were not really tolerated that much.” 

Henderson takes the view that transparency for the consumer is the most important thing within the process. He says: “If a customer knows what they’re being asked for and why they’ve been asked it, they’re more likely to comply. You don’t want them to feel like they’re complying with a process, but [rather] that they are [carrying out] a user journey. So I think the number one rule for less friction is transparency with customers.” 

Frontloading or progressive verification? 

There are differing views on whether KYC should be fully frontloaded or drip-fed into the user journey. Dexter says: “I would go for progressive KYC. You build the intent first to try and reduce that early drop-off.  

“You get the user in the door, let them explore the product, see what they like and dislike, and then earn the right to ask for more. Give contextual triggers rather than front-loading everything.” 

Henderson isn’t sure there’s necessarily a right way to approach this, quipping that “if you speak to 10 different compliance officers, you get 10 different answers”. 

“As long as you’re on top of your data, and constantly monitoring where there’s drop off, where there’s change, where there is potential friction, then whatever works for the operator is the right way to go. But it has to be agile, and it has to be data.”  

Perrygrove also thinks there’s a nuance to KYC philosophies for operators, given that risk changes the more a gambler spends with you. The kwiff CRO explains: “I don’t think it’s as simple as picking one and deciding, look, this is for me. I’m going to do it all at the beginning, or I’m going to come in dribs and drabs and try to reduce the friction.  

“You need that level of flexibility because the regulation says that when the risk changes, that’s when you need to act. And you really can’t predict the risk of one individual. En masse, maybe. But individually, you never really know who’s going to be a very active player [that will need] you need to engage much more with them.” 

Is positive friction a useful concept? 

The idea of taking positives from the regulation-enforced slow-down of player journeys to help protect them, educate them and potentially showcase your brand has been coined as “positive friction”, something of a buzzword in certain quarters of the industry. 

But not for Henderson. The Midnite VP of Compliance says: “I just don’t like the word friction. I think the customers feel that they’re in a safe environment.  I don’t think friction makes customers feel that way.  

“If I went into a shop to buy something and a sales agent asked me multiple questions… I’d know they’re doing their job, and I know that there’s excellent customer service, and it’s creating a safe environment. 

“But at the end of the day, I just want to buy the product. It hasn’t made my life any easier that I’ve had to answer questions, and it hasn’t made me feel like I’m more likely to come back here again.” 

He continues: “There just needs to be transparency and information to the customers. That way, they know they’re safe. They know they’re being protected. For me, that’s enough.” 

Perrygrove is more drawn to the idea of positive friction. He cites various responsible gambling tools created across the industry to help players take a break and slow down. He gives the example of kwiff’s ‘the curfew’. “It allows you to block a specific part of the day where you might not want to play. You might say, ‘I don’t want the distraction during my working day, so I’m going to block myself 9 till 5’,” he explains.  

“We’re building these tools but we’re always putting it for the player to decide which ones they want to use and how they want to use it.” 

Player safety and responsible gambling is clearly front of mind for Perrygrove, who says sometimes when self-control measures like deposit limits aren’t working for at-risk players, operators have to step in themselves. This might include enforcing time-outs or blocking certain products.  

He adds: “That’s pretty much mandatory in our eyes because we’ve seen across the industry where that has not worked and the harm that’s been caused by that, including extreme difficulties in families, the loss of money, loss of jobs, and even unfortunately, the loss of life.  

“I recognise that our industry has had a link to that. And we need to be pretty strong when any part of that looks like it could be happening to somebody. We want to stay as close to that as possible because it’s got a real human factor that hopefully smaller companies like ours can really recognise.” 

Dexter thinks player safety is paramount when it comes to the idea of positive friction. “If you can call any friction positive…” he elaborates. “It’s there to protect the player. It’s not there to create walls or boundaries. As long as there’s clear purpose and benefit for the user, and they’re aware of that. 

“The key is for them to remember that it’s about player safety, and build the trust and transparency around that. If it’s random or unexplained, that’s where it creates a friction, and that’s where you get the drop-offs and frustration.” 

He also sees an opportunity in the extra time created by regulation slowing player journeys down. “The more room that you’ve got to build trust in this then the more likely you are to get that user across the road,” he says. 

The blanket approach problem: Treating every player as a suspect 

A clear issue with onboarding user journeys is when the same approach is taken for all players. Identical affordability and verification approaches are seen as bad UX and bad compliance in the industry, which can divert safe players towards black market alternatives. 

Dexter makes the point that “it’s a bit like guilty until proven otherwise. The one-size-fits-all approach is [where players have to] prove you’re not a problem before you even get going. Friction should be proportional to the behaviour of the user rather than this blanket approach.” 

Henderson feels strongly about this. “If you’ve got somebody who is a sensible gambler, they’ve got no high-risk behavioural patterns. They handle their financial situation well. They’ve shown no signs of vulnerability, no signs that they’re in any way, shape or form a gambling risk,” he posits. 

“To apply a blanket approach to them, that is the type of customer that you send to the black market because they’ve come for a bit of entertainment. They can afford it. To ask a ton of questions to them about affordability and where their money’s coming from, that will drive them away because it doesn’t feel relevant or applicable.” 

He gives the example of Cheltenham Festival, where players may want to bet more than usual, and believes “annoying” them with an overly zealous affordability check would drive them away, initially to other regulated operators, but eventually, to the black market. 

Perrygrove believes some behaviour-monitoring systems employed by operators are helpful and can spot dangerous gambling patterns, even if players themselves haven’t realised yet. “We’re going to catch some players that may be on the edge,” he claims. “And there might be a point where they don’t believe that they’re on the edge. But we see it on such a holistic level, across such a wide player base, that we’ll probably be seeing it before they will.” 

The kwiff CRO isn’t sure that most players truly recognise the benefits of a good system. He continues: “We need to be smart in that area to allow a lighter touch, a bit of friction, but to say: ‘Hey, that change in behaviour, we’ve spotted it. Have you spotted it?’ And then lead the journey if it continues. We know that’s one of the systems we’re most proud of, how we’re in the background monitoring and responding.” 

The fear of black market defection 

Of course, a recurring worry among legitimate parts of the gambling industry is that of over-regulation making players leave and seek offshore, illegal alternatives. 

“Everybody in our industry is worried about the growth of the black market at the moment. It’s a massive concern for us all. It’s not an easy job for the regulator to get right,” Henderson says. 

Perrygrove agrees, and is worried about tightening regulations and the impact of tax hikes on UK operators’ offerings. He laments: “It’s terrible to think what we’re going to be doing over the next couple of years could drive people to the black market. I don’t want that. The regulators don’t want that.” 

“If you frontload, if you constantly prompt and as soon as you register, you’re met with KYC immediately, then all those kind of things which trigger at the wrong time are going to push users away.”  

Learnings from other industries 

Of course, regulatory friction when onboarding users isn’t exclusive to the gambling industry. When asked where iGaming operators should be looking for inspiration, Dexter points to fintech. “If you look at Revolut, if you want to start trading crypto or start trading with stocks on the app, you have to go through verification KYC processes. But they make it feel very seamless, very integrated. 

“And with [investment and trading platform] eToro, you can download the app, explore it, look at the market, read blogs and all that kind of stuff before you make any decisions.

“You can gain the trust of the UX and the brand, and then make the decision to make a deposit and go through a KYC process. The trigger points are different, they’re not frontloaded, but they feel very seamless and very integrated.  

“There’s definitely areas where they’ve solved problems that iGaming can take inspiration from.” 

Henderson puts it in a broader context, adding: “Consumer demand and expectation is so high. If it takes you five minutes to register an account in this day and age [you’re in trouble].  

“That’s why Amazon is the most liked product in the world. Everyone wants something and they want it now. You’ve got to make [the user journey] smooth, you’ve got to make it quick.” 

What does the future look like for onboarding journeys? The picture that emerges from the perspectives of Henderson, Dexter and Perrygrove is one of an industry still mid-adjustment.  

Regulatory frameworks exist and design principles are understood. But what remains uncertain is whether the pace of change is allowing operators the room to build user journeys that protect players without pushing them elsewhere.  

As Henderson puts it: “I think we’re going to see more operators get it wrong and then have to learn. It’s a tough one.” That might be an uncomfortable truth to consider, but it’s probably more useful than pretending all the answers are already out there. 

JS

James Swann-Phillips

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