GCF flags concerns over Gambling Commission affordability check data

In a letter to the UK Statistics Authority, the GCF seeks clarification on recent data from the Commission. This includes the fact that over a million accounts will be impacted by putting in place stricter affordability checks.

The GCF is also requesting comment from the Authority on the methodology behind the statistics used by the Commission.

Stronger affordability checks were put forward as one of several proposals in the Gambling Act white paper published in April. The GCF says that as government policy is being dictated by these figures, it is “exceptionally” important data is presented with context.

“The proposed policy changes are predicated on the premise that ‘only 3%’ of betting accounts would be subject to checks,” the GCF said. “The CEO of the Gambling Commission has made this claim on several occasions most recently in both the CMS Select Committee and in an open letter to Racing Post readers last week. 

“This figure is being used both to assuage opposition to affordability checks, and as a means to promote the concept of ‘frictionless’ checks, despite the fact, based on evidence where affordability checks are already taking place, this is practically impossible.”

In the Commission’s consultation papers, a table suggests 600,000 accounts will be subject to checks through binge gambling. A further one million face checks over “significant losses” in previous years. 

GCF asks regulator consider figures quoted by Gambling Commission

The GCF said while accounts would meet both these criteria simultaneously, it is asking the Authority if it agrees that more than one million accounts face enhanced checks.

“If that is so, then we would welcome further comment on the 3% claim and how the Gambling Commission, and also the government who take their figures from the Commission, have arrived at such a figure,” the GCF says.

“We believe this figure is being used to privilege a hypothesis that affordability checks will work, despite their unproven track record in combating addiction and the underlying fact addiction cannot be characterised by losses.”

The GCF also says that it believes the Commission is using figures to support a proposal it is already committed to. This, it adds, “seriously” distracts from clinical methods that will tackle addiction. It also says it undermines trust in the democratic process of the consultation.

Concerns over methodology used to collect data

As to how this figure was reached, the GCF said it understands it was based on research by the Commission. This looked at 5.86 million accounts across an unspecified number of operators between May 2020 and April 2021

In the same period, the GCF said, there were 32 million active online gambling accounts operated by licensed operators. 

“The referenced data is sparse, as it just gives the resultant numbers, for example total number of active customers that reached the following net expenditure during any rolling 24hr period,” the GCF said.

“They give for loss exceeding £1,000 that there were 116,880 active customers. The maths then equates to 116,880/5,867,022 = 0.199 = 2%. There does seem to be a difference between the number of active accounts that the Commission give in their industry data, 32 million and what they are using in this calculation where they consider the number in their sample to equate to 19% of the population, so giving a total number of active accounts as (5,867,022/19*100) 30,879,063.

“The Commission, we understand, have said that there is no reason that player activity found in these accounts, expected to be from the five biggest operators, should be the same for all operators and also state ‘each expenditure limit should be considered in isolation from the others’.”  

However, the GCF also raised the issue of how the Covid-19 pandemic impacted this data. It said that, as the UK faced lockdowns restrictions during the period, this will have “undoubtedly” impacted patterns of online play.  

As such, the GCF says the Authority should consider whether using this period of time was appropriate. It said an alternate period of May 2019 to April 2020 would have served as a more accurate sample.

Multiple accounts could also impact data

In addition, the GCF said that the research fails to reference how many people have multiple accounts. The GCF says data should report the number of people impacted as a percentage rather than number of accounts

“We would argue that using the latter only serves to reduce the percentage number but give little indication of the number of individuals who will be subject to checks. 

“While in part anecdotal, in a recent Racing Post survey of 9,000 active bettors, 16.6% have been asked for documentation as part of an affordability check. It is this variance that concerns us regarding the way the Gambling Commission are using statistics as they themselves have stated their concerns about the ‘misuse of statistics’.”

Commission clashes with Racing Post over affordability checks

The news comes after the Commission last week published an open letter to Racing Post readers in an attempt to “clear up misunderstandings” about the consultation on financial risk checks.

The regulator accused the racing and sports betting publication of providing readers with “imbalanced stories”. Additionally, the Commission said the newspaper had “refused” to publish a letter from the authority responding to the coverage.

In response, Racing Post editor Tom Kerr released a statement on X, formerly Twitter.

“We told the GC we were unwilling to publish a letter if it misrepresented disagreements over our coverage as errors of fact,” he said.

“That is precisely what this letter does. It simply repeats contentious assertions from the white paper and consultation without engaging with the numerous concerns raised by Racing Post readers and contributors. In fact, it dismisses those concerns as groundless.”