The Gamblers Consumers Forum have serious concerns when it comes to the use of affordability checks, and will argue strongly against them.
The Gamblers Consumer Forum believe affordability checks are wholly impractical and illiberal – they infantilise a generation of adults who are effectively being told they are unable to manage their own finances, but above all, plainly and simply, they will not work in a real-world setting.
From an addiction point of view, they do not do anything to address or treat the condition, they merely attempt to temporarily halt it by blocking the ability to place a bet in the regulated market. This, naturally, has unintended consequences. According to a survey conducted by YouGov on behalf of the Betting and Gambling Council, 79% of bettors believed it would result in more people going to the black market, and they were right – black market gambling site visits trebled during the World Cup. That is an absolutely staggering figure. Even more staggering is the fact that anti-gambling activists appear very concerned by a 0.2% gambling addiction rate, but they consider what they call a ‘parallel market’ of 1% to be “low”, despite its rise.
In terms of credit checks, we believe these are being manipulated from their proper usage, and as such will produce inaccurate results. A credit check does not providean accurate financial analysis of the very nuanced financial position of each individual. After all, a person earning £40,000 in London with several children will have a very different disposal income to someone earning the same living in the North of the country without a family. Moreover, a credit check’s purpose is to ensure the likelihood of borrowed money being paid back, not as a sign off for one to spend their own money. There are already legitimate concerns that what should be a simple process of placing a bet will begin to resemble that of a multi-£100k mortgage application.
We also believe affordability checks massively disadvantage those who are self-employed, retired, or are concerned about their data privacy. This extends to those whose bank does not facilitate open banking, another way of estimating income and expenditure by decoding transactions. In other words, the infrastructure is just not there to support affordability checks and open banking, making the idea of frictionless regulations near impossible to achieve. The Irish Government have recognised this issue and have no plans to introduce affordability criteria.
Operators have privately reported that when they request documents, 80% of users decide not to provide them. The route of those individuals is either to stop betting altogether, or to divert to the black market. Indeed, the Government may see a repeat of the rush to Gibraltar as seen in the late 90s in a response to betting duty, with users registering in the Republic of Ireland under the CTA to avoid friction and checks. This would result in both a loss to the Treasury and the betting levy as a result of the tens of thousands of gamblers who will get caught up in the criteria as currently set out for when credit checks are instigated. This is why the GCF will becalling for the creation of a Government panel made up of ordinary gamblers, independent bookmakers, and sporting industry representatives to directly influence Government policy concerning gambling, so ensuring there is a balanced conversation based on knowledge and expertise.
The GCF’s fear is that the Government with continue to push ahead with affordability checks, despite evidence this would be a wholly unreliable and disingenuous method. The Gambling Commission themselves cite a University of Liverpool study that shows “that over the course of January 2017, there were 22,080 individuals losing in excess of £1,000 on slots, whilst for non-slots play, there were 10,373 customers losing in excess of £1,000”. Unfortunately, The Gambling Commission then conveniently omits the caveat found in the original report: “The data tell us nothing about these individuals. Some may be sufficiently wealthy that losses of this magnitude are not important to them. Others might have been returning to the operator large wins earned in the preceding month”.
To conclude, the barrier to achieving the Government’s aim are that they are a solution to a problem that does not exist – a world where the vast majority of people who gamble are harmed by it. Affordability checks are tools to please a fantasy of the anti-gambling lobby that cannot ever come to pass: where gambling harm is completely eliminated. What is almost inevitable is that it will reduce levels of gambling overall by non-addicts, deeply harming the industries gambling and betting turnover support, and will likely increase black market activity in addicts. Ultimately the main barrier is this: the belief that preventing gambling activity will prevent gambling addiction. The most likely outcome of this is a movement by addicts to the unregulated market, or a movement by addicts to another addiction, which arguably, actually makes the problem worse.