Financial Vulnerability Checks: the Two Thresholds and What Is Not Asked

The two thresholds, and when each began

The check is a requirement of the Commission's social responsibility provisions on customer interaction, and it was introduced in stages at two levels of net loss, measured as deposits minus withdrawals over a rolling thirty-day period:

• £500 net loss in 30 days, from 30 August 2024 to 27 February 2025.
• £150 net loss in 30 days, from 28 February 2025.

The lower figure is the one in force. Both were deliberately set against net loss rather than deposits, so that a player who deposits £2,000 and withdraws £1,900 is nowhere near the threshold, while one who deposits £200 and withdraws nothing is past it.

What the check actually consults

This is the part that is persistently misdescribed. The assessment is designed to be frictionless: it looks for a small set of indicators that already exist on the public record, and it does not ask the player for anything. The indicators are the markers of serious financial distress recorded publicly:

• Bankruptcy orders
• County court judgments
• Individual voluntary arrangements
• High Court judgments
• Administration orders
• Debt relief orders

What it does not look at is as important as what it does. It is not an affordability calculation, it does not read an income figure, it does not inspect a bank account, and it does not consult a credit score or a repayment history. A clean public record passes, and the player is not told a check occurred.

It also does not affect the player's credit standing. The assessment is a check on public records, not an entry in them, and it is not a credit application.

The thing it is not: the affordability request

The request a player does notice — upload a payslip, a bank statement, proof of income — comes from somewhere else entirely. Operators have separate and much older duties to interact with customers where their play suggests harm, set out in the Commission's customer interaction guidance for remote gambling operators. Those duties are risk-based rather than threshold-based: they can be triggered by patterns of play, by time of day, by chasing behaviour or by a single large change in staking, at sums far below or far above £150.

A third category exists again beyond both: anti-money-laundering due diligence, which arises from the licensee's obligations under licence condition 12.1.1 and the Money Laundering Regulations 2017, and which asks about the origin of money rather than about capacity to lose it.

Three different duties, three different triggers, three different document sets. A player who has been asked for a bank statement has not hit the £150 threshold — they have been contacted under one of the other two.

The one that did not happen

Alongside the vulnerability check, the Commission consulted on financial risk assessments: a heavier, data-matched assessment at higher levels of loss. Those were piloted rather than introduced. There is no live requirement on GB operators to run a financial risk assessment, and coverage that describes British players as subject to mandatory affordability checks at a fixed figure is describing the pilot, not the rule.