UK gambling reform

Dr. James Noyes, considered one of the most influential architects of the UK’s affordability checks, the financial risk assessments for online gamblers, has now changed sides. In an open letter to Culture Secretary Lisa Nandy, Noyes calls for the planned introduction to be suspended for the time being. He argues that the Gambling Commission’s pilot project, which has been running since September 2024, is producing inconsistent data and causing too much friction for regular players, thus achieving the opposite of its original goal.

Who is Noyes and why is his letter unusual?

Noyes is a Senior Fellow at the Social Market Foundation (SMF), a cross-party British think tank. In his 2020 SMF report and a follow-up publication in 2021, he was one of the most vocal advocates for strict financial risk assessments in online gambling. His proposal at the time was a “soft cap” of £100 in net losses per month, above which automatic checks would be triggered. His conceptual framework was a key component of the UK Gambling White Paper of April 2023, with which the government announced the most comprehensive reform of gambling law since 2005.

The fact that this same man is now calling for a pause in the implementation of the cap in an open letter to Culture Secretary Nandy is causing a stir in the British gambling debate. His support at the time was contingent on three conditions: non-invasive auditing procedures, an independent ombudsman to protect consumers, and no noticeable impact on regular gambling operations. Today, Noyes notes that none of these conditions have been met. The ombudsman position was never established. The review processes are anything but smooth. And the data from the pilot project tells a different story than what the agency claims.

How the System Works and Where Its Problems Lie

Since the end of August 2024, the UK Gambling Commission has implemented a two-tier system. The first, mandatory tier involves simpler vulnerability checks based on publicly available data, such as insolvency records or ongoing debt settlement proceedings. These checks are triggered by net deposits of £150 or more over a rolling 30-day period. The threshold was lowered in February 2025 from its initial £500, thus covering the vast majority of UK online gamblers.

The second tier, more in-depth “Financial Risk Assessments” based on credit reference agency data, is triggered by a net loss of £1,000 within 24 hours or £2,000 over 90 days. This second tier is still in the pilot phase – and this is precisely where Noyes’ criticism lies.

The first tier involves more thorough “Financial Risk Assessments” based on credit reference agency data. In May 2024, the UKGC presented interim results from the project: 97 percent of the checks were fully automated, without players having to submit any documents. 1.7 million checks across 860,000 user accounts were tested. This figure has since served the authority as a key argument for the system’s resilience.

2026

At the beginning of 2026, however, the mood shifted. Reports from the industry, particularly from the horse racing sector, spoke of inconsistent credit data, unclear evaluation processes, and noticeable disruptions to gaming operations for a significantly larger user group than officially acknowledged. A final, independently audited report has yet to be published. Noyes identifies this as the central problem: the authority’s assurances are not supported by any reliable data, and therefore, no decisive action should be taken on this basis.

Horse Racing, the Black Market, and the Limits of Player Protection The British Horseracing Authority (BHA) is particularly vocal in its criticism. And Noyes? He explicitly sides with them. The horse racing industry fears revenue losses in the tens of millions because betting customers are deterred by verification procedures or simply switch to unregulated platforms. The economic argument masks a regulatory one: those who encounter excessively high hurdles in the legal market will seek one without them. Noyes makes this point himself. Overly invasive or poorly implemented verification procedures drive players to the black market – with the result that, ultimately, there is less transparency about gambling behavior, not more. Player protection that undermines its own regulated market misses its mark.

A decision is imminent – ​​but independent evaluation is still pending

The Gambling Commission could decide on the final implementation of affordability checks later this year. Noyes’s brief is an attempt to delay this decision until the pilot project has undergone an independent evaluation.

What remains is an unusual situation: A reformer is halting his own reform. Not because he believes the goal is wrong, but because he insists on clean data before millions of players are confronted with the consequences of poorly implemented regulation. Whether the Gambling Commission shares this logic will become clear in the coming months.