No one can say they weren’t warned. For years, bookmakers, punters and the horse racing industry have tried to explain, with increasing desperation, why affordability checks are dangerous and unworkable. At every turn, the Gambling Commission has covered its ears. This week it confirmed it will push ahead with intrusive financial checks on people simply trying to have a bet. This unelected, non-departmental regulator, which currently doesn’t even have a chairman or a chief executive, is telling us how we can spend our money. Naturally, Labour’s Gambling Minister Baroness Twycross welcomed the news.
Now it’s time to face the consequences: a rush of gamblers to the black market, where they will pay no tax and where there is no safeguarding in place, and an estimated £250m hole in racing’s finances. It is a strange, sorry act of selfharm.
‘For this decision to be taken unilaterally by the Gambling Commission shows a clear abdication of duty by the Department for Culture, Media and Sport, which has failed to grip this process or properly consider the damaging consequences of the decision,’ said Brant Dunshea, chief executive of the British Horseracing Authority.
Before sifting through the wreckage, it is worth looking at the numbers. In stage one, due to be introduced next year, punters who exceed a net deposit of £5,000 in a 24-hour period will be subject to a Financial Risk Assessment (FRA), carried out by credit reference agencies. For customers under the age of 25, this limit is reduced to £2,500. After what the Gambling Commission vaguely describes as ‘further engagement with implementation groups and stakeholders’, these limits will contract again: FRAs will be applied to customers whose net deposit exceeds £1,000 (£750 for under-25s) in a 24-hour period or £3,000 (£2,000 for under-25s) in a 90-day period.
These figures might seem high and it’s certainly true that someone having a tenner on the Grand National won’t be affected. But the Betting and Gaming Council (BGC) estimates that as many as 120,000 racing punters will meet these thresholds; 96,000 of them would, it is projected, refuse to provide bookmakers with financial documents.
The Gambling Commission’s claim that FRAs will be ‘frictionless’ (i.e. no documentation would be needed) was undermined by its own pilot scheme, leading to James Noyes, senior fellow of the Social Market Foundation, whose proposals were included in the 2023 white paper on gambling reform, to pause his support for affordability checks until there has been ‘adequate evaluation and scrutiny’.
Shadow culture minister Louie French added this week: ‘The mandate which was given, rightly or wrongly, by the previous government, supported by ministers in this government, was that these checks could go ahead only if they were truly frictionless… The words of the minister on the floor of the house yesterday and the Gambling Commission’s own analysis show that that can’t be delivered.’
So let’s say nearly 100,000 punters refuse to comply with affordability checks. Then what? These people, many of them professional punters, aren’t simply going to stop betting. Nor are the problem gamblers these affordability checks are supposed to help. No, they will take their money elsewhere, specifically to unlicenced bookmakers on the black market. No help for vulnerable gamblers. No tax for the Treasury. And this is where horse racing loses out, to the tune of £13m a year, since a percentage of every licensed bet’s stake is returned to the sport via the Horserace Betting Levy Board.
In fact, the number of punters moving to the black market has already increased dramatically in recent years. As reported by Bill Barber in the Racing Post, research by H2 Gambling Capital (H2GC) shows that ‘offshore gross gambling yield had increased to an estimated £685m in 2025 from £200m in 2019’.
‘The racing industry’s concern has always been the law of unintended consequences,’ a senior figure in racing tells me. ‘No one in racing is going to say that people with a problem shouldn’t be helped. But you have to understand that a lot of punters will just opt out of the regulated market. That’s bad. Full stop.’
This is not hyperbole. Racing is already suffering because of Labour’s tax rises on the gambling industry in the last Budget
But even if you do support the concept of affordability checks, the Gambling Commission’s thresholds make little sense. ‘It’s about wanting to be able to point to having tackled the problem, rather than actually tackling it,’ the senior racing figure says. Take this example. If you were to bet £100 a day on three short-priced favourites, you might in the long run break even, or more likely incur small losses. But you would comfortably meet the Gambling Commission’s 90-day threshold of £3,000 net deposits. Compare that with a punter betting, say, £20 a day on three- or five-fold bets (accumulators), which more closely resembles the behaviour of a problem gambler, and they are almost guaranteed to be a significant loser. Yet there would be no intervention, as they would fall way below the threshold.
‘I often deposit more than the threshold,’ professional punter Neil Channing tells me. ‘I’ve done that for a 12-year period, while showing no signs of harm. How am I suddenly a problem gambler? Of course I have sympathy for problem gamblers, but I’m concerned that gambling as a pursuit is being killed in this country – and horse racing as a sport will probably be killed because of that.’
This is not hyperbole. Racing is already suffering because of Labour’s tax rises on the gambling industry in the last Budget. Bookmakers have withdrawn race sponsorship and reduced prize money; high street stores have closed. It all means fewer people are betting on racing and less money is going back into the sport, which will inevitably mean job losses at yards and racecourses. You cannot attack gambling and expect racing not to get caught in the crossfire.
And if the Budget was the tremor, the introduction of affordability checks is the earthquake. Racing can’t survive much more of this. My question is simple: does anyone in government care?
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