James Noyes, one of the initial proponents of affordability checks for gamblers, has issued an urgent call for a pause in their implementation. Stuart Andrew MP, the gambling minister in the last government and also a former supporter of checks, agrees with him. The British Horseracing Authority has suggested that implementation could cost the industry £250m annually in revenue as punters refuse to supply personal financial information to gambling operators and shift to the unregulated black market instead.

And yet, at a board meeting scheduled for Thursday, the Gambling Commission is expected to ignore the rising tide of concern and rubber-stamp the formal introduction financial risk assessments, as the Commission calls them. Tens of thousands, and conceivably hundreds of thousands, of punters with licensed UK firms could soon be required to provide documentation on salary or assets before they can continue to gamble, despite initial promises – from Andrew, among others – that the process would be “frictionless” for all but a minority.

It is a moment of considerable threat for Britain’s racing industry, with the potential to inflict irreparable damage if punters stop betting or turn to the black market. This is despite evidence from the Gambling Commission’s own annual surveys that betting on racing is one of the safest gambling products on the market. Noyes, meanwhile, has also been clear that online slots and casino games – which are several times more likely to be associated with problem gambling – were always intended to be the main target of checks when the concept was initially proposed.

The how and why of our journey to this point is extended and not a little confused, and racing should accept at least a little of the blame.

Since the Blair government’s Gambling Act in 2005, which legitimised £100-a-spin roulette machines in high-street betting shops, fixed-margin gaming has steadily grown to dominate the gambling conglomerates’ balance sheets. Online gambling has also grown to dominate the sector, allowing operators to cross-promote casino and slots, which carry zero risk for the operator, to customers who were recruited via racing and sports betting.

They have also driven thousands of punters on to the black market already, by restricting their bets or closing their accounts altogether. While this was going on for much of the last 20 years, racing, for the most part, simply looked the other way.

In addition to the history, it is also important to remember why checks were proposed in the first place.

Problem gambling can have devastating consequences for addicts and those around them. Research has shown that 40% of gamblers with a Problem Gambling Severity Index (PGSI) score of 8 or above – indicating a high level of risk – report experiencing at least one “severe” consequence of their gambling, including relationship breakdown or committing a crime, over the previous 12 months. At the same time, just 20% of gamblers in this group have sought help from gambling support services in the same period.

The intention of checks is to identify gamblers who are at the greatest risk of harm and ensure, wherever possible, that they get the help they need. Reducing the figure of 80% who do not seek help is an urgent priority, and no form of gambling – even the weekly lottery draw – is entirely “safe”.

But a problem with checks from racing’s perspective is that they are triggered solely by spend, with no additional markers such as frequency or duration. This might, conceivably, be appropriate for repetitive, fixed-margin gaming, but it is wholly inappropriate as a measure of possible harm in betting, which has an entirely different profile in terms of profit, loss and participation. Checks designed for gaming products will, almost by definition, produce significant numbers of false-positives when applied to betting.

The gambling industry itself has been doing its best to blur the division between gaming and betting for decades. The “B” in FOBTs, the machines that turned betting shops into casinos, stands for “betting”, when nothing could be further from the truth. Again, racing played along with this for years, until the recent – successful – campaign to see off the harmonisation of gambling taxes forged a new and positive alliance between the sport and many leading campaigners for gambling reform.

You would hope that the Gambling Commission would appreciate the structural differences between betting and casino gaming. Yet a nagging concern throughout this very extended process, which started during the last government and seems set to conclude two years into the next, has been the extent to which the regulator has the necessary grasp of the issues and potential consequences, or the ability to change course if required.

Even its insistence on referring to financial risk assessments rather than affordability checks hints at a reluctance to fully engage with the debate, or divert from its chosen course. It is faintly reminiscent of a scene in The Simpsons, when a get-rich-quick con-artist tells Homer that he is absolutely not selling him a pyramid scheme. Instead, his fail-safe road to untold wealth is based on a trapezoid.

And if that reference brings back some awkward memories for the commissioners, the regulator has only itself to blame. Because the Commission did license a Ponzi, called Football Index, just a few years ago, and allowed it to continue operating for 14 months after senior executives had been explicitly warned that the platform was “an exceptionally dangerous pyramid scheme”. It was still “minting” new “shares” just days before its collapse, which cost its users more than £100m.

The Commission could now be seen to be adopting a similar fingers-crossed, hope-we-know-best approach to affordability checks.

A sporadic blog covering a “pilot” of checks was not updated between the spring of 2025 and 18 April this year, when a fresh post – five days after Noyes highlighted the extended silence – suggested that “a lot of recent commentary about financial risk assessments” had been “ill informed or inaccurate”.

The same post claimed that the pilot had implied that “less than 3% of active customer accounts would trigger any steps”, and that 97% of those would have a “frictionless assessment process”.

But there is no mention of whether these were largely gaming customers or bettors on sport, and in a country where 16% of the adult population – about 8 million individuals – is estimated to take part in online gambling in any four-week period, the potential, at least, for a grossly disproportionate impact on betting customers is clear.

The Gambling Commission was responsible for a desperate failure of regulation when it licensed Football Index. Before they vote to approve the rollout of affordability checks on Thursday, can the seven current commissioners be certain that they are not about to commit another?