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  • Writer's pictureKevin Jones

Striking a Balance: How Technology Can Streamline Affordability Checks for Gambling Operators

Affordability checks are an ongoing requirement for operators, but frequent changes or new regulations can create challenges for balancing customer acquisition and retention with compliance to avoid significant fines. In today's data-driven society, checkpoints and data collection are commonplace to assess the suitability of potential customers. Though there is a fine line to how time consuming and intrusive this process can be for a potential customer.

Interestingly, the mainstream media appears to be emphasising this issue, as seen in a recent article published by the BBC in line with potential government changes in the UK. It's worth noting that the nature of this industry appears to always receive a different type of attention in comparison to say, the situation with affordability checks for mortgages back in the 2000's which did not receive as much until it was too late, but that's a topic for another discussion.

So why such attention on affordability check for Gambling Companies?

Some of the key rational used is that gambling companies that implement effective affordability checks can benefit from a competitive advantage through:

  • Demonstrating a commitment to responsible gambling practices, which can build trust and loyalty among customers.

  • Enhancing their reputation and brand image, which can lead to increased customer loyalty and more sustainable revenue over time.

  • Reducing the social costs associated with problem gambling, such as financial hardship and mental health issues, which can minimise losses from customers who may become addicted.

  • Identifying potential problem gamblers early on and intervening before harm occurs, which can help to reduce the risk of negative publicity and damage to the company's reputation and brand image.

What about Intrusiveness and Personal Data?

This is where the challenge for operators happens and getting to grips with the most efficient way you can make the process smooth for a customer, but at the same time balancing between ensuring correct affordability check data points are collected and that personal data protection is in place with that information. (We did a feature on data protection here)

One question to ask is how deep do you go with personal data and can these checks be intrusive beyond what is required and would someone be comfortable providing that level of information, just to place a bet?

A lengthy and complicated affordability check process can be a deterrent for customers who are seeking a seamless experience. More so, If your process takes longer than your competitors', you may lose customers to other providers who offer a quicker betting experience.

Driving activity to Black Markets

There is a growing concern that more intrusive affordability checks within the gambling industry could potentially lead to an increase in black market activity (still up for debate). The UK The Betting and Gaming Council (BGC) at the back end of last year release a detailed report on this with EY.

The study, said these pressures, “could in turn lead to leakage to the black market, i.e. operators offering remote (mainly desktop and mobile) gambling products that do not hold a UK Gambling Commission license for remote gambling.”

CEO of the Betting and Gaming Council Michael Dugher, said: “But without Government clarity on affordability checks, our members are concerned they are driving frustrated customers to the unsafe, unregulated black market"

According to a more recent study conducted by BGC, the World Cup hosted in Qatar saw a major increase in black market betting. The research revealed that the number of UK gamblers visiting unregulated online black market betting sites increased substantially during the World Cup.

According to industry experts, signing up to a black market site and placing a bet takes less than 30 seconds, whereas regulated UK operators require an average of 12 minutes to conduct thorough identity and age verification checks to prevent problem gambling and fraud.


Gaming Eminence got in touch with Charles Cohen CEO and Founder of player affordability solutions provider DoTrust with a few questions on this topic.

GE) In your opinion, how do you think that stricter affordability checks can influence customers to switch from regulated to unregulated markets?

CC) It’s about the pain threshold. The way checks have been done in the past was like dentistry without the anaesthetic. Even the operators don’t like doing it and they know they are losing customers. Some probably are going offshore – which is the worst result for everyone.

GE) From the perspective of affordability checks, which emerging technology should gambling operators be most mindful of and why?

CC) We’re moving beyond crass “what can you afford” tests and days spent poring over bank statements to a place where financial data can be shared in a click and analysed in real time to produce fair, non-obtrusive and transparent checks of financial vulnerability.

The only technology to access that data is through online and mobile banking. Most people are already using Open Banking based services without even realising it, and it won’t take long for consumers to build confidence that this is a safe way to make their data visible. It’s regulated, fast and it doesn’t touch your credit score.

GE) Do you think certain types of customers are more likely to feel uncomfortable with the collection and processing of their personal data during affordability checks, and is this discomfort more related to their personal circumstances or the type of product being offered?

CC) It depends on the tradeoff for the consumer between losing privacy and gaining service.

We all make these trade-offs all the time, like giving gambling sites our personal ID in order to set up an account. Not so long ago even that was considered an affront to privacy, now people just accept it as something they have to do and it turns out most of them want to play more than they want anonymity.

I feel that, if the government gets the regulation right, people will come to expect that, if they wager regularly, operators are going to need to run some kind of risk check on them, just as they do for ID. So long as those checks are easy and trustworthy – and fair – then it won’t take long for people to adapt.


Gaming Eminence also contacted the UK Gambling Commission (UKGC) to gain insights on various aspects regarding stricter affordability checks. These include the potential impact of such measures on customers who may turn to unregulated markets, the need for operators to embrace emerging technologies, and the potential discomfort that certain customers may experience due to the collection of personal data during affordability checks.

They provided the response below.

UKGC) "Operators having proportionate and effective approaches to managing financial risk is part and parcel of preventing gambling related harm and operating a sustainable business.

Operators are currently required to have systems in place which identify people who may be at risk of harm and to take appropriate action. One part of an operator's approach to managing risk is having proportionate thresholds at which more information is required to satisfy themselves there is no issue with that customer relationship.

The GB gambling market offers more ways to gamble than anywhere else in Europe, perhaps the world, which makes it attractive to consumers.

It’s not as simple as a consumer who does not want to answer questions from a bookmaker immediately thinking ‘I’m going to go and gamble with an unlicensed operator’.

We have not so far seen any heavy-weight research that would stand up to scrutiny - indicating that this is happening on a large scale.

But we are not complacent, and we will continue to disrupt the unlicensed market - but we would be able to devote even more efforts to that if so much of our resources were not tied up in combatting non-compliance in the licensed market.

However, we would like to be clear that just because the black market exists, we will not scale back or stop some of the interventions we think we need to make in the regulated market to protect consumers."



It's clear the affordability checks are not going away, so where and how can operators look towards innovative technologies to ensure smoother affordability checks for their customers. We researched various current and emerging technologies and assessed how they could aid in streamlining affordability checks while addressing customer and regulatory challenges.


Machine learning and AI is already in place across various industries, such as banking, insurance, and e-commerce therefore the core structure of it as a technological tool is available in the market place from a B2C perspective.

If exploring this tech as a first instance, the time required for machine learning and AI to solve affordability checks depends on various factors such as the complexity of the checks, the size and quality of the data set, and the computational resources available. In general, the process of training a machine learning model to perform affordability checks involves several steps, including data preparation, feature engineering, model selection, and training. This process can take anywhere from a few hours to several weeks, depending on the complexity of the problem and the amount of data available.

Though don't let set up time be a deterrent of using this technology, as once the model is trained, it can perform affordability checks much faster than a human could, typically in a matter of milliseconds or seconds. However, it's important to note that the accuracy of the model and the speed of the inference process depend on the quality of the data and the model architecture chosen. Therefore, it's crucial to carefully design and validate the machine learning model before deploying it in a production environment.


Biometric authentication technology can be a game-changer for gambling operators by improving affordability checks for potential customers. For example, online gambling platforms can use facial recognition technology to quickly verify the identity of a customer during the registration process based on data in the system. This can speed up the onboarding process and improve the customer experience by reducing the time it takes to complete verification checks.

Additionally, biometric authentication technology can improve the accuracy of affordability checks by using machine learning algorithms as mentioned earlier to analyse biometric data. A potential use case could be voice recognition, as that can be used to analyse a customer's tone and inflection to detect if they are being coerced into gambling. This can help operators to identify and prevent fraudulent activity more effectively.

Moreover, multi-factor authentication can be used to enhance the security of affordability checks. A customer can use their fingerprint or facial recognition to verify their identity in combination with a password or one-time password (OTP). This provides an additional layer of security and reduces the risk of unauthorised access, which this in turn is all connected with their data affordability profile.


Open banking can revolutionise how gambling operators conduct affordability checks by leveraging access to customers' financial data such as income, expenses, and credit history, which can be used to assess their creditworthiness more accurately.

The process works by using open banking APIs to collect real-time transaction data from a customer's bank account, which can be used to assess their affordability for gambling activities not only for current clients as a way to ensure safer gambling, but also for new customers during the onboarding process. This in turn can reduce the need for manual checks and improve the speed of the onboarding process.

By connecting this transaction data, gambling operators can identify patterns in a customer's spending habits, such as regular large transactions, which may indicate affordability issues. This data can then be leverage with the technologies above to assist the operator in making informed decisions about whether to approve or restrict a customer's access to gambling activities at a quicker rate, making the process seamless for the customer.

There are several issues that have been identified with open banking APIs for third-party providers such as gambling operators. Some of these issues include:

  • Access: Third-party providers may have difficulty obtaining access to open banking APIs, as some banks may restrict access to their APIs or charge high fees for access.

  • Data Quality: The quality of the data provided by open banking APIs can be inconsistent and incomplete, making it difficult for third-party providers to rely on this data.

  • Security: Open banking APIs can pose a security risk, as they provide access to sensitive financial data. Banks must ensure that their APIs are secure and that third-party providers are properly vetted and authorized to access the data.

  • Standardisation: Lack of standardisation across different banks' open banking APIs can make it challenging for third-party providers to integrate with multiple banks and create a seamless user experience for customers.

  • Regulation: Regulatory compliance is a significant challenge for both banks and third-party providers, as open banking APIs must adhere to strict data protection and privacy regulations.

Addressing these issues requires collaboration between banks and gambling operators, as well as adherence to regulatory standards and the development of industry-wide best practices.


One potential application of blockchain technology in affordability checks is in the creation of a shared database of customer information. Such a database could be used by different operators to share information about customer affordability, while ensuring that personal data is protected and kept private.

By using blockchain technology, customers could maintain control over their own personal data, while gambling operators could still access relevant information to conduct affordability checks. This could help to reduce duplication and streamline the affordability checking process, making it more efficient for both operators and customers.

Additionally, blockchain technology can enable the use of smart contracts to automate affordability checks. Smart contracts are self-executing contracts with the terms of the agreement between buyer and seller being directly written into lines of code. This means that once certain conditions are met, such as verification of a customer's affordability status, the smart contract can automatically execute the next step of the process, such as granting access to gambling services.

The use of blockchain technology could also potentially improve the accuracy and integrity of affordability checks. By leveraging a secure and decentralised ledger, gambling operators can ensure that the information used in affordability checks is accurate and tamper-proof, reducing the risk of fraud and errors.


We will follow up on this topic with a breakdown into the providers in the market that work with affordability check technology and speak to them directly on their thoughts and perspectives on this evolving landscape.

If you would like to work with us discussions around areas of affordability checks please email at

1 Comment

Unknown member
Mar 14, 2023

Great article

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