Financial vulnerability checks and financial risk assessments: what the £150 check actually is
"Affordability checks" is a nickname for two separate Gambling Commission measures, and neither asks you for payslips. The first is a light-touch financial vulnerability check run against public records when net deposits reach £150 in 30 days. The second is a financial risk assessment using credit reference data at much higher spend, being introduced in stages from 2026.
Last reviewed: 21 September 2026 · Author: Eleanor Whitlock
1. Financial vulnerability checks (the £150 check)
Trigger. £150 of net deposits (deposits minus withdrawals) in a rolling 30-day period. The threshold was £500 when the checks began on 30 August 2024 and was lowered to £150 on 28 February 2025.
What is checked. Publicly available records only. The Commission lists six flags: bankruptcy orders, County Court Judgments, Individual Voluntary Arrangements, High Court Judgments, administration orders, and Debt Relief Orders. Credit reference agency data is explicitly not part of this check.
What you provide. Nothing. The Commission's description is "a targeted and non-intrusive way of using publicly available information". No postcode confirmation, no employment details, no documents.
What happens on a flag. The Commission expects "proportionate action", not automatic closure: a flag is a prompt for the operator to look at the account, interact with the customer and decide. Checks "would not prevent the continued gambling or making of deposits unless there were risk flags".
How it has gone. The Commission's implementation blog (14 May 2026) reports that 68% of operators had already run such checks voluntarily; about 7% of active accounts were checked in the first three months; 78% of checks returned within ten minutes.
2. Financial risk assessments (the high-spend check)
What it is. A frictionless assessment using credit reference agency data — not documents — for customers whose net deposits reach much higher levels. The aim, in the Commission's words, is to support "high-spending customers in financial difficulties, while reducing friction for customers who are not in financial difficulties by removing the need for unnecessary and unpopular document checks".
Rollout. After a pilot, the Commission announced in July 2026 a staged introduction rather than a single start date:
| Stage | Adults 25 and over | Under-25s and higher-risk groups |
|---|---|---|
| Stage 1 (largest operators) | £5,000 net deposits in a rolling 24 hours | £2,500 in 24 hours |
| Final stage | £1,000 in 24 hours or £3,000 in 90 days | £750 in 24 hours or £2,000 in 90 days |
Interim stages, and the timetable for stage 1, were to be set after engagement with the industry over summer 2026; the Commission's own updates page is the place to check the current stage.
Enforcement. The Commission said it would not take enforcement action over FRA failures during the early stages, while all other licence requirements — including existing customer-interaction duties — continue to apply.
What neither check is
- Not a request for bank statements. Source-of-funds requests exist, but they are a separate anti-money-laundering and harm measure triggered by risk, not by these thresholds.
- Not a loan application. The FVC uses public records only; the FRA uses credit reference agency data but is described by the Commission as frictionless — the customer is not asked to apply for anything or send anything in.
- Not a spending cap. Neither check sets a limit. They inform the operator's decision about interacting with the customer.
Why the confusion
Between 2020 and 2023, before these measures existed, some operators asked customers for documents at low spend levels to satisfy the Commission's customer-interaction expectations. Those ad-hoc requests are what most people mean by "affordability checks", and the Commission's stated purpose for the new framework was to replace them with something standardised and largely invisible to the customer.
Quick answers
Will I be asked for documents at £150? No. Nothing is requested from you at this threshold.
Can an operator still ask for documents? Yes, under anti-money-laundering rules or where behaviour suggests harm — but that is a separate process from these checks.
Does the £150 count deposits across all operators? No. Each operator sees only its own deposits. The Commission's white-label guidance separately expects licensees to hold a single view of a customer across the brands on their licence.
Sources: Gambling Commission, Financial vulnerability checks: insights from implementation (14 May 2026); Gambling Commission, Our position: light-touch financial vulnerability checks; Gambling Commission, Commission to introduce Financial Risk Assessments in staged approach (7 July 2026) and Financial risk assessments update – July 2026.