The British Horseracing Authority and industry groups warn that the Government’s proposed affordability checks—tested in pilots since 2024—are neither reliably frictionless nor consistent, and that pressing ahead with the current approach risks driving racing punters to unregulated operators and reducing levy revenues that fund the sport.
Where the immediate risk to horseracing sits
The most direct commercial threat is straightforward: under the proposed triggers—£1,000 net loss in 24 hours or £2,000 over 90 days—BHA modelling suggests roughly 120,000 racing customers would be subject to document checks, and about 45,000 of those might stop using regulated operators and move to illegal sites. That migration would remove an estimated £13.2 million in levy contributions that support British racing’s prize money, training and infrastructure.
Those figures matter because the sector already faces constrained funding: the Government closed its recent Horserace Betting Levy review without increasing the rate, and the BHA stresses that any avoidable drop in turnover amplifies long‑term competitiveness problems versus jurisdictions such as France and Ireland. BHA chief executive Brant Dunshea has urged ministers—including Culture Secretary Lisa Nandy in recent briefings—not to proceed with rules that add avoidable customer friction.
What the 2024 pilots actually revealed about verification
Pilots run since 2024 used three different credit reference agencies and returned inconsistent results for the same bettors; in practice that meant some customers were flagged by one CRA and cleared by another. In several pilot instances operators had to ask customers for bank statements or payslips to resolve discrepancies—documents a YouGov poll for the Betting and Gaming Council reported two‑thirds of bettors (65%) would refuse to hand over.
Those user attitudes match earlier Gambling Commission polling showing 77% opposition to financial checks in some form. Former DCMS minister Stuart Andrew and the 2023 Gambling White Paper both set the bar: checks should be “frictionless and proportionate.” The pilot evidence so far, plus the Treasury’s £26 million allocation in the 2025 Budget to tackle illegal gambling, signals a policy tension between protecting vulnerable gamblers and not enlarging the black market.
Thresholds, actions and the likely operational fallout
Below is a compact comparison of the proposed trigger thresholds, the immediate verification action, and the industry estimates of who would be affected and what could be lost to illegal markets.
| Trigger | Immediate verification step | Estimated racing customers affected | Estimated migration to illegal operators | Estimated levy loss |
|---|---|---|---|---|
| £1,000 net loss in 24 hours | CRA checks → possible bank/pay slip request | ~120,000 (combined triggers) | ~45,000 | £13.2m (racing portion) |
| £2,000 net loss in 90 days | Same escalation; aggregated checks over time | (included above) | (included above) | (included above) |
Operationally, inconsistent CRA outputs create two concrete burdens: more manual review and higher compliance costs for regulated operators, and a worse user experience where even responsible bettors face intrusive document requests. That combination tends to push price‑sensitive or privacy‑sensitive customers toward unregulated operators, who do not report levy contributions or meet the same consumer safeguards.
Decision checkpoints for regulators, operators and bettors
The near‑term checkpoint is the Gambling Commission’s forthcoming decision on whether to mandate affordability checks and how to define “frictionless.” Regulators should insist on demonstrable, repeatable CRA alignment and a clear standard that avoids routine document demands; if pilots keep producing inconsistent outputs, the practical test for moving from pilot to mandate has not been met.
Operators should lobby for risk‑based thresholds, automated soft checks as the first step, and clear customer journeys that limit document escalations. Bettors should verify operator licensing and be prepared to question requests for bank statements or payslips; the industry’s YouGov and Gambling Commission polling suggests most consumers will push back against intrusive verification.
Quick Q&A
When will the next decision come? The Gambling Commission is expected to decide on mandated checks after reviewing pilot outcomes; no exact public date has been set but the decision is the next formal checkpoint referenced by the BHA.
Who is most exposed? Regular racing bettors around the proposed thresholds—the BHA estimates ~120,000—plus operators that rely on levy income; losses here disproportionately affect prize funds and jobs in racing.
What should signal a pause? Continued inconsistent results across CRAs, rising rates of customers abandoning regulated sites, or early indicators of migration to illegal operators (measurable through market share studies) should all trigger a reassessment rather than immediate rollout.
