Executive Director Tim Miller defended the Commission's approach to Financial Risk Assessments, revealing new pilot data that contradicts critics' concerns.
Apr 29, 2026 · 9 min read

Gambling Commission Executive Director Tim Miller used his keynote address at the inaugural Ethical Gambling Forum in Great Britain to mount a robust defence of the regulator's Financial Risk Assessment proposals, countering what he described as "ill informed" and "inaccurate" commentary surrounding the controversial measures.
Speaking on 28 April 2026, Miller revealed new data from the Commission's pilot programme that he argued definitively supports the need for standardised financial risk checks whilst addressing industry concerns about their implementation.
The Commission's pilot findings directly contradict earlier government estimates about the scope and impact of Financial Risk Assessments. Where the 2023 White Paper initially projected that 80 percent of assessments would be frictionless, the pilot demonstrated that 97 percent of the 3 percent of active accounts triggering assessments would receive seamless processing.
More significantly, the pilot revealed that only 0.1 percent of all active customer accounts would be unable to complete assessments without friction – a dramatic reduction from the White Paper's 0.6 percent estimate.
"Only one in a 1000 accounts would be unable to receive an assessment in a frictionless way."
— Tim Miller, Executive Director, Gambling Commission
The pilot also uncovered concerning vulnerability patterns among high-spending customers. Consumers in the pilot cohort were between two and four times more likely to have a debt management plan and between two and five times more likely to have experienced a default in the previous 12 months compared to the general population.
97%
Frictionless assessments achieved (vs 80% projected)
0.1%
Accounts unable to complete without friction (vs 0.6% estimated)
3%
Active accounts triggering assessments
2-4x
Higher likelihood of debt management plans
2-5x
Higher likelihood of defaults in 12 months
Miller directly confronted several misconceptions that have dominated recent industry discourse around Financial Risk Assessments. He emphasised that the proposed thresholds represent assessment triggers, not spending limits or caps.
"The proposed thresholds for an assessment are not limits or caps on customer spend. They are not 'affordability checks' by a different name."
— Tim Miller, Executive Director, Gambling Commission
The Executive Director also addressed concerns about document requests, clarifying that successful Financial Risk Assessments would eliminate the need for operators to request financial documentation from consumers.
"If these checks are implemented it will allow us to give clear guidance to operators that they should not require consumers to provide documents to assess financial risk following a financial risk assessment."
— Tim Miller, Executive Director, Gambling Commission
Miller described the current system as fundamentally flawed, noting that expecting operators to assess consumer gambling harm risk has existed since the Gambling Act was passed in 2005, yet still results in inconsistent approaches.
"In 2026 it can't be right that this still leads to some operators asking consumers to share bank statements and other financial documentation. Such an approach is outdated, inconsistent and disproportionate."
— Tim Miller, Executive Director, Gambling Commission
Critical Policy Clarification
The distinction between assessment triggers and spending limits has become a major point of regulatory confusion. Industry stakeholders should note that Financial Risk Assessments create evaluation points, not transaction restrictions, fundamentally different from the affordability caps previously proposed by parliamentarians.
Financial Risk Assessments represent the primary remaining commitment from the Government's gambling review white paper requiring Commission decisions. Miller confirmed that recommendations would be presented to the Commission's Board "in the near future" but cautioned against assumptions about predetermined outcomes.
The Commission has been collaborating with the Steering Committee on Reciprocity (SCOR Committee) to develop streamlined approaches using credit reference data specifically targeted at highest-spending consumers. This partnership aims to replace the current "patchwork of different approaches" operators use to identify customers experiencing financial difficulties.
SCOR Committee Partnership
The Steering Committee on Reciprocity represents a cross-industry initiative specifically designed to standardise credit reference data usage across gambling operators. This technical working group has been developing APIs and data-sharing protocols that could eliminate the current fragmented approach to customer financial verification.
Beyond Financial Risk Assessments, Miller provided updates on the Commission's Gaming Machines consultation response. Key changes take effect from 29 July 2026, requiring operators to immediately remove machines when the Commission identifies non-compliance with technical operating licence requirements or other standards.
Initial consultation information was published at the end of January, with a full response expected during Summer 2026. Miller acknowledged the "potential financial costs of implementing some of the original proposals" would significantly influence final decisions, particularly given the current operating environment.
The Commission received £26 million over three years through the Government's Budget to intensify illegal gambling enforcement activities. Miller, who chairs a subgroup within the Government's illegal gambling taskforce, outlined the Commission's recent enforcement achievements:
Miller announced plans to publish a national risk assessment on the illegal market to ensure focused attention on primary risks. He also criticised technology companies for reactive approaches to harm prevention, stating the Commission would "become increasingly vocal" in highlighting companies that fail to protect British consumers from illegal operators.
£26 million
Government enforcement funding (3 years)
741
Cease and Desist orders issued
397,527
URLs reported to search engines
266,667
URLs successfully removed
1,068
Websites referred for delisting
1,134
Websites disrupted via takedowns/geo-blocking
Despite recent regulatory focus on consumer protection, Miller emphasised the Commission's commitment to supporting industry innovation. He confirmed ongoing discussions with the Industry Forum about creating pathways for cryptoassets to serve as consumer payment options for licensed gambling in Great Britain.
The Executive Director outlined plans for a strategic review examining the "impact, efficiency and burden of current regulatory requirements" – aligned with Government regulatory reform objectives. However, he noted that specific commitments depend on outcomes from DCMS's fees consultation.
Miller extended an open invitation to operators with consumer-friendly innovation proposals, emphasising that the current statutory framework doesn't automatically preclude new approaches that enhance consumer experience.
The future of Britain's gambling market depends on collaborative efforts to deliver innovative consumer experiences within well-regulated environments prioritising fairness and safety.
Operator Innovation Strategy
Operators seeking regulatory approval for new technologies should engage early with the Commission's innovation team. The cryptoassets payment discussions demonstrate that proactive collaboration can accelerate approval timelines, particularly when proposals include robust consumer protection frameworks and technical compliance documentation.
The forum attracted attendees from multiple jurisdictions, which Miller welcomed as an opportunity to gain external perspectives on British regulatory approaches. He noted that Britain maintains "one of the largest, licensed gambling markets in the world" but acknowledged the value of learning from international experiences.
Miller recognised the changing landscape following Government taxation changes announced in the previous year's Budget, including risks of consumer migration to illegal markets. This concern directly influenced the additional funding allocation for illegal gambling enforcement.
Global Regulatory Trends
International jurisdictions are closely monitoring Britain's Financial Risk Assessment implementation as a potential model for responsible gambling regulation. Several European regulatory bodies have indicated interest in adopting similar credit-data approaches, making the UK pilot results influential beyond domestic policy.
The Commission published its annual Business Plan the week preceding Miller's address, outlining priorities including continued Gambling Act review implementation, enhanced illegal gambling enforcement, improved data maturity, and proactive operator compliance engagement.
Final resource allocation awaits DCMS fees consultation results, which will determine the Commission's capacity for specific initiatives including innovation support programmes.
Warning
The Commission's ability to deliver on innovation support and regulatory burden reviews remains contingent on DCMS fees consultation outcomes. Operators should prepare for potential delays in guidance updates and approval processes if funding allocations fall short of operational requirements.
Miller's address signals a potential shift in the Commission's approach following intensive consumer protection implementations. The emphasis on innovation support and regulatory burden review suggests recognition of industry operational pressures, particularly given current market taxation changes.
The Executive Director's criticism of technology companies' reactive harm prevention approaches indicates the Commission may pursue more assertive strategies in compelling platform compliance with consumer protection obligations. The timeline pressures around Financial Risk Assessment implementation remain significant, with Board decisions imminent and industry implementation planning dependent on regulatory approval. Miller's data presentation appears designed to counter industry resistance whilst maintaining Government policy support for the measures.
According to UK Gambling Commission.
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This content reflects a general overview of regulatory frameworks based on publicly available information. It does not constitute legal advice or a legal opinion. iGamingWriter.blog disclaims any liability arising from reliance on this material.

Written by
Olga MuntyanDirector of Project Management
Olga has been leading project management at We–Right™ Factory since 2020, coordinating multilingual content delivery for iGaming operators and affiliates. She manages timelines, team capacity, and cross-market workflows that keep large-scale content production on track. On iGamingWriter.blog, Olga writes about project coordination, content pipeline management, and operational efficiency in iGaming content teams.
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