Affordability is a reality that the industry has to confront, an unavoidable fate that is only going to become more uncomfortable the less it is embraced.
A consistently missed factor is nuance; the gambling sector is unlike any other in how it is viewed by customers, meaning it requires a high level of delicacy in interactions.
The timing for the shift is pivotal, with the enticement of the black market building its threat to the breaking point.
Speaking to iGaming Expert following the launch of GamScore, a newly launched app aimed at improving the gambling and financial well-being of users, Josh Apiafi, one of the platform’s founders, warned that the black market “obviously has threats to all of us”.
He emphasised that everyone involved in the regulated industry has a vested interest in collaborating to tackle the black market and stop its surge.
At the heart of this, according to Apiafi, is highlighting the dangers of the black market and ensuring that players are educated about the potential vulnerability they expose themselves to if they drift to unlicensed operators.
“We can’t stop people venturing to the black market, but we can certainly identify that kind of activity,” he noted.
“And there are people out there that don’t realise the accounts they’ve got are actually with offshore operators.”
Apiafi lamented the presence of black market operators on TikTok and other social media platforms, raising significant concerns that they are almost indistinguishable from the regulated sector in many ways.
He revealed that GamScore is aiming to take a wider approach to affordability by identifying black market activity and bringing it into a wider score for player checks.
Stopping the stigma around affordability
As an industry, we have long lobbied for the stigma to be ended around the use of the safer gambling toolbox, but when it comes to affordability, there is a stubbornness around changing the perception of financial risk checks. A lack of any ability to compromise on affordability is only serving to ensure that the industry misses an opportunity to warn of the black market it so vigorously bemoans.
Adding black market activity to the overall gambling wellness score by GamScore is undeniably a challenge for the app, given the discreet and immoral tactics employed by unlicensed operators.
However, if it can be achieved, it may well shift the tone when it comes to debate around affordability and the industry.
GamScore’s Mark Potter underpinned that since its formation, they have had positive feedback from the industry, specifically from racing.
He added that there is a desire to steer the conversation away from “surveillance and toward consumer tools and responsible gambling, they are empowering the player”.
Apiafi emphasised that by bringing data into one place through Open Banking, there is a real possibility to better inform players and bring as many as possible into the green zone to ensure that they are gambling within their means.
Perhaps it’s muscle memory when it comes to anything related to affordability, but the unveiling of GamScore was met with a frosty reception from some quarters of the industry.
One of the criticisms was around the reliance of the app on AI; however, pushback is largely fuelled by an infiltration of gambling freedoms that is unlikely to ever return.
Others have noted that punters simply will not sign up to a betting wellness app like GamScore, though Apiafi believes the next generation of bettors is more in tune with technology and personal data, which could spark a change.
He explained: “People of a certain generation – my generation – see Open Banking and just do not like it.
“The younger generation don’t mind a solution which involves Open Banking, not that the bookmakers are going to be checking their accounts, but they’re so used to Open Banking and they’re uber comfortable with their data.
“It is not giving it to an operator, unless you decide you want to give that score to an operator, it’s all about being able to keep an eye on your own betting activity.”
Further addressing the backlash which came on the back of GamScore’s announcement, Apiafi told iGaming Expert: “There was some misinterpretation alongside some emotionally charged people who still think that they can cling on to the fact that it might get scrapped. The misinterpretation comes from the fact that we haven’t been able to provide the full and proper explanation.”
Potter and Apiafi were united in their dismay of the current system, with 60% of people being so turned off by being asked for documents that they simply move on and find another account, eventually on a path that inevitably leads to the black market.
Both were aligned in their pleading with the industry to take a proactive approach to the inevitable fate of affordability checks.
Emphasising that the mission of ‘GamScore is to find a solution within the confines of what it’s going to look like for us in a regulated market moving forward’.
Apiafi explained: “If we had a one-off credit check today, any of us, that may be fine, but something could happen tomorrow. Over the next month our income could change, and of course, that would be relevant to any check moving forward.”
He emphasised that it is vitally important for the consumer to be given a level of control over the process of affordability, with this also enabling the opportunity for education and potentially safer gambling habits.
Fierce friction
Launching GamScore, Potter and Apiafi clearly have an optimism that they can break down the barriers being put up by the industry when it comes to affordability, but the friction is still fierce from some quarters. The Betting and Gaming Council (BGC) is threatening to launch legal action against the Gambling Commission if it presses ahead with Financial Risk Assessment Checks.
BGC CEO, Grainne Hurst stated: “FRAs were meant to be ‘frictionless’ and workable in practice. The pilot was supposed to test that. Instead, it exposed serious concerns about whether the system is reliable, proportionate or fair, and whether it will genuinely improve protections for consumers.
“The biggest issue is what happens after a customer is flagged. The Gambling Commission has focused heavily on the idea that most checks will be technically ‘frictionless’, but punters care about outcomes, not process. If an assessment leads to intrusive follow-up questions, requests for personal financial documents and account restrictions, then the customer experience will be severely disrupted.”
This is somewhat at odds with the assurances of the Gambling Commission, which has continued to move to assure that Financial Risk Assessments (FRAs) are not affordability checks, and as such will not cap a player’s spend, nor will players be asked for financial documents.
Looking to douse the flames of negative feedback around affordability, the Commission has emphasised that less than 3% of active customers would trigger any steps by an operator. Furthermore, of those that would trigger a check, 97% would successfully receive a frictionless assessment process.
The train for affordability checks is full steam ahead whether the industry likes it or not. If stakeholders don’t get on board and navigate the journey, but rather stubbornly and naively remain at the station, the destination may not be one that is entirely desirable for an already embattled UK iGaming sector.










