Opening
The concept of affordability checks has ignited controversy across jurisdictions. From the UK’s Gambling Commission proposals to discussions in Australia and beyond, operators and regulators are grappling with how to balance risk-based protections with individual privacy, commercial impact, and regulatory efficiency. Yet amid the operational, political, and technological debates, one group remains largely absent from the design table: players themselves.
What would affordability look like if it were co-created with the people it is meant to protect?
Core Analysis
Regulatory approaches to affordability currently prioritise financial thresholds, data indicators, and system-led interventions. While this is consistent with statutory duties and the mitigation of economic harm, it often fails to reflect the nuanced reality of players’ experiences. Generic flags, such as spend above income proxies, can miss vulnerable players below thresholds and alienate financially secure customers above them. This leads to a fundamental design tension between protection and autonomy.
Now consider a shift. What if affordability measures were structured with players, not simply for them?
Research from the Behavioural Insights Team, the UK Gambling Commission’s Lived Experience Advisory Panel, and initiatives like Australia’s BetStop reveal a recurring theme. Players respond more positively to personalised, choice-based interventions than to opaque restrictions. Engagement rises when tools are transparent, respectful, and relevant to how people think about their money and risk.
This is not about handing control entirely to individuals. Rather, it is a call for strategic redesign, where the intelligence of frontline lived experience informs the design of affordability frameworks, consent flows, and thresholds.
Solutions
To integrate player-centric thinking into affordability policy without compromising regulatory integrity, operators and regulators can consider three strategic shifts.
1. Co-design policies with player panels and lived experience groups.
True consultation means more than stakeholder surveys. Regulators could embed structured co-creation forums into their rulemaking processes, as seen in the innovation of health and social policies. Operators can create ongoing player advisory councils, particularly drawing on individuals with experience of gambling-related harm, to test and refine risk models and friction points.
2. Move from static thresholds to dynamic, self-reflective tools.
Affordability could be reframed as a dynamic dialogue rather than a static line. Self-assessment prompts, income-confidence scoring, and spending tolerance indicators can give players more agency while feeding risk insights into operator systems. This does not eliminate the need for hard checks, but complements them with a richer behavioural context.
3. Make interventions transparent, not just compliant.
One reason players reject affordability checks is a lack of clarity. Who sees the data? What triggers a review? Why was an account restricted? Clear, consistent communication and simple appeals mechanisms are essential. If players helped write the scripts, they would likely sound less like surveillance and more like service.
Final Question
If the industry wants affordability to be effective, proportionate, and accepted, can it afford to keep designing it without those most affected? Senior leaders must ask: Are we creating systems that protect players or systems that alienate them, and how would our policies change if we started by asking them?
Summary:
This article challenges operators and regulators to consider how affordability checks can be improved by integrating player insights and lived experiences into their design, thereby balancing protection, autonomy, and trust.
Footnotes:
- UK Gambling Commission. “Customer interaction: Guidance for remote gambling operators.” 2023.
- Behavioural Insights Team. “Reducing gambling harms: A behavioural audit.” 2021.
- Australian Communications and Media Authority. “BetStop – the National Self-Exclusion Register.”
- GambleAware. “Lived Experience Council.” 2023.