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Gambling Commission asks industry to cut regulatory burdens, but consistency may be the bigger issue

The Gambling Commission has launched a formal invitation for the gambling industry to submit proposals on how to reduce the burdens associated with gambling regulation.

The call, which opened on 26 June 2026, is not a consultation. Instead, the Commission is asking operators and other stakeholders to identify areas where regulatory requirements, guidance, technical standards, reporting processes or wider regulatory interactions could be streamlined or improved.

According to the Commission, the aim is to reduce unnecessary administrative burden while maintaining strong consumer protections and upholding the licensing objectives of the Gambling Act 2005: keeping crime out of gambling, ensuring gambling is conducted fairly and openly, and protecting children and vulnerable people from harm.

It is a welcome invitation. But it may not address the real issue many operators experience day to day.

The rules are not always the burden

For many operators, the problem is not necessarily the existence of the LCCP, the Commission’s AML guidance, or the broad principle that gambling businesses must take a risk-based approach to safer gambling and financial crime.

In fact, many of the core obligations are hard to argue with. Gambling operators should understand their money laundering and terrorist financing risks. They should have controls that reflect those risks. They should identify customers who may be experiencing harm. They should intervene where the evidence justifies intervention. They should be able to explain and evidence their decisions.

The difficulty comes when written guidance is applied inconsistently in practice. Industry concerns are not only about the wording of formal requirements. They are about how those requirements are interpreted during compliance assessments, how much weight is given to individual assessors’ views, and whether operators feel able to challenge those views without fearing escalation.

That is where the burden can become more than administrative. It becomes operational uncertainty.

When interpretation becomes policy

A risk-based regime depends on judgement. That is unavoidable. But judgement must be consistent, transparent and anchored to the actual rules. If one compliance assessment treats a control as proportionate, while another treats the same control as inadequate, operators are left guessing. If an assessor informally suggests that a particular step is expected, even where the published guidance does not require it, many operators will comply simply to avoid further scrutiny.

This can lead to defensive compliance. Operators may collect more information than they need. They may add friction to low-risk customer journeys. They may block or restrict customers where a more proportionate interaction would have been enough. They may build processes around what they believe an assessor wants to see, rather than around the actual risk presented by the customer. That is not good for operators, and it is not necessarily good for consumers either.

The Commission’s own customer interaction guidance refers to using all available information, balancing financial, behavioural and time-based indicators, and applying proportionate customer interaction as a result. That is a risk-based approach. It does not mean treating every customer as though they present the same level of risk.

The affordability debate shows the problem

The debate around financial risk assessments is a useful example. The Commission has been clear that financial risk assessments are not “affordability checks” and would not assess how much an individual can afford to gamble. It has also said that the proposed checks are not live, that they would be targeted at high-spending customers, and that the vast majority would be frictionless.

In its April 2026 update, the Commission said there would be no need to require document checks following a financial risk assessment, and that operators should avoid defaulting to requests for bank statements or account closures in every case.

That clarity is useful. But it does not fully answer the industry’s concern. If operators are asking customers for bank statements, occupation details or other personal information earlier and more often than the Commission says is required, the question is why. Is it because operators are misunderstanding the rules? Is it because they are overreacting to enforcement outcomes? Or is it because the expectations communicated during compliance assessments feel different from the expectations published in formal guidance?

That distinction matters. If the Commission believes there is misinformation around financial risk assessments, it should also consider why that perception has taken hold. Operators do not usually create poor customer journeys for fun. They do it because they believe the regulatory risk of doing less is greater than the commercial risk of adding friction.

Enforcement still matters

None of this means regulation should be weakened. The gambling sector remains exposed to serious financial crime and customer protection risks. Recent enforcement action shows why robust compliance is still essential.

In the Corbett Bookmakers case, the operator was fined after the Commission found AML and social responsibility failings, including insufficient KYC evidence and failure to adequately interact with customers staking or losing significant sums.

Similarly, Spreadex was fined for regulatory breaches after failures relating to AML controls, source of funds, customer protection and repeated weaknesses following earlier enforcement action.

These cases underline an important point: proportionate regulation does not mean relaxed regulation. High-risk activity should trigger stronger scrutiny. Operators should not be able to ignore red flags, rely on vague customer assurances, or allow significant losses without meaningful intervention.

But proportionate regulation also means avoiding unnecessary intervention where the risk evidence does not support it.

The challenge is not choosing between strong compliance and good customer experience. The challenge is applying the right level of scrutiny to the right customer at the right time, and being able to evidence why that decision was made.

What burden reduction should really focus on

The Commission’s call for proposals asks the industry to identify requirements that no longer serve their purpose, could be streamlined, or could be communicated more effectively. That is useful. There may well be reporting processes, forms, duplicated requirements or outdated guidance that can be improved. But if the biggest burden is inconsistency, then reducing paperwork will only go so far.

A more meaningful burden-reduction exercise should also look at how compliance assessments are conducted. It should ask whether operators are receiving consistent messages from different assessment teams. It should consider whether informal expectations are being treated as binding requirements. It should give operators a clearer route to challenge or clarify an assessment view without feeling that doing so will increase enforcement risk.

The Commission could also consider publishing more practical examples of what proportionate compliance looks like in lower-risk, medium-risk and higher-risk scenarios. Just as importantly, it could publish examples of what it does not expect operators to do. That would help operators avoid unnecessary friction while maintaining robust controls.

The real test

The Commission’s invitation is a positive step. It shows a willingness to listen and to consider where regulation can be improved without weakening consumer protection. But the success of this exercise will depend on whether it addresses the industry’s lived experience of regulation.

For many operators, the burden is not simply the rulebook. It is the uncertainty of how the rulebook will be interpreted during an assessment, the fear of escalation, and the pressure to satisfy expectations that may not be clearly stated in the published guidance.

Reducing regulatory burden is not just about removing requirements. It is about making sure requirements are applied consistently, proportionately and transparently. If the Gambling Commission wants to reduce unnecessary burdens while maintaining high standards, consistency in compliance assessments would be a good place to start.

For gambling operators, the challenge is not just meeting regulatory expectations, but being able to evidence a consistent, risk-based approach. VinciWorks’ AML training helps staff understand customer due diligence, red flags, source of funds, suspicious activity and the practical steps needed to reduce financial crime risk.

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