Financial vulnerability checks

What the check is allowed to look at

Social responsibility code provision 3.4.4, introduced into the Gambling Commission’s licence conditions and codes of practice (LCCP), mandates that the check must at minimum include a customer-specific public record information check for significant indicators of potential financial vulnerability. It searches publicly available registers—not credit reference databases—for specific court and insolvency records. The code specifies these indicators: whether the customer is subject to a bankruptcy order or equivalent, a county court judgment (CCJ), an individual voluntary arrangement (IVA), a high court judgment (HCJ), an administration order (AO) or decree, a Debt Relief Order (DRO), or equivalent.

These records are drawn from central registries such as the Individual Insolvency Register and the Register of Judgments, Orders and Fines. A hit means the individual has already been through a formal legal process because of unmanageable debt. The operator must then weigh any result alongside what else it knows about the customer and act proportionately where risk is found. It must record the reasons for that decision.

The threshold, and the fact that it is net

The trigger is net deposits, calculated as deposits minus withdrawals over a rolling 30-day period. The figure counts only fresh money that stays in the account, not total spend or turnover. A player who tops up £200, withdraws £50, then deposits another £100 within the same 30 days has net deposits of £250—a figure that would now trigger a check.

Until 27 February 2025, the threshold was set at deposits minus withdrawals exceeding £500 in that rolling window. On 28 February 2025 it tightened sharply. The code now states: “the relevant threshold is where the customer’s deposits minus withdrawals exceeds £150 in a rolling 30-day period.”

The rule applies to all remote gambling licences except those for lotteries that do not offer instant wins or high-frequency draws. It also excludes holders of technical, software, host, ancillary, trading room and limited general betting licences. For the online slot, casino, or sportsbook customer, threshold monitoring is live at the lower level.

Why the £500 figure is still quoted

Players citing the earlier £500 mark are referencing a rule that was in force for almost six months, and any check triggered under it remains valid for 12 months. A customer whose net deposits hit £505 while the £500 mark still applied, and who was checked then, will not face a fresh check under the £150 rule until that earlier check is more than a year old. The customer sees no interruption while a friend who never crossed £500 before 28 February gets asked for information after depositing just £160. Because the exemption clock runs from the date of the most recent check, large numbers of players checked under the old threshold are still shielded, keeping the £500 figure in circulation and making the lower limit appear inconsistently applied.

The indicators, one by one

The public records scan targets a list that spells severe financial strain. A bankruptcy order marks the most serious personal insolvency. A county court judgment (CCJ) is a court order to pay a debt; unpaid CCJs stay visible for six years. An individual voluntary arrangement (IVA) is a formal agreement to repay some of what is owed, binding on creditors once approved. A high court judgment (HCJ) involves larger sums. An administration order is a court route for those with debts, while a Debt Relief Order (DRO) is a cheaper alternative to bankruptcy for people with minimal assets and low income.

Each indicator shows the customer has already encountered a legal debt-resolution process. If the check turns up none of these, the operator has no further financial vulnerability obligation at that moment—provided it has not separately identified risk from its own customer data.

The twelve-month exemption

The obligation to run a vulnerability check does not bite if the licensee “has previously conducted a financial vulnerability check or a financial risk assessment within the previous 12 months”. That exemption is the reason one player can be asked for documents while another, depositing similar sums, is not. A financial risk assessment conducted for a different reason—perhaps during an affordability review—satisfies the condition in exactly the same way. The clock starts from the date of the last check, not the date the threshold was met, so timing matters enormously. The Commission has not published data on how many checks are being avoided because of this rule, but it is the single most likely explanation for the inconsistent treatment consumers report.

The next milestone is not a further statutory drop. For now, the £150 rolling net deposit is the line beyond which a purely public-record vulnerability check becomes mandatory—and it remains something that does not and cannot involve a credit reference agency.