How a punter with average losses of 4p a day got caught in an affordability check nightmare

A punter with annual net losses of just £16.22, the equivalent of 4p a day, has revealed the tortuous bureaucracy he faced to prove he could afford to bet after being subject to "Gambling Commission-mandated" financial checks.

Tom Lane, 57, has been battling to discover why his bookmaker placed a deposit restriction on his account this month despite describing himself as a “recreational and mostly weekend bettor”. 

Tracing the history on his account, Lane said he found he had deposited £415 since May 2018, the equivalent of a little over £60 per year, and withdrawn £270. When informed by email on December 2 that he was no longer able to make deposits “following an affordability review”, Lane had a balance of £39.58.

Lane, who lives in Dorset with his wife, owns his home, has held the same professional job for 30 years and has no debt, queried the decision given the sums involved. 

In response, his bookmaker, Unibet, told him "following changes in the Gambling Commission guidelines in September 2022, it became mandatory for us to conduct affordability checks for players". Customer support repeated the claim that its checks were mandated by the Gambling Commission on three subsequent occasions in their correspondence with Lane.

Excerpts from Unibet's correspondence with punter Tom Lane

The Gambling Commission denies imposing affordability checks on punters. This month, the regulator's chief executive Andrew Rhodes said British racing was wrong to blame plunging online turnover on the commission, writing in a letter to the Racing Post that "there are no current 'affordability' checks in force through regulation" and that criticism was based on "significant misunderstandings".

Having challenged the decision, Lane was told by the operator's customer services that the credit reference agency TransUnion provided the bookmaker with a credit score which was factored into affordability decisions and that the agency “uses a scoring system distinct from the one you might access directly through them”. 

Undeterred, Lane obtained his Statutory Credit Report (SCR) from TransUnion. According to Lane, TransUnion described his report, which he was told had been the basis for the account restriction, as “straightforward and without issues or any negatives”.

Despite the contents of his SCR, when contacting customer services to again request the lifting of his account restriction, Lane was told: “The score you have with [TransUnion] translates to a different score with us so that we can assign the [affordability] group.

“The agreement is with the UK Gambling Commission not TransUnion, so if your score was 800 with TU you may be in one scoring group that we have agreed with UKGC. Either way the system was bringing back a score that did not permit play.”

Following further correspondence, Unibet’s senior management team agreed to lift the restriction on Lane’s account provided he supplied photographs of his passport, proof of address and his three most recent payslips. No further details were provided on the affordability scoring system.

Andrew Rhodes: "no current affordability checks in force through regulation"

In response, Lane asked why 'source of wealth' details were required at such a low spend. The bookmaker said: “Gambling regulations within the UK are strict and this process is part of our proactive approach to safer gambling, and also in line with our agreement with the UKGC that this process will be completed for all accounts trading from the UK.”

Lane, who had never before experienced affordability checks, told the Racing Post: “I have a love of horseracing and I like to have a bet if I am watching it or other sport on the telly as it can make it more exciting. All my bets are small – I’m a 50p Lucky 15 punter or might have a fiver on something if I fancy it – and it’s certainly very affordable. 

“I’ve read all about affordability checks but I assumed they would only affect gamblers who bet substantially more than I do and may have problems such as debts to go with that. I never thought they would affect me in any way. 

“This is not a decision based on anything to do with why the checks were brought in. I do understand the reasons behind having something as there are people who are problem gamblers, who have addiction problems, and are gambling beyond their means. 

“However, it’s about how they’re implemented, so I am intrigued as to how on earth their system restricts an account such as mine. I’m hoping that ultimately they will ascertain there is something wrong with their system and correct it for the good of everyone."

He added: “I’m a believer in if there’s something wrong you make it right, and I’m a believer in the little person standing up to the big corporations when the big corporations are mistreating them.”

Lane’s experience comes following the publication of statistics by the Gambling Commission that showed online betting turnover on horseracing up to the end of March 2024 had plummeted by £1.6 billion in the last two years, creating a real-terms black hole in betting turnover of £3bn once adjusted for inflation.

Asked for comment on the restrictions placed on Lane’s account, its affordability scoring system and the percentage of its customers who had their accounts restricted, a spokesman for Unibet said: “We do not comment on individual customer cases. However, like most UK-licensed operators, [parent company] Kindred has a robust affordability model in place that utilises publicly available information to determine limits and thresholds for customers.”

Despite the bookmaker repeatedly stating the checks taking place were “mandated”, the Gambling Commission reiterated on Monday that there are "no current 'affordability checks' in force". A spokesman added: “In September 2022, new customer interaction rules came into effect. These require operators to consider indicators of harm, including spend, in considering overall risk of harm to a customer. These new rules did not relate to 'affordability checks'. 

“It is possible that the messages mix up the general requirement to identify indicators of harm and take action to support customers with the issue of 'affordability checks'. Andrew Rhodes has made clear on several occasions it is important operators do not state things are a ‘regulatory requirement’, or have been otherwise mandated by the Gambling Commission, when they are not, as this appears to be a common issue.”

Read more like this: 

Labour vice-chair of parliamentary racing group calls for 'urgent action to arrest financial decline' of the sport in Britain 

'It's costing turnover' - restrictions are forcing down online betting says professional gambler Neil Channing 

The Front Page: racing's £3bn black hole - what caused it and what does it mean for the sport? 

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