Drop the pilot

Happy ICE everybody!

Whilst our intrepid team walk the floor at Excel London, it is left to yours truly to look on from afar and pick over the bones of recent statements from various members of the UK Gambling Commission (and the accompanying sinking feeling that inevitably comes with them). 

Perhaps most significantly, UKGC executive director Tim Miller announced “we will be setting up a pilot phase to see how the technology works and how it impacts consumers”. Andrew Rhodes said something along the same lines the following day.

This is a confirmation of a direction that was sign-posted in the consultation documents: namely that the UKGC doesn’t merely see its role as specifying precisely what operators have to do in order to conduct affordability checks, they are also getting into the business of cobbling together the specific solution they want operators to use. Hence, the idea of a pilot phase and the promise of “something new” in the offing.

Is this going to work?

At ClearStake, we’ve heard rumours of what this ‘something new’ might be, and we’ve also heard rumours that it doesn’t work, so let’s walk through all this step by step.

  • First, it seems inconceivable that Andrew Rhodes or any of the current UKGC management will stand over a system that doesn’t actually solve the problem. That means that this new system has to actually do the job. It has to get a decent read on a person’s disposable income (and where that income comes from)
  • Second, there is no way of doing that job without sharing financial data. This isn’t a statement of opinion, it is a statement of fact. So whatever the new system is, it has to involve financial data in some form.
  • Third, all the mood music heard to date suggests that this won’t actually be the case. I would love to be proved wrong, but it seems an attempt is being made to pull together various sources of data to provide some sort of financial approximation of a given individual, which in turn will be used to make affordability decisions (we will still have to do AML decisions the old-fashioned way, just to heighten the absurdity).

So where does all that leave us? It leaves us with a system that doesn’t work, and that will be holed under the water line the very first time an individual gets into difficulty when gambling, after having ‘passed’ one of these checks. And then we are back to square one.

But all that is some way down the line. And almost certainly significantly further down the line that you think.

Anytime soon?

Speaking of lines, how is HS2 getting on? OK, perhaps that was a little below the belt, but if anybody needed reminding that public sector delivery isn’t always on-time and on-budget, there it is.

At face value, it appears absolutely extraordinary to me that the UKGC are intending to actively put themselves forward as leading the delivery of a ‘solution’ to the challenge they themselves have created, and worse a challenge for which a solution already exists. It invites all sorts of questions around liability and responsibility, and what it surely means is that this is going to take some time.

When (not if) the pilot comes back with issues and areas where further work is needed, is the UKGC going to continue to run the project and see it through to completion? How long is this going to take? Do they have the skills? All these questions have to be considered very much up in the air. 

I don’t have the answers, but I can tell you that I suspect this proposed solution won’t actually be solving anything for some time to come. If it is, then someone somewhere is cutting corners, and I refuse to believe that will be anyone at the UKGC.

And meanwhile, life goes on

So where does all this leave operators? Well, as noted previously, very little has changed. Affordability (and AML) checks still need to be carried out. They ARE being carried out, today, using financial data. 

Until something changes (ie a magical new system undergoes a successful pilot, sometime in 2028), then operators will have to continue doing this. They can either do that manually using paper statements, or in the simplest, easiest and most frictionless way possible using Open Banking. 

Those are the only two options in town. One is about five times as effective as the other. And neither of them require a pilot.