
ARC: Affordability checks could be imposed on “highly selective” evidence
Racecourse operator publishes Gambling Commission consultation submission as it rails against the proposed measures


Arena Racing Company (ARC) has suggested affordability checks could end up being imposed on “highly selective” evidence that may damage horseracing, rural economies and do little to improve problem gambling rates.
The operator of 15 racecourses and five greyhound tracks in Great Britain released its submission to the Gambling Commission’s (GC) consultation on the much-derided affordability checks following the closure of the process on 18 October.
ARC did not pull any punches in its response, claiming the measures are “potentially dangerous” for racing, despite making the concession that it supported the GC’s aims “in principle”.
The company also said the measures, should they be implemented, would “deter” bettors from using licensed operators and also would “threaten their right to privacy”.
The proposals for affordability checks include two levels. The first will see light touch checks for a net loss of £125 within a rolling 30-day period, or £500 within a rolling 365 days.
The second assessment at an enhanced level will see checks deployed when a bettor has a net loss more than £1,000 in a rolling 24 hours or £2,000 in rolling 90 days.
In a note accompanying its public submission, ARC said: “[Affordability checks] will impact countless legitimate consumers who have no issues with gambling.
“For example, one proposal – to impose checks on any customer losing £125 in a rolling 30-day period – encompasses a large number of legitimate consumers playing within their means. This is not a targeted measure.”
The organisation also took aim at the suggestion by the GC that only 3% of accounts will be impacted by the checks.
ARC continued: “This figure includes dormant accounts within its scope. It severely underestimates the potential impact of the checks and should not be used as a basis on which to decide on their implementation.
“The evidence provided throughout the consultation has been highly selective. We are concerned that this undermines due process.
“It also means the consultation is likely to significantly underestimate the impact of the proposed measures on the behaviour of betting consumers, and therefore the financial impact on the horseracing industry.”
ARC also noted the lack of pilot scheme in regard to affordability checks, citing Gambling Minister Stuart Andrew’s admission that such a scheme could be run to ensure frictionless checks would work as “envisaged”.
ARC added: “There is however, no information in the consultation on what form this pilot programme would take, how long it would run for, who would conduct it and how its independence and integrity will be safeguarded. This is a major omission, in our view.
“It means that the Gambling Commission is consulting on an entirely untested regulatory intervention with potentially significant economic and social consequences – but not consulting on how the testing process would work.”
Last week, the Gambling Consumer Forum, a lobby group representing the interests of punters, said affordability checks would be amount to “unleashing destruction” on the industry.