Gambling Commission Will Not Be Distracted From Financial Risk Assessments, Gardner Tells Regulators in Lima

Speaking to the world's gambling regulators in Peru, the Commission's acting chief executive answered critics of affordability checks and of her own survey data in unusually blunt terms. On the illegal market, the money has arrived but the new court powers have not.

• Sarah Gardner, acting chief executive of the Gambling Commission, told the International Association of Gaming Regulators (IAGR) conference in Lima on 20 October that it "can't" be distracted from implementing financial risk assessments, after what she called "frenzied attempts" to make it change course
• She said the full consultation response, held back when implementation was announced in July, is planned for this autumn
• She defended the Gambling Survey for Great Britain against critics "some of whom have some vested interests"
• The first £7 million of £26 million in government funding against illegal gambling arrived in April, she said, but court powers to suspend IP addresses and domain names are only "coming soon"
• She warned that suppliers calling their systems "Gambling Commission approved" are not telling the truth, and said the Commission is still recruiting a permanent chief executive

Gardner Used a Global Stage to Answer the Commission's Critics at Home

The Gambling Commission published on 21 October the text of the keynote Sarah Gardner delivered the previous day at IAGR's 2026 conference in Lima, noting that it is the speech "as drafted and may slightly differ from the delivered version". The conference runs from 19 to 22 October and is hosted by Peru's Ministry of Foreign Trade and Tourism, according to IAGR. It was the deputy chief executive's second published speech this month as acting chief, after her address to Allwyn's player protection conference.

The sharpest passage concerned financial risk assessments (FRAs), which give operators access to limited credit reference data on their highest-spending customers. Gardner said there had been "at times frenzied attempts to get the Commission to change course", including "sustained efforts to suggest that a process that doesn't touch over 97 per cent of accounts and is frictionless for all but 0.1 per cent is somehow not frictionless". She promised to work through evidenced concerns and to support "other sectors that fear an adverse impact, like British horseracing", then drew the line: "But what we can't do is be distracted from implementation."

Her evidence was the pilot. High-spending gambling customers were two to four times more likely to have a debt management plan, and two to five times more likely to have had a default in the previous 12 months, than the wider population, she said, adding: "We have not identified a better way than FRA's to tackle that risk." Fewer than 3% of accounts would need an assessment when fully implemented. The consultation response was held back in July so the detail could be worked through with industry, and "we plan to publish the consultation response this Autumn", she said. The first stage, announced in July, triggers at net deposits of £5,000 in 24 hours for customers aged 25 and over. Racing opposes the checks: the British Horseracing Authority's chief executive, Brant Dunshea, called the July decision "one of self-harm on an immense scale".

Gardner widened the charge to what she called "whataboutary". Her example was the Gambling Survey for Great Britain, which she said "continues to be attacked by a small number of critics, some of whom have some vested interests". The survey's 2025 report puts 2.4% of adults at 8 or more on the Problem Gambling Severity Index, down from 2.7% in 2024, and new questions will soon track use of the illegal market, she said.

The Illegal Market: The Money Arrived in April, the Powers Have Not

The November 2025 Budget gave the Commission £26 million over three years to tackle illegal gambling, and the first £7 million "came online in April", Gardner said. She repeated the 2025 to 2026 results that Sue Young, the Commission's executive director for operations, first set out in June: 741 cease and desist notices, 397,527 URLs reported to search engines with 266,667 removed, 1,068 websites referred for delisting and 1,134 websites taken down or geo-blocked.

New powers, she said, are "coming soon" that will let the Commission apply to a court for IP address and domain name suspension orders. They sit in section 170 and Schedule 18 of the Crime and Policing Act 2026, which received Royal Assent on 29 April; legislation.gov.uk marks the section as prospective, meaning it has not been commenced. The Home Office says the orders will "primarily be served internationally", where registries need a court order to act.

Gardner also pointed to research the Commission published on 20 October, the third phase of its illegal online gambling series, carried out by Yonder Consulting. It finds that the search term "not on GamStop" has become "a primary gateway" to illegal sites, and that the strongest predictors of illegal website use are seeking sites not blocked by GamStop and sites that ask for minimal personal information.

B2B suppliers serving illegal operators alongside licensed ones is "something we are clear is unacceptable", she said; in July Evolution Malta Holding agreed a £4.75 million settlement after its games appeared on six unlicensed websites accessible in Great Britain. Affiliates, she said, are "too often" happy to promote licensed and illegal operators at the same time. She also said suppliers had been telling operators that specific systems are "Gambling Commission approved", which "is of course not true".

The speech did not mention prediction markets or the statutory levy, and AI appeared only as a topic regulators are "jointly exploring". Gardner welcomed Ruth Evans as chair and Sarah Fox to the executive team, and said the Commission is "now working on recruiting Andrew's successor".

The Commission Has Decided to Fight the Affordability Argument in Public

Regulators rarely describe their critics' tactics in front of their peers. By calling the lobbying "frenzied", Gardner has made FRAs a test of the Commission's authority as well as a policy, under a new government and before a permanent chief executive is in post. Her strongest card is the pilot's debt and default data. Her weakness is that the full evidence base is unpublished, so critics are asked to accept conclusions before they can check the working. The autumn consultation response now carries more weight than usual: if its methodology is thin, the "vested interests" charge will be turned back on the regulator.

The Commission's Own Research Makes the Critics' Best Argument for Them

The Phase 3 findings say friction over access and data is what most strongly pushes people to illegal sites. That is precisely the channelisation argument behind the industry's black market warnings. Gardner's answer, that FRAs replace document requests with a silent credit check for most high spenders, is coherent, but it is a prediction that only the new survey questions on illegal gambling can test. Meanwhile enforcement remains largely voluntary: the 1,134 disrupted sites came through cooperation with search engines and platforms, and the court orders that would reach offshore registrars await commencement.

The Commission has told the world's regulators it will not blink on affordability. Whether that stance holds will depend on the evidence it publishes this autumn and on what its own data shows about the illegal market.