Affordability Checks Are The New Normal


Adam Doyle is TruNarrative’s Head of Gaming and a 10 year veteran of Identity and Financial Crime Management in the Gaming industry.

Here Adam outlines his thoughts on affordability, protecting players and staying ahead of the curve…  



Affordability Checks Are The New Normal

I frequently use online gambling sites and have a few accounts with different operators.

Whether in a work capacity or simply as a customer of the gaming sites, I take a great interest in how each of the operator’s present their customer journey. Each has its take on how best to onboard, how best to transact and of course, how best to interact with their customers, especially in light of the latest guidance from the Gambling Commission.


When I play, I want to sign up, bet, and cash out with minimum effort.


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Gambling customers, just like consumers of other online products and services, want things to happen in the blink of an eye.

The trend across online retail and financial services for instant delivery influences consumer expectations in our industry as well. It is, therefore, logical to suggest that operators with the lowest customer friction throughout the customer journey will see increased retention and higher overall lifetime values.

However, in an increasingly complex regulated industry like ours, the requirement for friction in the customer journey is becoming harder to avoid. KYC checks, device monitoring, anti-money laundering assessments, biometric review, and requests to provide evidence of affordability, are now all becoming a common part of a player’s journey. However, this wasn’t always the case!

Seasoned customers are now expectant of a certain level of checks that are becoming standard across the industry. But there was an interim period where early adopters of higher friction journeys will have lost sign-ups to later adopters. In the short-term late adopters did not experience the same drop out rates.


Of course, regulation catches up with the whole industry in the end.


There have been occasions when operators haven’t succeeded in meeting regulatory expectations, as players slip through the gaps of an often-compliant, but sometimes imperfect and disjointed process of customer interaction and subsequent monitoring. I have seen instances where this is caused by a combination of technology shortfalls and human error, rather than complacency.

Conversely, there are examples of players now testing these new regulations. This manifests as finding unforeseen loopholes in the process, or taking advantage of bonuses open to abuse, and in some cases, manipulation of responsible gambling guidelines to leverage their position over the operator.

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I spoke to an operator recently who had found a forum post explaining to its readers how to have lost bets refunded. 

The scripted process went something like this….Choose an operator with less stringent processes or with limited support teams at certain times (usually late night/early morning) and then included a script for exactly what to say, to claim they should not have been allowed to place the bet.  Other operators have also mentioned they are seeing evidence of this type of activity.


So what’s next?


Unquestionably, regulation surrounding affordability will continue to tighten.

Already this year we’ve seen multiple updates to the affordability guidance issued by the Gambling Commission, especially in consideration of COVID-19.

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This will likely expose further shortcomings in the operator’s tech and process, leading to increased player friction and further manual work for operators and therefore greater potential for human error.

With the current economic situation, the Gambling Commission is rightly showing concern for players who may be experiencing financial hardship by requesting operators strengthen checks to ensure every player can afford to place their bets.

However, unlike a financial institution, gambling operators are not currently able to receive detailed affordability information without an intrusive, very high friction process involving the manual submission of payslips or bank statements. Most operators have historically reserved this manual, labour intensive process for high risk, and high-profile players.

With the latest guidelines, I foresee a much more detailed affordability assessment for almost every player. Focusing on thresholds and triggers for deposit and play patterns, the ability to review and amend these instantly will be key. However, minimising customer friction throughout will still be a priority for most operators.


Q: So how do we bring a comprehensive affordability assessment into a low friction customer journey?

A: More Data Sources, Layered Approach, New technology


Tying together disparate sources of information is key to getting a full picture of a player early on in their journey, ensuring they continue to play responsibly, and ultimately being able to evidence this to the regulator.

Naturally, operators will be concerned about the levels of friction and the potential high operational cost of implementation.

Here are a few things that are being used in the industry but in isolation and not as part of a layered approach. Using isolated solutions means it’s almost impossible to build the full picture of a customers affordability.


•        Risk Rating a player upon registration or first deposit

•        Operators Responsible Gambling tools – Self-exclusion, take a break tool, spending limits, internal and industry watch lists

•        Using the likes of CRA data to support affordability assessments

•        Monitoring behaviour around deposits, withdrawals and play patterns, applying triggers and thresholds accordingly

•        Human interaction, sometimes a player wants & NEEDS that conversation

•        Advanced matching across application data and third party data sources

•        Open Banking. The technology is there now, so let’s offer players this option alongside manual document submission


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Here at TruNarrative, we help operators ensure future compliance and market agility by implementing these techniques and data sources into a real-time automated and layered process flow.

Using solutions and data sources in isolation can lead to an operator making incorrect decisions when interacting with players. Using a layered approach with multiple solutions together, is key to building a picture of a player’s affordability and their behaviours.

Some of these techniques will in the short term increase perceived customer friction, requiring a change in customer attitude.

Explaining to customers as they move through their lifecycle that the extra friction is for THEIR SAFETY, will be key.



That’s personal! I’m not telling you that…

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Operators will need to engage with their customers in a manner that keeps them safe, without being seen as intrusive or ‘parental’.

Some players have now come to accept the requirement to submit identity documents at some point in their customer journey. I would say, providing operators maintain the lowest possible friction, most customers will in time accept the new requirements to submit affordability information.

Example: It is now commonplace in Sweden for players to sign into their bank account on sign up to allow the operator access to affordability data.

It will be important to use technology to keep friction low and explain to customers why these new permissions and information are being requested. In the long term, this will reduce what the player deems as friction, mitigating drop out and create an overall safer environment for players.


Customer acquisition and maintaining engagement has never been easy.

Marketing expenses, managing affiliate relationships and building a brand is all part of what we do, so, understandably, there may be resistance towards anything that increases overall customer friction, and some may say diminish their experience.


As with every regulatory evolution, there are winners and losers in the short term, some operators will see a higher drop off rates, but I think eventually all operators will be collecting extensive affordability information on an increasing majority of players.


This isn’t just a work/player issue for me, it’s a societal issue.


Gambling, shopping and spending money on non-essential items isn’t bad!!

Gambling, shopping and spending money on non-essential items when you haven’t got enough money to pay your mortgage or rent that month or, you haven’t stocked the cupboards to ensure you and your family can eat that week/month is bad.

I genuinely believe the new affordability requirements are part of the gambling industry changing for the better! Staying transparent, talking to players about what is happening and getting ahead of the curve with technology will be the key to the next few years.


If you like reading my thoughts and you have made it this far, why not find out how I and TruNarrative can help you implement technology and data solutions to comply with the latest regulations and maintain long term business agility.