UKGC’s findings focus on the initial £500 net deposit threshold over a rolling 30-day period. The threshold was reduced to £150 from 28 February 2025, so the regulator still needs more evidence on how the rule works at the lower level.
Early Data Points to Smooth Adoption
The Commission analyzed data from remote operators that account for roughly 90% of customers in Great Britain. The sample included both large and smaller businesses.
Many operators were already prepared. According to the regulator, 68% already had a form of financial vulnerability check in place on a voluntary basis. A further 26% introduced them in anticipation of the rule changes.
Speed Was the Strongest Result
Checks were performed on an average of 7% of active customer accounts within the first three months of the requirement. Notably, most checks were returned quickly. The Commission found that 78% were returned within 10 minutes, with another 10% being returned within two hours.
The speed is particularly relevant for compliance teams, since checks need to be done within live customer interaction systems. If checks were slower, operators would face more pressure to add friction to the customer journey. The early data suggests this was limited at the £500 threshold.
Operators also used different timing models. Approximately 63% conducted checks when a customer reached a certain limit. Another 36% went with an early check such as during registration or initial deposit. Under the license condition, operators do not have to run a new check at the threshold if a financial vulnerability check or financial risk assessment has been completed within the previous 12 months.
Public Data Remains the Limit
Furthermore, the Commission found confusion around what data the checks can include. Some operator responses suggested a misunderstanding about the data used in the checks. According to the regulator, the financial vulnerability checks can use only public record details linked to serious financial risk flags. The indicators of such risks include:
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Bankruptcy order or equivalent;
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County Court Judgment;
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Individual Voluntary Arrangement;
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High Court Judgment;
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Administration Order or decree;
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Debt Relief Order or equivalent.
The Commission’s license condition also confirms that operators should consider the information in combination with any permitted customer data and take proportionate action where risk is found.
CCJ Handling May Need Better Guidance
The most sensitive issue is how operators respond to a single County Court Judgment. The Commission emphasized that a CCJ may be linked to a smaller amount or dispute, and thus heavy restrictions should not be imposed automatically. In cases with automated processes, the regulator suggested softer steps taken by operators, like deposit limits or manual review.
Takeaways
Early findings suggest the checks did not create major visible disruption at the £500 threshold. The real test will be how operators apply the lower £150 threshold over time. Operators need rules on how to respond to public-data flags and avoid unnecessary account restrictions.
