Open banking gives operators real visibility into player finances, but fragmented regulation and missing consent frameworks are undermining what affordability checks can actually achieve.
Affordability checks are tightening across regulated gambling markets as player financial data becomes available to operators due to open banking. However, a question remains over data fragmentation across operators, with scrutiny swirling as to whether current data standards are fit for purpose. There’s also the question of tighter frameworks, and whether they are pushing players toward unregulated alternatives as opposed to protecting them.
Payment Expert‘s 2026 Payments Digital Day closed with a panel session – Rethinking Affordability: How Data is Transforming Safer Gambling – bringing together voices from across the gaming and payments ecosystem to examine whether current affordability frameworks are structurally capable of delivering what regulators and operators intend.
The panel included Charlotte Shelberg, Director of Product at LeoVegas; Management Consultant at Spyglass Insights, Rahul Das; Mariola de la Piedra, Head of Marketing and Innovation at GELSA; and Ambrose Muscat, MLRO and Compliance Manager at an EMI and CASP.
A one-way window to safer gambling
Open banking gives licensed operators a window into a player’s financial behaviour, but the window closes the moment the player moves somewhere else. Hit a threshold with one operator, register with another, and the clock resets. The data exists, it just does not travel; a key barrier to implementing safer gambling.
Muscat said an operator running across ten jurisdictions has one dataset and ten different rulebooks. “Unless regulators and authorities actually have their radars on, we’re kind of shooting ourselves in the foot.”
Das identified a separate issue in player aggregation: two operators assessing the same customer’s current account data will arrive at different affordability figures. If both extract what they individually consider sustainable, the combined draw may leave the player unable to cover his bills at the end of the month. “If we both try and pull from the same customer, they’re in trouble – and the unlicensed operators will take the rest.”
In the UK specifically, Das noted the gambling regulator proceeds on the assumption operators can access current account turnover data held by credit bureaus. In practice, it is ring-fenced and has not been consented for use by gambling companies. The data exists in the system; it simply cannot be touched, a detriment to safer gambling efforts.
Resolving it requires the regulator to go to the banks directly and build the consent framework itself, rather than assuming the problem is already solved. “It takes a village to keep the customer safe. It’s everyone’s responsibility,” he says.
Shelberg said player-set limits work where regulator-imposed ones tend not to. “Deposit limits are useless if applied by the regulator. What actually works is when the customer can make use of it themselves.”
A player who treats a limit as their own is more likely to respect it, and more likely to think about it holistically across all the operators they are playing with, effectively engaging in safer gambling.
The grey market problem
Displacement risk came up repeatedly across the session. Muscat cited figures suggesting Germany’s grey and black market expanded by a factor of 15 following the introduction of stricter controls. “It’s an unadulterated failure if you’re trying to protect people. The result is more of them going to markets where they have close to zero protections.”
Das placed this in a longer arc, arguing the original purpose of gambling regulation – balancing commercial viability with consumer protection – has given way to something closer to a political and moral project. Fines have grown, restrictions have tightened, and the industry has contracted under regulatory pressure. “I think the balance has shifted too far toward restriction. In some ways, affordability has been mixed up with AML and policing.”
De la Piedra said much of the data infrastructure discussion is largely academic across Latin America, where cash still accounts for upwards of 70-80% of transactions in much of the region. Open banking is in its earliest stages, with Colombia only recently passing new legislation on the subject.
In the absence of the financial signals which underline UK or German affordability frameworks, operators have to build from behavioural and transactional data instead, integrating signals across the customer journey rather than conducting periodic checks.
De la Piedra’s company recently launched a virtual wallet giving players end-to-end control over their funds and self-imposed limits. “If we reposition affordability as safe play limits – something empowering customers to set their own limits – it completely changes the relationship and maximises lifetime value,” she says.
Who speaks for the industry?
The panel also covered a structural absence neither side could resolve. Gambling has no continental institution capable of coordinating standards across borders or making the collective case to regulators.
Muscat asked who speaks for the industry at a European level in the way FIFA speaks for football. “We joined an open market only to be told it’s not that open. Until European countries agree on a continental model – one not just about each state maximising its own tax revenue – people will keep hopping from one operator to another, and from one jurisdiction to another.”
Shelberg acknowledged the European Betting and Gaming Association as a partial answer, while noting gambling remains politically easy to tax and difficult to defend.
Getting regulation right requires understanding how the market actually works – and, she said, that understanding is still missing in many of the places where the rules are being written.
