7995: The case for change
The current landscape
Licensed gambling operators in the UK operate under very comprehensive regulations. They have been required to apply mandatory KYC and AML checks, affordability verification, ongoing transaction monitoring, and source-of-funds processes. These standards are comparable in many respects to those applied by banks themselves.
MCC 7995, the merchant category code applied to gambling transactions, applies a single classification across the entire landscape without distinguishing between UK Gambling Commission-licensed operators and unlicensed offshore sites. The Level Playing Field Group's objective is to ensure that how gambling payments are treated, across classification, pricing, authorisation, and data, reflects the standards and risk profile of the regulated industry today.
What the data shows
Regulated gambling merchants consistently post some of the lowest payment risk metrics of any merchant category in the UK:
Fraud rates below 2 basis points, which is lower than clothing retail, hotels, utilities, and most digital content categories
Chargeback rate of 0.01%, against a UK-wide average of 0.6%
Bank-grade KYC and AML applied to every customer at onboarding, with ongoing monitoring thereafter
Despite this, regulated gambling merchants typically pay 60–90 bps in processing costs, compared to 40–60 bps for high-street merchants of comparable volume.
Payments risk and reputational risk
The payments ecosystem does not currently apply a consistent definition of reputational risk as it relates to regulated gambling. In 62 stakeholder interviews conducted for the independent whitepaper underpinning this initiative, participants were unable to provide a clear or shared definition of what additional brand risk means for a Gambling Commission-licensed operator.
The group's position is that payment treatment should be grounded in measurable, transaction-level data, and that where reputational considerations exist they are best addressed through clear policy.
What the group is working toward
A payments ecosystem for regulated gambling that is fairly priced, data-driven, and fit for a mature, heavily regulated industry. One where authorisation decisions reflect true transaction risk, classification frameworks distinguish between licensed and unlicensed operators, and consumer protections are supported by the infrastructure consumers rely on.
The group is actively exploring practical paths, including:
MCC evolution
MID whitelisting
Enhanced use of existing transaction data
Standardised decline codes
Data consortium
Consumer outcomes
Licensed gambling operators in the UK operate under very comprehensive regulations. They have been required to apply mandatory KYC and AML checks, affordability verification, ongoing transaction monitoring, and source-of-funds processes. These standards are comparable in many respects to those applied by banks themselves.The regulatory framework around licensed gambling exists to protect consumers. Licensed operators provide dispute resolution, self-exclusion tools, affordability safeguards, and KYC processes designed around the consumer's interests. The group's work on payments infrastructure to improve authorisation rates, reduce friction, and modernise classification, helps ensure that infrastructure supports the consumer protections the industry is built around.
The research
The group's work is grounded in the research of Time for a Level Playing Field for Regulated UK Gambling Payments, an independent whitepaper conducted by Piran Consulting Ltd and commissioned by PXP. 62 interviews across the ecosystem, covering regulated gambling merchants, card schemes, acquirers, issuing banks, and payments industry experts.