Tom Walton held a 5% share in Imperial Emperor, a horse good enough to finish fourth in the Dubai World Cup. That run should have put close to £30,000 in his account. Four months on, he's still waiting. He's one of several members and trainers of Deva Racing left chasing prize money and training fees, after shares in Imperial Emperor were allegedly sold to 130% of the horse. On 24 July 2026 the BHA barred Deva from running horses in Britain at all. When journalists went looking for director Ryan Tongue, his email auto-replied that he'd been signed off sick, and the inbox wasn't being monitored.

It's the fourth such collapse since 2019, and each one exposes the same structural gap: nobody with statutory power is actually watching what happens to members' money once they've paid it.

Where the neglect is specific

The BHA describes its 2024 syndicate licence as proactive regulation. Look closely and it tests one thing: whether an operator can advertise and promote shared ownership properly. It does not test whether a member's money sits in an account ring-fenced for their syndicate, or in one pot shared with every other syndicate the same operator runs. It does not test whether the training fees a trainer invoices match what a member is billed. It says nothing about VAT, and nothing about how quickly prize money has to reach a member's account.

Nor is this vague. The BHA has said, in correspondence circulated to owners' groups this year, that it "is not concerned with the regulation of any services provided by clubs or syndicates," and that such matters sit "entirely beyond the BHA's governance." It has gone further still, formally stating it is not a "competent authority" under the Provision of Services Regulations 2009 — the law that would otherwise oblige it to act on exactly this kind of consumer harm.

Set that beside its own promotional language and the neglect looks pointed rather than incidental. When the 2024 licence launched, the BHA's own head of participant services described the growth of shared ownership as key to racing's long-term sustainable future. There are now more than three thousand syndicates in Britain — a recruitment number the BHA is happy to publish. It wants credit for every new member who joins. It wants none of the responsibility for what happens once they've paid.

The neglect shows up again in the one fix the BHA could plausibly deliver without new regulation: a transparent, live register of who owns what. Racing Digital, the joint venture between the BHA and Weatherbys built to modernise ownership records, is meant eventually to provide exactly that. Its own chair departed amid what one trade title politely called "a period of turbulence," and its overseers admit the programme has faced "challenges" and past "uncertainty and speculation" caused by its own silence. A project meant, by rights, to have already replaced the systems it's still promising to replace is not evidence of a regulator quietly working on the problem. It's evidence of a fix that's been available and unbuilt for years.

Club members have even less

It gets worse for anyone who's joined a racing club rather than a syndicate. Clubs don't involve ownership shares at all — members typically get trainer updates, yard visits and sometimes a cut of prize money, but no defined stake in the horse. Because of that distinction, racing clubs sit entirely outside the BHA's syndicate code of conduct. A syndicate member at least has a nominal set of rules to point to. A club member has none. Given how easily a business can drift between the two categories — sometimes without members noticing, sometimes by design — this isn't a small gap sitting beside the first one. It's a second, larger gap sitting directly behind it, for a category of member the BHA barely acknowledges separately at all.

What actually needs to change

The Racing Innovation Group has put together the clearest blueprint the industry currently has, built question by question around exactly where the BHA's licence falls short. Stripped to its essentials, it comes down to five changes:

• Mandatory disclosure of the horse's purchase price, and any mark-up on it, as a contract term rather than an optional courtesy.

• Transparent training fees, so the trainer's actual invoice and the sum a member is billed are both visible, not just the second.

• Clear VAT treatment, stated plainly in the contract rather than buried in a single line deep in the terms.

• A gross-to-net breakdown of prize-money deductions, written out before anyone signs, rather than discovered afterwards.

• A live, BHA-maintained share register — one of horses and ownership percentages, one of owners and their shares — open to inspection, so an oversold horse can be caught before the money disappears rather than after.

To that, RIG adds the recommendation that would actually give the rest some teeth: mandatory professional indemnity insurance, funded by a levy on syndicators, alongside genuinely ring-fenced client accounts and an independent complaints process run through the BHA rather than left to the small claims court. None of this requires new legal powers. It requires the BHA to accept that having taken on the licensing of syndicators, it has taken on responsibility for what they do with members' money too — and to extend the same basic protections to racing club members, who currently have none at all.

Australia already answered this

Australia settled the argument years ago. Syndicates there are regulated as managed investment schemes; licensed operators must carry professional indemnity insurance as a condition of their licence, funded by the industry itself. Britain has had this comparison in front of it since at least 2019 and adopted none of it. Each collapse since has produced the same response — sympathy, a promise to learn lessons, another checklist — and the underlying licence has never once been extended to cover the money.

Still waiting

None of this is abstract for Tom Walton, or for the racing club members whose position is worse still. Every one of RIG's five changes is a modest, implementable fix for a specific, named gap — not a demand for a new bureaucracy, just for the licence the BHA already issues to actually cover the money as well as the marketing. Until it does, the growth figures the BHA is so keen to publish will keep being underwritten by the very members, syndicate and club alike, that it has so far declined to protect.