Gambling Commission wakes up
After seemingly lying dormant on the issue, the UK Gambling Commission (UKGC) has rubbed the sleep from its eyes and is looking closely at the rising threat of the illegal gambling market.
On 18 September 2025, the Commission published the first phase in a 4-part “series of reports examining the illegal online gambling market in Great Britain”.
What the Gambling Commission said
The research, conducted in partnership with Yonder Consulting, has produced new data that centres around player behaviours, motivations and personas.
Prevalence of illegal gambling
In Britain, the prevalence of illegal gambling is still relatively low, especially when compared to the big numbers of illegal gamblers in countries like Germany and The Netherlands.
This aligns with a 2024 report commissioned by the Betting and Gaming Council (BGC), which estimated that £2.7 billion is staked on the UK’s online black market annually, representing around 2.1% of the total wagered online across Britain.
The vast majority of Brits still prefer to use licensed operators, and the UK situation isn’t nearly as concerning as elsewhere in the world, but it is still significant and on the rise. It remains to be seen what the full impact of recent regulatory changes will be. Stake limits and financial checks haven’t been received well, but will that translate to hordes of players heading for unlicensed or illegal markets?
Who are the illegal gamblers?
The report identified 4 categories of illegal gamblers:
- Self-Excluders: Often problem gamblers who have subscribed to self-exclusion systems like GAMSTOP, but who continue to gamble despite this.
- Social Explorers: Generally directed by social media adverts and influencers, Social Explorers discover illegal sites through various channels.
- Accidental Tourists: Accidental Tourists are unaware that they are using an illegal site. They generally come across illegal platforms through search engines and recommendations.
- Skilled Advocates: These players knowingly and intentionally use the black market, often motivated by alternative games, better odds, or the availability of crypto banking.
The appeal of the unlicensed sector
According to the UKGC’s report there are various reasons (often quite obvious) as to why players choose to use illegal and unlicensed casino sites.
Many use these sites for their accessibility. These may be the ‘Self-Excluders’, or those who are banned from legitimate casinos. Illegal sites frequently don’t require ID checks.
The fact that illegal sites generally don’t pay taxes means they can often offer better odds, making them, in some respects, more competitive and more appealing than legitimate sites.
Anonymity a factor
Anonymity isn’t possible at legal casinos, which have stringent KYC (know your customer) protocols as well as anti-money laundering (AML) measures. Illegal sites may allow players to gamble anonymously, and even use virtually untraceable methods like cryptocurrencies.
Unaware(!?)
Surprisingly, the report found that most were unaware that they were gambling illegally. This seems tricky to verify (perhaps many players would say that). But, if this is the case, it may suggest that more education and awareness-raising should be effective. What is anecdotally evident though is that it’s often only a ‘trained eye’ or experienced player that can quickly tell the difference between a legal and unlicensed slot site.
Risks and downsides of unlicensed gambling
In this latest update, Andrew Rhodes, Chief Executive Officer of the Gambling Commission, describes the illegal market as “unsafe, unfair and criminal”, but this hardly scratches the surface.
Illegal sites may not offer the usual safer gambling tools, or player assurances. It’s often the case that they simply refuse to pay out. For these reasons, the black market is a dangerous place for players, especially the more vulnerable.
Illegal gambling is also a threat to the legitimate market, and for the British gambling industry it is certainly a concern. Illegal and unlicensed sites tend not to pay taxes, and they’re undermining the growing, legitimate market.
UKGC Illegal Gambling Hub
Alongside the data, the UKGC has launched its new Illegal Gambling Hub, which contains public guidance, research and updates. It sets out some of the Commission’s plans and findings, while also providing a chance for players to anonymously share information about their illegal gambling experiences.
Increased disruption
Disruption is one of the few weapons in the UKGC’s arsenal, but its efficacy is limited. That said, on a more positive note, Rhodes announced “a 10-fold increase in our disruption activity” since April 2024. Disruption only goes so far, but a 10-fold increase is likely to be, at the very least, a thorn in the side of illegal operators.
More urgency needed
Rhodes said “it’s vital that we have both a deep and broad understanding of how [the black market] operates.” There’s no doubt that evidence-gathering is a smart move. Good legislation is backed up by data. However, gathering and analysing data itself is not a proactive approach. It’s time for a pragmatic plan of action.
The danger is on our doorstep, and we’ve seen from examples across Europe that things can change very quickly. The longer the UKGC takes to address the problem of illegal gambling, the more players are at risk, and the more our gambling industry will suffer. Right now, urgency is key – unfortunately, urgency still doesn’t seem to be in the UKGC vocabulary.
Are new regulations behind the exodus?
As useful as the data may be, there aren’t many big surprises in there. The UKGC particularly should not be surprised by the rising popularity of the black market, given that its heavy-handed regulations are likely a major driving force behind it.
The Commission is simply reaping what it sowed, and the new data does nothing to suggest that its intrusive financial background checks and harsh stake limits aren’t to blame.
Warnings came thick and fast
There was no shortage of warnings. The Netherlands, Germany, Belgium, Australia and other markets also over-regulated and caused an outflux of players to the black market, inadvertently crippling the legitimate one. At home, media outlets and groups associated with the industry issued warnings, objections and pleas to the UKGC.
The good news: it’s not too late, but the thumb-twiddling has to stop. As the situation in the UK isn’t as dire as elsewhere, these warnings can still be heeded. There would likely even be some who would support the Commission dialling back some of its more oppressive moves of recent years.
If the UKGC has indeed arisen from its complacent slumber, it must snap into action and form a realistic plan that doesn’t involve blunderously making the same mistakes as other regulators.
UKGC statement: the pros and cons
There are both strengths and weaknesses to the UKGC’s current position.
Pros:
- Evidence-based decision-making is the only sensible approach, and the more data, the better.
- The discovery that most players are supposedly unaware about being on an illegal platform suggests that education is necessary.
- Most respondents agreed that operators should have to be licensed, suggesting general satisfaction with the wider system.
- Increased levels of disruption are a good thing, and this may have a measurable, damaging effect on illegal operators.
Cons:
- A significant number of players appear simply not to care that they're playing on illegal sites.
- Some data supports that increased illegal gambling is a result of the UKGC’s newer legislations and restrictions.
- Data itself is not a plan of action, and imposing new restrictions may just worsen the situation.
- Disruption only goes so far; new operators can spring up quickly and easily.
What else should the UKGC consider?
The UKGC should be working more closely with the government and law enforcement agencies to increase its power and ability to intervene. Its powers are currently limited, and there hasn’t been an update on anything more than ‘disruption’ in some time.
While the best approach to tackling illegal gambling is likely to involve addressing the source, there has been little discussion of consequences for illegal gamblers. Many gamble illegally on purpose, and seem not to care. Harsh punishments would be unreasonable, but, as it stands, players don’t have many incentives not to gamble illegally. Maybe an awareness of some of the other illegal activities funded by illegal gambling would go some way to players at least pausing for reflection.
Where might we be in 12-18 months?
This is just the first in a 4-part report. The remaining 3 parts, which will be released “over the coming months” will cover:
- Section 2: Engagement data and trends
- Section 3: Enforcement and disruption activity, highlighting the work of the Illegal Markets Team
- Section 4: The challenges of estimating the size of the illegal online market in Great Britain
The UKGC needs to act more quickly than this would suggest. For this reason, things may get worse before they get better. As it stands, the Commission hasn’t published a comprehensive plan for actually addressing the problem.
That said, data gathering is a key step, and it may suggest that the Commission is gearing up for a more proactive approach to dealing with the black market. A cynic might wonder why ‘challenges of estimating the size of the illegal online market’ is part 4 in this exercise rather than simply getting on with actually tackling the illegal online market.
Final words
The situation is not good, and if early warnings had been heeded, we might not be in this position. Still, with a sensible, evidence-based, practical approach, a great deal of damage can still be avoided. Time is crucial though, and there’s not much left.