The long war – regulators vs illegal sites
The war on illegal gambling continues, but it seems to be getting harder for the Gambling Commission (UKGC) to keep up, let alone make gains. With the same problem being seen across almost all regulated markets, finding ways to outmanoeuvre black market operators is getting harder and harder – but is it possible to stop it?
Why are players going to unlicensed and illegal sites?
Before you can try to fix a problem, you’ve got to understand why it exists. With up to £2.7bn staked online with black market operators in the UK each year, understanding the ‘why’ is important.
In many ‘war on illegal gambling’ pieces, authors look to the illegal drugs market as a comparison, but I don’t think it’s the right comparison to make. There’s not a cocaine aisle in Tesco!
Instead, it’s more like illegally streaming a new series, or opting for the fake Chanel bag. Sure, there’s a legal option, but sometimes it’s harder to reach, costs more money, or is just less convenient.
Introduction of stake limits
Stake limits (£2 per spin for under-25s, or £5 for those over) were introduced in mid-2025 as a way to curb the spending of players who couldn’t afford it. But, for those who can afford it, they were simply an annoyance.
Online casinos must adhere to this rule as part of their UKGC licence, or risk having it revoked. Black market operators don’t have the same issue, so players can wager exactly what they choose.
Introduction of personal financial checks
Affordability checks (officially known as ‘financial risk assessments’) were rolled out between August 2024 and February 2025. These aimed to find vulnerable players and prevent them from wagering more than they could afford. However, the loss amounts set for when intervention could kick-in were considered to be very low – £125 net loss in a rolling 30-day period or £500 in a rolling 365-day period.
While well-intentioned, these checks were widely unpopular and considered intrusive by many UK players. For some, they became an incentive to gamble elsewhere.
‘Not on Gamstop’
One of the UKGC’s great accomplishments is a self-exclusion system that really works. Gamstop prevents those who self-exclude from accessing licensed online casinos. The problem is that unscrupulous illegal sites directly target these players.
Phrases like ‘not on Gamstop’ have become common marketing ploys in the illegal casino landscape. They target the very people who most need to be protected, because they can’t use a legal casino and they often make these sites the largest amount of money. Though this is of little consequence to the illegal operator.
Appeal
Illegal sites have fewer rules to follow and fewer overheads too. They don’t need to pay for licensing, or uphold the rules. This means that they can afford to offer larger bonuses, fewer registration restrictions, and sometimes larger game catalogues too.
For many players a massive welcome bonus is a huge tick, one that’s big enough to make the lack of a licence seem less important. Not having to include any of your personal details upon registration is more convenient too.
It’s only when things eventually go wrong that the reason for that registration and KYC process, or the lengthy bonus terms finally make sense – and by then it’s too late.
The innocents
With 5.4% of UK gamblers using both illegal and legal sites and only 0.8% using exclusively illegal, it’s fair to assume that a proportion of players simply don’t realise they’re playing at an illegal site.
Illegal operators are brilliant at mimicking the look and feel of licensed casinos. They use familiar branding cues, English-language support, GBP payments, and even UK-facing SEO tactics to appear legitimate.
Search results don’t help either. Black market sites regularly outrank licensed operators for generic terms, and once a player is on-site, there are few obvious warning signs until a withdrawal is delayed, restricted, or refused entirely.
For these players, the move to an illegal site isn’t a protest or even a calculated risk. Instead, it’s accidental – and by the time they realise, the protections of regulation are already out of reach.
Warnings ignored
Before the introduction of affordability checks and stake limits, some major players in the UK industry warned about the potential implications.
The Racing Post was particularly outspoken about the impact that affordability checks might have. They ran numerous articles leading up to the introduction of the checks, stating:
- Racing owners thought the checks to be an ‘excessive, illogical and disproportionate intrusion’
- That keen bettors felt this could be their ‘last year punting’
Even amassing more than 100,000 signatures asking for the checks to be thrown out wasn’t enough.
While the BGC were a little more measured in their criticism, indeed supporting stake limits, they still had plenty to say about affordability checks. Michael Duger, CEO of the BGC in 2024 said:
“At the BGC we supported enhanced checks for online gambling, but have been clear throughout that checks should be carefully targeted on those showing signs of problem gambling, or those who are at risk of harm, so operators can use technology to take swift action. They must also remain frictionless for the vast majority, as punters have repeatedly made clear they will not submit to intrusive checks.”
So why were they ignored? Only the gambling commission can truly say, but it does seem this may be a case of ‘well, the wheels are already turning’. By the point these comments gained traction, the implementation of the White Paper was already underway.
The Gambling Commission – why they did it
From the Gambling Commission’s perspective, the reforms introduced after the White Paper were driven by a clear mandate: reduce gambling-related harm at a population level.
Affordability checks and stake limits offered visible, enforceable measures that demonstrated action, particularly in response to political pressure and long-standing criticism from anti-gambling groups.
Stake limits were seen as a direct way to curb excessive losses on high-intensity products. Financial checks were designed to identify vulnerability earlier and prevent harm before it escalated.
In public statements though, the Commission rarely addressed the ‘why’ but it often addressed the ‘how’, repeating that the checks would be frictionless and only affect around the top 3% of players.
In an FAQ on the proposed checks the UKGC answered the following:
"Won’t these checks impact and cause inconvenience to a significant proportion of customers?"
"No, not at all and this is the key myth that we are hearing from various stakeholders. We have proposed a system of proportionate checks to target only the very highest spending customers where the impacts of any harm may be most severe... It's estimated that just the very highest spending 3 percent of accounts would undergo financial risk assessments."
With so much time spent reinforcing how frictionless these checks would be, it’s surprising how little time was spent explaining why they were brought into action in the first place.
Tax increase implications
The budget announcement dealt yet another blow to licensed operators, with an increase in remote gambling tax. From April 2026, the tax on profits will rise to an eye-watering 40%.
For licensed operators, higher tax bills don’t exist in isolation. They affect everything from bonuses and promotions to game variety, customer support, and ongoing platform investment.
While larger operators may be able to absorb these costs through scale, smaller and newer casinos will be far less able. The more profit margins shrink, the less added value can find its way to the customer. Fewer promotions, tighter terms, and less innovation risk making licensed sites feel less competitive. If illegal operators can pay no tax at all, it stands to reason that consumers might turn to them for better value than regulated sites.
Wagering requirement cap potential implications
A 10x wagering requirement cap seems a sensible decision. It’s intended to improve transparency and fairness, and for many players it will do exactly that. However, it may also have uneven effects at the smaller/newer end of the market.
For new casinos, being able to promise an attractive welcome bonus was a way of getting feet through the door. Higher wagering requirements have been one way to balance out overly generous bonuses. Removing that flexibility could force some operators to scale back or exit the market altogether.
If that happens, then we might start to experience a reduction in brand choice. We end up with a blander, more homogeneous regulated landscape. In that scenario, illegal sites that are unconstrained by bonus caps may appear more attractive, simply by offering variety and excess where licensed operators genuinely cannot.
What is the Gambling Commission doing about illegal gambling sites?
The UK Gambling Commission has made the illegal gambling market a growing focus of its work – and speeches! It clearly realises that unlicensed operators pose a threat to both regulated operators and customers too.
Since April 2024, the UKGC has ramped up the ‘disruption’ element of its plan. It has issued more than 3,000 cease-and-desist notices, referred hundreds of thousands of domain names to hosting providers, and had almost 290,000 URLs removed from search results, all reducing the visibility of unlicensed sites.
Alongside the slightly ‘whack-a-mole’ approach that’s being taken in the disruption phase, the Commission is also analysing consumer engagement trends. This helps it not only to identify the illegal sites, but also understand who is using them and why.
A key focus for the UKGC has been encouraging broader industry participation. In order to see real change, it’s been asking for payment providers, search engines, and licensing partners to do their part to make it harder for illegal operators to transact within the UK. It remains to be seen how effective this strategy will be.
Case study: What the Dutch are doing
Like the UK, the Dutch government has also acknowledged a sustained rise in illegal gambling. State Secretary for Justice and Security Arno Rutte described the trajectory of the black market as ‘worrying’ and confirmed plans to further empower the Kansspelautoriteit (KSA) to tackle unlicensed operators.
Current efforts focus on disrupting not just illegal casinos themselves, but the wider ecosystem that enables them, including payment providers, internet service providers and marketing partners. Websites promoting ‘casinos without Cruks’ are a particular target, with .nl domains potentially removable.
While there are limits to existing powers, new legislation is being prepared following the evaluation of the Remote Gambling Act. This bill should give the KSA greater authority to block illegal sites at scale, alongside longer-term prevention, education and enforcement measures at both national and European level.
Final words
Illegal gambling is not a problem unique to the UK. The Dutch are tackling it head on – in much the same way as the UKGC seem to want to go about it, just a couple of rungs further up the ladder.
Being as fast and flexible as the illegal gambling sector is going to be tough, but it’ll be essential if meaningful change is to happen. Listening to stakeholders and players alike, while taking decisive, cross-industry action will be the only way to gain ground in what’s set to be a lengthy battle.