UKGC study: illegal gambling beside licensed play

Britain's Gambling Commission has looked at real bank transactions to see how people use illegal gambling sites, and the study does not show a substantial shift away from the licensed market. The report, "Illegal gambling - Findings from an open banking data analysis", was published on 28 October 2026. The Commission says suspected illegal transactions "typically occur within broader patterns of on-going legal gambling activity".

How the study worked

The Commission bought an anonymised dataset of Open Banking transactions gathered by YouGov from about 38,000 people who consented to share their banking data for research, in return for a small incentive. It covers July 2018 to July 2026: 157.2 million transactions in total, 4.8 million of them with licensed non-lottery gambling companies. Licensed gambling payments were flagged by an algorithm built by Yaspa. Warwick Business School provided technical support.

Finding the illegal payments was harder. A first attempt, searching transaction descriptions for the names of known illegal operators, failed. The Commission's explanation is that illegal operators "rarely or never include their name" in the information they give payment providers. Exact matching on transaction descriptions and merchant names, using known examples, worked better: it found 3,426 suspected illegal-operator transactions made by 179 people. Their average age was 44, and 115 were men. The report names no illegal brands.

What it found

• Illegal play sits on top of licensed play. Among those with repeated suspected illegal transactions, 91% also used licensed operators. In the six months after their first suspected illegal payment, the licensed activity of the 122 people with at least two suspected illegal transactions did not drop substantially. The report says illegal gambling "is embedded within existing gambling behaviour rather than triggering a sustained shift away from the licensed market".
• Higher problem gambling scores. Survey scores on the Problem Gambling Severity Index (PGSI) were available for 146 of the 179. Of those, 45% scored 8 or more, the top band. The figure was 6% among the 12,543 people in the dataset with any licensed non-lottery gambling transaction. The Commission stresses this comparison holds only within this sample.
• Few credit cards. 4% of the suspected illegal transactions (138) were made on credit card accounts, by 15 of the 179 people (8%). The rest went through current accounts. Gambling with credit cards has been banned at licensed operators in Great Britain since 14 April 2020 (non-remote lotteries excepted).

In a blog post on the same day, Commission data scientist Steven Murphy said the analysis "may be the first time" a regulator or research team has done this anywhere. He wrote that the result is consistent with earlier Commission research suggesting illegal gambling is "usually supplementary to legal gambling" rather than a straight replacement.

What it does not show

The Commission lists the limits itself, and they matter:

• The dataset is not nationally representative. It slightly over-represents men and under-represents women, especially women over 55, and only includes people who were given a small incentive to share their data.
• It sees only bank payments from institutions that support Open Banking. Crypto payments, for example, are not captured.
• It can only spot operators already known to be illegal, so there may be a significant number of transactions with illegal operators in the data that are not identified.
• It cannot show that illegal sites cause harm, only that the two appear together in this group.
• It cannot estimate the size of the illegal market, either in absolute terms or relative to licensed gambling.

This study does not say how many players use illegal sites or whether that number is rising. It says that, for the people it could see, illegal play tends to be an extra rather than a move away from licensed sites, and that this group reports much higher problem gambling scores.

This is the latest piece in the Commission's research series on illegal online gambling, after an earlier report we covered on 23 October, on how "not on GamStop" searches lead people to illegal sites. The tax debate is covered in our Budget 2026 duty story.

For readers outside the UK: this is British data on British residents' bank accounts. The figures should not be read as applying to other markets.