Gambling Commission outlines black market dangers
A recent UK Gambling Commission (UKGC) report, published 18 September 2025, aims to lift the lid on the black market. This is the first instalment in a series of 4 reports intended to shed light on the illegal sector, and inform the Commission’s next moves.
This instalment, which focuses on consumer behaviours, motivations and personas, reveals 4 categories of illegal gamblers, and provides a sense of the scale of the problem.
Gambling Commission report key points
We’ve assessed the new report and summarised the main things to be gleaned.
4 categories of illegal gambler
Based on the self-reported data, the respondents (those who use illegal gambling platforms) fall into one or more of 4 distinct categories.
The report refers to the first group as ‘Self Excluders’. These are players who have subscribed to self-exclusion schemes like GAMSTOP, but who continue gambling anyway. As illegal sites don’t work with self-exclusion schemes, there’s nothing to stop these vulnerable, self-excluded players from taking to the black market.
Next up are the ‘Social Explorers’. These players are directed to illegal sites via social media influencers and adverts.
‘Accidental Tourists’ make up a surprisingly large number of illegal gamblers. These players are under the impression that the sites they’re using are legitimate. Many illegal casinos are hard to distinguish from their licensed counterparts.
The fourth group, dubbed ‘Skilled Advocates’, use these sites intentionally, and are aware they’re breaking the law. The main things that attract these players are certain promotions, the availability of different games and payment methods, and sometimes better odds.
UK not as bad as some
The current levels of illegal gambling in Britain are indeed concerning but still fall well short of the situation in places like Belgium or Germany. Governments and regulators in some countries have estimated that 50% or more of their gambling revenues are lost to the black market.
In Britain, the Betting and Gaming Council (BGC) estimates that 2.1% of gambling takes place on illegal sites. This may sound like a fairly insignificant portion at first, but it equates to £2.7 billion worth of stakes each year.
Why is illegal gambling on the rise?
There’s no doubt illegal gambling is increasingly popular, and the new data reveals a bit about exactly why players are taking to unlicensed platforms in such significant numbers.
For one thing, players can access these sites despite any restrictions, bans or exclusions that might prevent them from gambling on the regulated market. This includes the aforementioned Self-Excluders.
As these sites often don’t pay taxes, they can offer more competitive rates and odds than legal sites. This makes the legal market less attractive. Many players, including Skilled Advocates, use these sites for this reason, despite the risks.
Also, as unlicensed sites often don’t require ID, they appeal to those who prioritise anonymity. This is likely to overlap with criminal activities, perhaps including the laundering of funds.
A majority of players weren’t aware that they were gambling illegally. It’s not clear how or if this was verified, or if players were simply taken at their word. Regardless, it’s a lot of people and something the Gambling Commission needs to explore further. If legal and unlicensed sites look very similar to the average player what can be done to differentiate them?
The perils of the black market
There are lots of dangers when it comes to using the illegal market, and players have different relationships with these. Some are unaware. Some think that the risk is worth taking. And some seem simply not to care.
Black market sites don’t carry out the same stringent verification processes, and they aren’t subject to audits from regulators. There is often no way to verify the fairness of the games, and with some unlicensed or illegal operators there is no legal recourse whatsoever.
For players, the main dangers are being cheated, having funds withheld, compromising their personal data, and being taken advantage of. For industry more generally, a huge amount of tax revenues are already being lost, and if rising trends continue, this could escalate dramatically.
UKGC actions update
Alongside the new report and data, the UKGC published an update of its activities. This included a comment from CEO, Andrew Rhodes, who announced “a ten-fold increase in our disruption activity” since April 2024. This is undoubtedly positive, but a multi-faceted approach to tackling illegal operators will be needed.
Also, the Commission has launched a new Illegal Gambling Hub, where players can file anonymous reports and catch up on UKGC initiatives.
Pros and cons of the Commission’s position
The new report marks a significant step for the Commission, which some have accused of inactivity. Here’s a snapshot of what the report means for the regulator:
Pros:
- The extra disruption levels show that the Commission is fighting back.
- Respondents agreed that the industry should be regulated, justifying the UKGC.
- Some data suggests specific methods should be effective in combating illegal gambling.
- The data is robust enough to actually inform legislation-making.
Cons:
- Data is consistent with criticisms that over-regulation is likely to blame for the thriving black market.
- The fight cannot be fought with disruption alone.
- Many respondents have strong motives to continue using illegal platforms – not enough incentive to switch to regulated sites.
- UKGC may be tempted to continue its over-regulation crusade.
What does this mean for the industry?
There’s both good and bad news for the industry. The report shows that, while levels of illegal gambling are relatively low, there’s a lot of work to do. This must involve keeping the legal market competitive, relevant and viable, and this could be a challenge
The best outcome for the industry, from this data and the sets to follow, would be for the UKGC to take a look at some of its recent moves, and perhaps reconsider. The implementation of stake limits and financial checks on individuals have generated a largely negative response outside the corridors of the Gambling Commission.
What’s behind the exodus?
The data examines players’ motivations, revealing several reasons why black market sites appeal. However, there’s likely to be more to the motives of players that isn’t made explicit in the report…
The rise in illegal gambling is generally thought to be a reaction to the introduction of strict regulations intended to protect players – meaning it’s likely that the Commission itself is at least partially to blame for increased levels of illegal gambling.
One UKGC report from earlier this year found that 4.31% of gamblers had faced restrictions in the previous year. Perhaps some of the upcoming data will examine whether the Commission’s controversial background checks and stake limits have caused players to seek out new, less oppressive ways to enjoy gambling.
What’s happening elsewhere?
Elsewhere, the pattern has been similar, but more pronounced. In The Netherlands, an estimated 10% of players gamble illegally. The Dutch regulator, the KSA, aims to keep this figure below 20%, so they’re meeting targets. However, this number has risen since stricter regulations have been introduced.
In Germany, the situation is stark, with as many as 50% of players gambling illegally. In Belgium, immediately following an advertising ban, a sharp 6% increase was seen in the use of illegal sites.
It’s undeniable that there’s a correlation between the strictness of regulations and the popularity of illegal platforms.
Warnings heeded?
In addition to the warnings from other markets, discussed above, many UK media outlets spoke out against some of the Commission’s more heavy-handed legislative changes.
Some of the core issues highlighted by No Wagering, the Racing Post, Betting & Gaming Council and others include the introduction of stake limits, which met some resistance. Affordability checks also proved controversial, and many players rejected the idea before their introduction.
What does the future hold?
The UKGC has its work cut out, not just in tackling the illegal gambling problem, but in managing the growing sense of unease and disapproval within the industry. It has failed to heed obvious warnings, choosing to make the same costly errors as other regulators.
The Commission must keep stepping up the disruption, but complement this by collaborating with law enforcement. Disruption is equivalent to treating symptoms, rather than the true cause of the issue.
They might also consider ways to make illegal platforms less appealing to players – an area which seems underexplored at the moment. This would likely involve enabling legitimate sites to operate more competitively, and issuing some form of dissuasion or punishment for those who repeatedly and knowingly use illegal platforms.
One positive thing revealed in the data is that the majority of players appear to be unaware that they’re gambling illegally. This means that raising awareness and educating people, a relatively attainable goal, could prove to be effective.
Summary
Unfortunately, even if the UKGC slammed on the brakes and dialled back some of its more controversial regulations, things will continue to worsen for the near future. The trajectory isn’t great, but the faster the UKGC moves now, the more damage – to both the industry and players – can be mitigated.