UK Gambling Commission: Open Banking data shows illegal play supplements licensed gambling

The UK Gambling Commission has published a technical report that uses anonymised Open Banking transaction data to examine how consumers in Great Britain interact with illegal gambling operators. The study, released on 31 October 2026, found no notable decline in transactions with licensed gambling companies after individuals were first detected transacting with unlicensed operators, and it identified higher rates of moderate-risk and problem gambling among users of illegal services.

Method and dataset

The Gambling Commission used a large, anonymised dataset drawn from Open Banking to identify specific transactions between Great Britain residents' bank accounts and companies it classified as unlicensed. The regulator contrasted those transaction records with the same individuals' transactions with licensed operators and with survey results linked to the panel, including Problem Gambling Severity Index (PGSI) scores. The Commission framed this approach as enabling “direct observation of consumer behaviour in the illegal market” rather than relying on web-traffic estimates, online surveys or focus groups.

Findings on substitution versus supplementation

When the Commission analysed the average number of transactions with licensed companies in the months before and after it first detected an individual transacting with an unlicensed operator, it did not observe a notable drop in engagement with legal operators afterwards. The report states this pattern is consistent with earlier Consumer Voice research and with the conclusion that illegal gambling activity is usually supplementary to legal gambling rather than a direct substitution.

“When we look at the average numbers of transactions with licensed companies in the months before and after we first detect an individual transacting with an unlicensed operator, we do not see a notable drop in the levels of engagement with legal operators afterwards,” Postdoctoral Data Scientist Steven Murphy writes.

The report therefore challenges assumptions that consumers abandon licensed firms when they begin using unlicensed sites.

Harms and PGSI distribution

The Gambling Commission compared the distribution of PGSI categories for people who interact with illegal operators against the wider group for whom it only detects licensed gambling transactions. The regulator found that the relative sizes of the low-risk, moderate-risk and problem gambling categories were reversed when comparing the two groups, implying that people who use illegal operators are more likely to fall into the moderate-risk and problem gambling categories than those who only use licensed companies.

The study links transaction-level evidence with PGSI survey outcomes from the same panel to place gambling-related harm in the context of actual financial activity.

Caveats and limits

The report lists several caveats. The Commission notes there may be undetected transactions with unlicensed operators and that the dataset, while large, is not nationally representative. Those constraints narrow how far the findings can be generalised across the whole population of Great Britain.

The regulator nevertheless described the exercise as a “powerful proof of concept” for using financial transaction data to understand illegal gambling. Murphy wrote that the analysis “may be the first time such an analysis has been completed by any regulator or research team in the world.” The Commission said it will continue to expand its use of financial transaction data and is open to collaborations with stakeholders in the financial sector, including banks and payment providers, to improve understanding of illegal activity and related harms.

Organisational context and leadership

The publication comes while the Gambling Commission searches for a new chief executive following the departure of Andrew Rhodes. The former chief executive left in March to pursue a consultancy role with Hawkbridge; his departure was announced eight months ago. In the interim, Sarah Gardner has continued to lead the organisation as acting chief executive. Commission chair Ruth Evans issued the job description for the role, which lists responsibilities including leading the regulator’s workforce, working closely with the board and external stakeholders, and providing visible leadership on complex public policy issues.

What the Commission says next

Murphy emphasised the contribution the analysis makes to the Commission's evidence base and flagged planned next steps: expanding the use of financial transaction data and remaining open to external collaborations. The regulator stated the approach demonstrates the value of drawing on the broadest possible range of evidence to understand illegal gambling in Great Britain and elsewhere.

For readers looking for further regulatory context, the report links to the Commission’s broader methodological update on illegal market trends and its evidence strategy in the regulator's work on regulation. Coverage of the Commission's leadership vacancy and related governance detail appears in the Commission's public notices and in news. Researchers and industry stakeholders with an interest in data-driven studies that connect transactional patterns and harm metrics can find the technical appendices and classification methods summarised in the report and discussed in the Gambling Commission's outreach to banks and payment providers in its b2b engagement programme.