UK Gambling Commission study (31 Oct 2026) finds illegal gambling is typically complementary

The UK Gambling Commission published on 31 October 2026 a technical report using anonymised Open Banking transaction data to analyse how Great Britain consumers interact with unlicensed gambling operators. The study compares detected payments to illegal operators with transactions at licensed companies and finds that, after the first detection of black‑market activity, there is no notable drop in activity with licensed operators; additionally, consumers detected in the illegal market show a greater presence in higher PGSI risk categories.

Methodology and scope of the analysis

The regulator used a large anonymised set of bank transactions from Great Britain derived from its Open Banking panel to identify payments to unlicensed gambling businesses. According to the report, this approach allows direct observation of consumers’ financial behaviour, in contrast to indirect estimates used in other research such as web‑traffic analysis, online surveys or focus groups.

The study links transactions to survey outcomes for the same sample, including Problem Gambling Severity Index (PGSI) scores. The UK Gambling Commission specifies that the dataset is not nationally representative and that some payments to unlicensed operators may not be detectable, which limits the scope of certain conclusions.

Main findings

The report compares the mean number of transactions with licensed firms in the months before and after the first detection of payments to unlicensed operators and does not identify a significant reduction in engagement with licensed operators following that initial detection. The regulator interprets these data as consistent with the idea that illegal activity is typically supplementary to licensed operators’ activity, rather than a direct substitution.

The distribution of PGSI categories for people who interact with illegal operators differs from that of those who transact only with licensed firms: the relative sizes of low risk, moderate risk and problem categories are effectively reversed compared with the population that shows only licensed transactions. The report notes that this suggests consumers using the illegal market may be at a higher risk of harm from gambling.

"When we look at the mean number 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 levels of engagement with licensed operators afterwards," writes Steven Murphy, Postdoctoral Data Scientist.

Limitations acknowledged by the regulator

The report includes several caveats: there may be payments to unlicensed operators that are not identifiable in the dataset; the dataset, while large, is not representative of the entire Great Britain population; and observing transactions does not replace qualitative methods for understanding individual motivations. The UK Gambling Commission takes these limitations into account when presenting its conclusions.

Institutional interpretation and next steps

The regulator describes the project as a "powerful proof of concept" for using transaction data to understand illegal gambling in Great Britain and beyond. Steven Murphy adds that deriving the analysis from an existing panel made it possible to link transactions to survey outcomes.

Murphy also states: "It represents a substantial contribution to our evidence base on illegal gambling that could not be achieved with any other source of evidence." The UK Gambling Commission indicates its intention to expand the use of transaction data and to remain open to collaboration with banks, payments providers and other organisations interested in safety and tackling crime in gambling.

Organisational context

The report is published while the Gambling Commission seeks a new chief executive following Andrew Rhodes’s departure from the regulator in March 2026 to join consultancy firm Hawkbridge. Sarah Gardner has continued as acting chief executive since then. The regulator’s chair, Ruth Evans, issued a job description that includes responsibility for the regulator’s workforce, relations with the board and external stakeholders, and visible leadership on complex public‑policy matters.

Frequently asked questions included in the report

The report answers key questions: What sets this study apart? It uses anonymised bank transaction data to observe interactions with illegal operators rather than indirect estimates. Does illegal gambling replace legal gambling? The analysis does not identify a significant drop in transactions with licensed operators after an initial detection of illegal activity. What findings on harm appear? People detected transacting with illegal operators show a higher share in PGSI moderate‑risk and problem categories.