The UK Gambling Commission (UKGC) has published the last out of a part-four series on its approach towards the black market.
While comprehensive, the Yonder Consulting-conducted report did recognise some of the caveats that obstruct the exact estimate of the prominence of the online black market in the UK.
To understand the current trends better, the UKGC attempted to first build a profile of the typical black market player with part one of its study, published on 18 September.
With the agreement that it shouldn’t be treated as representative of all those who gamble online, the study outlined four typical characteristics of the users that engage with illegal gambling.
These are generally men, between the age of 18 and 24, who are active gamblers, and who usually rank eight or above on the PGSI problem gambling scale. They typically go to the black market to bet on football, for online bingo, or to play online fruit or slot games.
The motivation behind going out of their way to find illegal sites are most often better odds and offers, games unavailable elsewhere, access to alternative payments like crypto, no stake limits, and a low entry barrier – meaning weak ID or financial checks.
Still, the majority of responses painted illegal gambling as “supplementary rather than exclusive”, meaning people favoured more time and money spent on licensed websites.
Interestingly, however, this seemed to contradict another key highlight – the Commission established that players generally had low levels of awareness of the illegal iGaming market, with responses denying illegal play but indicating differently elsewhere, and vice versa.
Furthermore, only a minority of people was able to name specific black market operators – “numerous” responses named licensed providers as such. Almost all, however, responded that having a licence in the UK is important.
In conclusion, the first part of the Commission’s report found a “disconnect between perceived license importance, understanding if an operator is licensed, and knowledge of how to verify that”.
For the second part of its report, the regulator measured consumers’ rates of engagement with the online black market. Between May 2024 and July 2025, a total of 1,000 unique black market websites were identified, but “no overall increase in engagement in Great Britain”, the Commission stated.
Part three highlighted the three tactics that the gambling authority is utilising to hit the black market where it hurts the most. These are Regulation and Investigation (RI), Technological Advances (TA), and Marketing Strategy (MS).
RI includes legal and enforcement measures, such as cross-border collaboration with other institutions, tracking of illegal websites, blocking of such websites, and blocking payments to them, among others.
TA, meanwhile, focuses on eradicating the tools that black market operators are utilising to avoid scrutiny, such as indexing manipulation, VPN use, AI to evade detection, and URL concealment.
Lastly, MS deals with disrupting advertisers and affiliates based in the UK, enforcing advertising standards through the Advertising Standards Authority (ASA), as well as in-depth analysis of SEO marketing.
The latest and final chapter in this four-part study uncovers the three approaches that the UKGC is taking to estimate just how prominent the black market is.
Through the dwell-time approach, the regulator estimates average engagement and time-spent-on-site data – but it largely relies on assumptions, and each additional assumption adds additional margins for error, the UKGC recognised.
The channelisation approach involves comparing engagement rates with the legal and illegal market, but the caveat here is also the need for multiple assumptions.
With the third approach, the UKGC bets on survey-based data. However, this can also often lead to misrepresented assumptions.
All in all, the conclusion was that illegal online gambling is “clandestine” and its exact size often changes and almost always remains in the shadows, with participation rates diluted by a wide range of consumer behaviours.
Reflecting on the latest findings and painting the way forward, Ben Haden, UKGC Director of Research and Statistics, commented: “We have set out areas of work to focus upon. By breaking down the challenge into its constituent parts, it is possible to see a pathway to making an estimate that is fit for purpose.
“Getting there will also need input from operators – data on the legal market will help us strengthen assumptions and update our evidence base. We are looking forward to further conversations to clarify what we need and how operators can help.
“While the exercise of trying to understand the macro-metric of the size of the illegal market is important, the generation of trend data – and insight into specific websites to target disruption activity, is arguably even more vital. We are pleased we are now able to better understand these trends and supply key operational data to our Enforcement Team.”
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