Building the illegal market evidence base – starting with taking a consumer–driven approach
Our Director of Research and Statistics Ben Haden provides reflections on the implications of our consumer research into the online illegal market.
Posted 18 September 2025 by Ben Haden
Building an uncontested evidence base on a market which is legal, mature, historically well researched and with accessible datasets is a challenge. Building one for the illegal online gambling market, which is none of those things, is at another level. It makes the triangulation of evidence even more important.
Over the next two months we are going to publish reports and insight from different methodologies, including primary data we have collected.
These reports will provide insight from the gambling industry, from its supply chain and the experience of our international regulatory colleagues. They will explore the operational work we do to disrupt and make it difficult to provide illegal gambling at scale to consumers in Great Britain. However, it all begins with the experiences of consumers themselves and the digital footprints they leave behind, and what this tells us about the drivers and motivations that lead them to gamble with unlicensed operators who are transacting with them illegally.
In order to build our understanding, we conducted in depth research through our Consumer Voice research programme, working with Yonder Consulting. What our mix of qualitative and quantitative consumer research shows is a wide range of reasons as to why a consumer may engage with illegal websites.
At a headline level, we know that the majority of gambling consumers do not engage with illegal gambling websites. We also know that those that do are largely using illegal websites alongside their usual gambling with licensed operators, to supplement their primary gambling experiences. Participation in the illegal market tends to be higher among men, younger individuals (aged 18 to 24), consumers who gamble more frequently, and those who score 8 or more on the Problem Gambling Severity Index (PGSI).
It is perhaps not surprising, but nevertheless concerning, that much of the illegal operator activity in this space targets those who have excluded themselves from the legal market but are still seeking opportunities to gamble. Many of these consumers are at risk of, or may already be experiencing gambling harms, which can be exacerbated further by their engagement with illegal online gambling websites. The volume of advertising aimed at this group is significant and with over half a million consumers signed up to GAMSTOP, unfortunately there are many to be targeted.
There are also consumers who are using illegal websites for other reasons. Our research has shown that some consumers do knowingly and systematically engage with illegal websites – doing so because they want to gamble on new markets, with alternative currencies, or to explore new games.
Others are not aware that they are using an unlicensed website but use search engines or follow recommendations on social media and forums to find what they consider to be better odds or markets of interest to them.
We know from our previous research on consumer trust in gambling that consumers place a high degree of importance on regulation, and the need for gambling companies to be overseen by a regulator and held accountable for their conduct if it falls short of standards. The lack of regulation and consumer protection in the illegal market is therefore clearly a concern to us. A key next step is to drill into some of the drivers in more detail and see the extent to which they may lead consumers to overlook or disregard this principle. What influence does regulatory action have on consumers’ propensity to venture into less secure gambling spaces? How much of a role do industry-led actions, such as account restrictions, play? This will be the focus of our next phase of research.
Our research so far shows that the debate on approaches to disrupting the illegal market, and influencing and informing future consumer behaviour, needs to be nuanced and strategic – built on appreciation of mainstream trends of online usage, associated trust and consumer behaviours, as well as evolving gambling trends. Our ongoing work with consumers will also focus on understanding the relative size of the key audience groups that use illegal gambling websites, and how we appropriately target our resources as a result within our regulatory remit.
Our next report in this series will outline how we have used big data and analytics to add a further layer to the evidence base, by understanding trends in consumer engagement over time. Whilst this is a challenging task, there are several helpful observations that we can use to inform our ongoing research as well as wider regulation.
Finally, there is a legitimate question to understand what is genuinely lost from the legal market when consumers engage with illegal websites. Is the spend that is taking place in the illegal market – often from those who are self-excluded or could potentially be experiencing harm - spend that we, or the industry, would want to see back in the legal market? Our work to build a deeper understanding of consumer experiences will be an integral part of addressing this question.