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Illegal online gambling - Phase 1: Exploring consumer pathways into using illegal gambling websites

The Gambling Commission's report on the first phase of the Consumer Voice illegal gambling project.

Published: 18 September 2025

Last updated: 18 September 2025

This version was printed or saved on: 18 September 2025

Online version: https://www.gamblingcommission.gov.uk/report/illegal-online-gambling-phase-1-exploring-consumer-pathways-into-using

Introduction

This report presents the findings from a mixed methodology study conducted by Yonder Consulting in partnership with the Gambling Commission. The main objective of this developmental study was to enhance understanding of experiences of people who gamble and attitudes towards illegal gambling websites (Note: illegal gambling websites are websites held by gambling companies which offer their products to consumers in Great Britain without having obtained the necessary licence from the Gambling Commission to do so1).

More specifically, this research aimed to:

One of the Gambling Commission’s 3 Gambling Act licensing objectives is to prevent gambling from being a source of crime or disorder, being associated with crime or disorder, or being used to support crime. This includes the prevalence of gambling companies operating without a licence from the Commission. Through its Evidence Gaps and Priorities Programme, the Commission has identified a need to improve its knowledge of the extent and impact of the illegal market in Great Britain.

A core component of this need involves understanding why and how some consumers choose to engage with the online illegal market, that is, gambling websites. As this becomes better understood, it can feed into the Commission’s wider work on sizing the prevalence of the online illegal market in Great Britain.

This study forms only the first phase of research into this topic; subsequent phases will ultimately inform the development of questions for the Gambling Survey for Great Britain (GSGB), providing data to enable the Commission to track the prevalence of consumer engagement with the illegal market over time.

Alongside this research, the Commission is developing a data project to estimate the scale of the online illegal market. The model is used to identify illegal gambling websites and combine web traffic data with player behaviour data to estimate the amount of gross gambling yield generated from these websites. This model allows the Commission to track the direction of change in the online illegal market over time, and assess the direct impact of disruption, as well as any indirect effects that occur due to changes in policy on the licensed market.


1The ‘How to read this report’ section contains more detail of the terminology used.

Methodology

A multi-phased approach was used within this study. The following timeline presents an outline of the methodology used. Each stage is explained in detail in the following sections.

Timeline

  1. March 2024 - Scoping phase

    To inform the scope of the research, Yonder spoke to subject matter experts within the Gambling Commission to understand how the Commission conducts its enforcement activity and to build a better understanding of the online illegal market and its complexities. This included speaking to the Gambling Commission’s enforcement team and communications team, reviewing contact centre data and learning about the data project mentioned data project mentioned on the previous page. Yonder also spoke to members of the Gambling Commission’s Lived Experience Advisory Panel (LEAP) to inform development of research materials.

  2. 27 March 2024 - Initial qualitative phase

    Focus group with 11 members of LEAP to capture insights into the online illegal market and ways into it, and to test questionnaire content with this audience, to ensure a range of experiences and behaviours were covered.

  3. 17 to 22 April 2024 - Quantitative phase

    Online survey of 1,007 individuals who gamble online, with the aim of gathering information on potential indicators of illegal gambling and gaining consent for recontact. Respondents were asked key questions regarding their gambling activities, such as their GAMSTOP usage, and whether they believed their activity was with legal or illegal websites.

  4. June 2024 - Concluding qualitative phase (part 1)

    10 online depth interviews with respondents who completed the online survey, with the objective to delve into their pathway into illegal gambling, recounting: levels of awareness of engagement with illegal websites, the role of regulation, whether they do any research to vet these websites, their motivations for using these websites, and attitudes towards future use of illegal websites.

  5. July 2024 - Concluding qualitative phase (part 2)

    2 focus groups with a total of 7 individuals recruited from the Gambling Commission’s wider lived experience network, peer facilitated by members of LEAP, exploring experiences of using illegal gambling websites while registered to GAMSTOP.

Initial qualitative phase

At the start of the project, a 90-minute online focus group was conducted with 11 members of LEAP1. The aim of this stage was twofold.

  1. To capture insights into the illegal market and ways into it, how aware people who gamble might be that they are gambling on illegal websites and how they feel about this.
  2. Test questionnaire content with this audience to ensure it reflected their perceptions of the illegal gambling market in Great Britain, and to ensure the language used in the questionnaire was accessible and non-stigmatising. Respondents were sent the questionnaire ahead of the focus group to review, before feeding back on the content within the main discussion.

Members of this group were spoken to as a first step within the research because the Commission was aware that many of these individuals have direct experience of using the illegal market, and anticipated that it would likely be challenging to find a wider group of individuals with this experience, due to the perceived low prevalence of use of unlicensed illegal websites.

Quantitative phase

Yonder conducted an ad hoc online survey with a sample of 1,007 people who had gambled online at least once in the last four weeks, excluding those who only: gamble in person, play National Lottery draws, play scratch cards, or participate in private betting (that is, any combination of only these activities).

The rationale for excluding those who only play National Lottery was due to the nature of the survey content, which required some degree of understanding and engagement with typical online gambling activities such as betting, casino products, or bingo games.

Respondents were recruited to be broadly representative, using a quota-based sampling approach, with four key demographics tracked: age, gender, UK region and social grade, to match the known incidence of those who gamble as occurring in the general population using random stratified sampling frames2 .

This incidence was taken from the nationally representative ‘Cost of Living’ survey that Yonder carried out for the Commission. After fieldwork, weights were applied to the data to correct any imbalance that occurred in sampling, to exactly match the quotas. Fieldwork for the online survey took place between 17 and 22 April 2024.

The core purpose of the quantitative research was to inform the qualitative phase, by gathering information on awareness of, and potential indicators of engaging in, illegal gambling and gaining consent for recontact.

Concluding qualitative phase (part 1): depth interviews

10 respondents were recruited to take part in one-hour online depth interviews, which were conducted in June 2024. These respondents were recruited through recontacting a sub-set of individuals who took part in the quantitative survey.

Most respondents were recruited on the basis that they had either reported they had knowingly used or had suspected they had used illegal gambling websites. To this end, 8 indicators from the quantitative survey were used for recruitment purposes.

Of the behaviours we asked respondents about, the following 8 listed were determined to be less likely, or in some cases, not possible to be encountered by consumers when using legal gambling websites.

A spread of these indicators was recruited for across the sample – each of the 8 indicators are provided (in no particular order), alongside a reference to its corresponding question on the quantitative survey3 , and also a short explanation of why it was considered to be an indicator for the purpose of recruiting for the qualitative research stage.

  1. Used a gambling website where they did not need to provide ID or age verification upon sign up
    All legal online gambling businesses must ask individuals to prove their age and identity before they gamble, for more details, see requirements for Age, ID and financial verification on The Commission's website.

  2. Tried to access a gambling website they had used previously, but found that it had been taken down
    A core role of the Commission’s Enforcement team is to make it difficult for companies to provide illegal gambling at scale to customers in Great Britain. One way of achieving this is through conducting disruption activity, which can involve shutting down illegal gambling websites. For example, from April 2023 to March 2024, the Commission’s referrals to search engines resulted in 33,316 URLs and 126 websites being removed from search engines. For more information on this, see Activity to tackle unlicensed gambling and outcomes from The Commission's Impact Metrics.
    It is therefore plausible that a consumer discovering that a website they previously used has been taken down could be an indicator that it was an illegal website that was removed.

  3. I have a VPN, and I always use it when visiting gambling websites, specifically
    There are some gambling websites that are not licensed in Great Britain but are licensed in other countries. Consumers may not be able to access these websites as the website can identify that the consumers are located in Great Britain. It is possible that using a VPN specifically when accessing gambling websites could indicate that a consumer is intending to use websites that are not licensed in Great Britain.

  4. Paid to gamble using a credit card
    In Great Britain, paying to gamble using credit cards in has been banned since 2020, meaning that licensed gambling companies are not able to accept them as a payment method. For more details, see The Gambling Commission's news article on the ban.

  5. Gambled on a foreign website and/or one where they had to change the default currency or language
    Changing the payment option from a non-British Pound Sterling (GBP) currency (such as Euros) to GBP may indicate that the website has set its default language or currency to be that of its country of origin, that is, not Great Britain. This may indicate that the site, although possibly licensed in a country outside of Great Britain, is not licensed by the British Gambling Commission.

  6. Paid to gamble using foreign currency (that is, not GBP)
    Paying using a non-GBP currency (such as Euros) may indicate that the website and its core consumer base is located outside of Great Britain. This may indicate that the site, although possibly licensed in a country outside of Great Britain, is not licensed by the British Gambling Commission.

  7. Paid to gamble using cryptocurrency
    It is very unlikely that the Commission would grant licences to gambling companies that accept blockchain technology payments such as cryptocurrency from consumers, as these companies are not typically able to verify the source of their funding. Verifying a gambling company’s source of funds is a core component of reviewing a licence application, as the Commission must be assured that the company is not being funded by the proceeds of crime. Therefore, it is unlikely that a gambling website accepting cryptocurrency payments is licensed by the Commission. For more information, see the Commission’s guidance on Blockchain technology and crypto-assets.

  8. Paid to gamble using non-fungible tokens (NFTs)
    It is very unlikely that the Commission would grant licences to gambling companies that accept blockchain technology payments such as Non-Fungible Tokens (NFTs) from consumers, as these companies are not typically able to verify the source of their funding. Verifying a gambling company’s source of funds is a core component of reviewing a licence application, as the Commission must be assured that the company is not being funded by the proceeds of crime. Therefore, it is unlikely that a gambling website accepting NFT payments is licensed by the Commission. For more information, see the Commission’s guidance on Blockchain technology and crypto-assetts.

A spread of pathways into illegal gambling websites were also represented across the qualitative sample, including individuals who had found out about these websites via search engine, word of mouth, social media, gambling forums, paid advertising, and affiliate websites. Demographic profiles, Problem Gambling Severity Index (PGSI) scores, and context surrounding these respondents’ engagement in the 8 indicators and pathways into illegal websites can be found in Appendix C.

Respondents took part in a 30-minute online digital pre-task which captured details about themselves, their online gambling behaviours and preferences, and their levels of awareness and experiences of using illegal gambling websites.

Depth interviews were then conducted with these respondents to further delve into their pathway into illegal gambling, recounting levels of awareness of illegal websites, the role of regulation and whether they do any research or vetting of these websites, their positive and negative experiences, and attitudes towards future use4.

Concluding qualitative phase (part 2): focus groups

Two 90-minute focus groups were conducted online in July 2024, to understand experiences of using illegal gambling websites for those who have self-excluded from licensed gambling websites (that is, those who had used GAMSTOP in the past).

Unlike with the depth interviews, these focus groups took a peer-to-peer approach, meaning these sessions were facilitated by LEAP members. The LEAP facilitators were provided with a condensed discussion guide containing core objectives and a short list of questions for the session. They were thus less prescriptive than the depth interview sessions, which allowed the discussion to develop more organically. It also helped ensure that respondents felt at ease by being interviewed by someone they already knew, who could directly relate to their experiences5.

Respondents for these focus groups were recruited through the Gambling Commission’s wider lived experience network rather than recontacted from the quantitative survey. Respondents consisted of members of gambling support groups, who the LEAP facilitators were already connected with. This approach was taken primarily due to ethical considerations: Yonder and the Commission felt that in order to explore this sensitive topic appropriately, risk of harm to respondents needed to be minimised and therefore, a higher level of safeguarding protections needed to be available.

To participate, respondents were required to have gambled online and used an illegal gambling site 12 months ago or more, that is, within a recent enough period to recall experiences, but not so recent as to risk harm or distress during the focus groups.

During recruitment, potential respondents were provided with a list of the topics and questions that would be covered during the session. This was to ensure they had time to consider their levels of comfort in answering these questions beforehand.

Respondents met with their respective LEAP facilitators prior to, and after their sessions to receive additional peer support.

After the focus group session, respondents were provided with a support sheet, which contained prompts to encourage self-care, resources for confidential professional support services, and the contact details of the Commission’s Lived Experience Coordinator, who was present during the sessions and available for support both before and after.

The first focus group consisted of 4 respondents and was an all-female sample, ensuring coverage of a female perspective as this can be underrepresented in gambling research. The second group consisted of 3 male respondents.

Discussions revolved around online gambling activity (including preferred activities, providers, and pathways in) as well as experiences of using unlicensed gambling websites while registered to GAMSTOP.


1LEAP is a panel of individuals who have experienced gambling harm in the past. It provides advice, evidence and recommendations to the Commission to inform decision making and raise standards. More information on LEAP can be found on the Commission's governance committees and boards page.

2 See Appendix A for quota table.

3 See Appendix B for the quantitative survey.

4 The discussion guide used in these depth interviews is included in Appendix D.

5 The discussion guide used in these focus groups is included in Appendix E.

How to read this report

For the purposes of reporting, the narrative has been structured to largely focus on the consumer pathways uncovered by the qualitative phases, rather than exploring the quantitative data question by question. For more detailed insight into quantitative findings, please refer to the data tables which will be published at a later date.

The guidance set out in the following paragraphs is designed to help anyone who wishes to use data from this report to ensure it is interpreted and reported correctly.

Findings from this study can be used to:

This research consisted of an online self-reporting survey conducted by Yonder, which focused on a sub-sample of people who gamble online. This specific sample of people was chosen as it was determined that their insight and perceptions would be most relevant to the objectives of the study. Therefore, the views and experiences voiced by our sample may not be representative of either the general British population or the wider gambling community.

Therefore, findings from this study should not be used to:

Sample sizes used within the qualitative stages of the research are small by nature and represent the views of several sub-groups of those who gamble online, such as: self-excluded individuals and those who may use illegal websites. Therefore, insights from these stages should be taken as exploratory rather than conclusive. Quotes included from these stages serve to illustrate key points and should not be taken as representing the views of all respondents.

Terminology used

Specific terminology is used within this report, the definitions and the rationale behind them can be found in the following sections.

GAMSTOP: A free tool that allows people to self-exclude from all licensed gambling websites in Great Britain. More information can be found on the "About GAMSTOP" page on GAMSTOP website (opens in new tab) .

PGSI: Problem Gambling Severity Index, a screening tool which measures ‘problem gambling’, that is, gambling to a degree that compromises, disrupts, or damages family, personal or recreational pursuits. A PGSI score of 8 and over represents problem gambling by which a person will have experienced adverse consequences from gambling and may have lost control of their behaviour. A PGSI score of 3 to 7 represents moderate risk gambling. A PGSI score of 1 to represents low risk gambling. For more details on the PGSI, see the Commission’s report on Problem gambling screens.

Unlicensed gambling: Terminology used throughout this report to describe gambling websites and providers which are not licensed by the Gambling Commission1, for more details on the requirements for a gambling company to obtain a licence, see the Licence Conditions and Codes of Practice (LCCP).

During the scoping phase of the study, alternative terms that are commonly used within gambling research and lived experience communities were considered for use with consumers: primarily, ‘unlicensed’, ‘unregulated’, and ‘illegal’. However, desk research, stakeholder engagement, and conversations with those with lived experience led the Commission to the decision that ‘unlicensed’ was the most suitable term to be used when discussing this topic with consumers and those with lived experience.

Using the term ‘illegal gambling’ when speaking to individuals would be problematic for several reasons. The term ‘illegal’ can imply that the individuals engaging with unlicensed gambling websites are behaving unlawfully, when in fact, it is the gambling companies that are conducting illegal activities by not complying with the regulations in Great Britain. Building on this, engagement with Lived Experience Advisory Panel (LEAP) revealed that people who gamble may find the term ‘illegal gambling’ to be stigmatising, and subsequently be less inclined to be honest about their experiences with the illegal market if they have the misperception that they could be penalised for engaging with it.

For some, the term ‘unregulated gambling’ may be perceived to refer to gambling activities not being subject to certain laws or regulations, and that there is not a governing body responsible for ensuring the safety of consumers. An example of an ‘unregulated’ gambling activity would be non-commercial private betting between friends and family, as this activity is not regulated by the Commission or by any other governing body. Therefore, the term ‘unregulated’ does not provide enough clarity for consumers; not all unregulated gambling activities in Great Britain are considered to be ‘unlicensed’ or ‘illegal’ by the Commission or by other bodies.

For reporting purposes, the term ‘illegal gambling’, however provides a clearer definition: gambling companies that offer their products to consumers in Great Britain without having obtained the necessary licence from the Gambling Commission to do so.

Limitations

While Yonder took care to ensure the robustness of the findings through the research design and application, there are a number of limitations which should be considered when reading this report.

All insights gathered from this study are based on self-reported behaviour rather than observed behaviour, meaning insight is limited to what respondents felt comfortable revealing to us in the research setting.

Furthermore, as respondents could struggle to identify whether they had in fact used a licensed or unlicensed website, this can impact the accuracy of their recall. For self-excluded individuals (registered to GAMSTOP), all had previously used these websites over 12 months prior to the research, which could also impact the accuracy of recalled behaviours and experiences.

Quantitative

The questionnaire was designed to inform the qualitative phase by gathering information on awareness and potential indicators of engaging in illegal gambling among those who gamble online. As a result, a range of potential indicators of illegal gambling were included. These are not definitive indications that someone has used an illegal website. In fact, some potential indicators included have more potential to occur both when using licensed and illegal websites – for example, difficulties with withdrawing winnings can also occur when using licensed websites.

However, the questionnaire was designed in this exploratory way to provide a wealth of sample information – including less conclusive occurrences such as withdrawal issues, and the eight potential indicators for the qualitative phase, which Yonder used to provide the Commission with more depth of understanding on the pathways into illegal gambling, and the potential pull and/or push factors. Yonder defined a set of eight potential indicators of unlicensed gambling (for example, paying to gamble on a website using a credit card) that are less likely, or in some cases, not possible to occur on licensed websites. This helped inform recruitment criteria to ensure the subsequent qualitative phase spoke to those using unlicensed websites.

This approach did mean, however, that landing on an incidence rate for illegal gambling was not within the scope of this research. This may serve as a potential area of focus for upcoming research with the Commission, now that the qualitative phase has provided the sufficient depth of understanding into this element of the sector.

General limitations of quantitative research: results provide a snapshot of attitudes and opinions but provide little insight into why respondents feel the way they do, and the specific drivers behind responses. Hence, the overall research design including a qualitative element to allow deeper insight into the ‘why’ behind respondents’ responses. Further, respondents were provided with pre-coded lists of responses which may not have captured the full range of responses that exist. To mitigate against this, open-ended responses were also included to allow respondents to provide more detail on the reasons for their responses.

Qualitative

Qualitative sample sizes are by their nature small, so conclusions can only be directional, unless contextualised by quantitative data. For example, depth interviews were conducted largely with individuals who have recently used illegal websites. As a result, they may be more likely to have positive perceptions and experiences of these websites compared to those who previously used them, but don’t currently. Therefore, their opinions should not be taken to be representative of those who gamble online as a population.

Qualitative research heavily relies on the skills and experience of researchers, which can introduce potential researcher bias. This is mitigated by employing a grounded theory approach, using excel grids to capture qualitative data and notes and developing narratives through rigorous analysis of this data.

A next step within a further phase of research into this topic will be to further contextualise the qualitative findings, with further quantitative validation.


1Within this definition of illegal websites, there remains the possibility that some of these websites may be licensed elsewhere, that is, in other markets outside of Great Britain.

Executive summary

Overall, our research has shown how individuals who gamble can struggle to accurately recognise use of illegal online gambling, that risks tend to be known but can be mitigated by their own due diligence (often through social channels), and how experiences range from negative to positive to ambivalence.

Awareness of engagement

Whilst 5 percent of 1,007 respondents reported that they use both licensed and illegal websites, and 6 percent reported that they used to use illegal websites, but don’t currently, the qualitative research indicates that people who gamble struggle to accurately assimilate their experience. Some individuals believed they had never used illegal websites, only to later discover they had, and vice versa. Additionally, if a site appears credible and trustworthy, individuals are often less likely to question its licensing status and might require prompting to understand they have gambled on an illegal website.

Despite our efforts to identify various potential indicators of illegal gambling, few can categorically be counted on as definitive. Furthermore, more reliable indicators such as websites not requiring ID verification and accepting credit cards, might not be recognised by individuals who gamble as a proxy for illegal activity.

Accordingly, the next phase of research will be used to gauge the depth and nature of illegal gambling activity with greater precision.

Motivations and risks

A range of factors were seen as incentives for using illegal platforms. Common motivations (cited both within the quantitative survey and qualitative interviews) include, but are not limited to: better odds, providing games that are unavailable in Great Britain, and lower barriers to entry - such as minimal age or ID verification and alleged lower deposit limits.

Some users described being drawn to the challenge of engaging with foreign and digital currencies, enabling them to build their skillset within this area. Some appear to view this as a separate gambling avenue that allows them to distance themselves from their primary accounts although follow up research is required to corroborate this with more factual (rather than claimed) evidence.

This is not to say that gambling on illegal websites does not carry risks, including the potential for non-payment of winnings. But here, some illegal site users recounted managing the risks by consulting others and obtaining recommendations, and through placing smaller bets. That being said, besides clear indications from Self-Excluders, the amount of funds that people deposit into illegal websites is unknown, and therefore the potential for harm has yet to be fully understood.

Pathways into the market

The pathways into illegal gambling heavily rely on social networking, with word of mouth (33 percent), social media personalities (29 percent) and gambling forums (29 percent) presenting common pathways within the survey data. Social networks can be perceived to legitimize illegal websites, particularly when users can vouch for their reliability based on their past experiences. Word of mouth and forums indeed foster reciprocal exchanges of information.

Search engines also serve as crucial discovery tools for those who are not part of social networks, often being the first place individuals look for better odds or a wider variety of websites. For Self-Excluders, search engines become a resource for finding gambling companies not registered to GAMSTOP.

Once individuals enter this realm, advertising and social media play significant roles, akin to the licensed market. The credibility of social media influencers can be ambiguous; they can raise awareness, but some of their profiles may be viewed with scepticism, with some individuals being wary of fake accounts. Overall, the social dimension - whether through forums, word of mouth, or advertising – appears to play a significant role in driving awareness and directing users toward illegal gambling, much like it does for licensed platforms.

Audience insight

During this project, we identified various drivers and barriers associated with illegal websites, as well as strategies individuals use to mitigate risks. The influence of social factors was particularly notable. We gained insights into the illegal audience, ranging from individuals with negative perceptions of the market to those who were more open-minded, and encompassing those expressing complete surprise at their own participation in illegal gambling.

One of the most intriguing insights came from observing different attitudes toward the illegal market. Self-Excluders who had engaged with illegal gambling expressed negative views, citing the market's predatory nature. In contrast, other users provided mixed feedback: some reported issues with payouts, while others highlighted positive aspects, such as a diverse range of games and the ability to use multiple currencies. This led us to identify four user profiles1:

We intend to gather more evidence in subsequent research phases to further understand the relationship between licensed and illegal activity, and accordingly better understand the range of attitudes we discovered.


1 Note, these audiences reflect attitudinal and behavioural leanings and have been drawn out of qualitative research. They have not been subject to any quantitative segmentation so remain directional.

Main findings

Awareness of illegal online website usage

In the quantitative survey, respondents were provided with a simplified version of the Gambling Commission’s criteria for licensing a gambling website1:

When prompted with this explanation, a total of 81 percent of the 1,007 respondents reported that they currently only gamble with licensed websites: 73 percent reported that they only use licensed websites, and 8 percent reported that they only used licensed websites, but would not rule out using illegal websites in the future, as shown in Figure 1.

4 percent of respondents reported that they only gamble with unlicensed websites; 5 percent reported that they use both licensed and unlicensed websites; and 6 percent reported that they used to use unlicensed websites, but no longer do. 4 percent of respondents selected ‘prefer not to say’.

Figure 1: Whether respondents had used unlicensed websites, based on the explanation provided about licensing requirements in the quantitative survey

Whether respondents had used unlicensed websites, based on the explanation provided about licensing requirements in question 8 of the quantitative survey.
Response Percentage
Prefer not to say 4%
I only ever gamble on websites that I know are licensed 73%
I have never gambled using unlicensed websites before, but would not rule it out in future 8%
I have previously gambled using unlicensed websites but don’t anymore 6%
I gamble using both licensed and unlicensed websites 5%
I gamble using both licensed and unlicensed websites 4%

Note. As previously mentioned, consumers were asked about ‘licensed’ and ‘unlicensed’ websites, rather than using the term ‘illegal’.

Base size: 1,007 respondents

Respondents who indicated that they have used illegal websites were asked to list the names of the websites they had used; some of the websites listed (6 out of 36) were in fact licensed by the Commission. This indicates that it can be difficult for consumers to identify the difference between a licensed and illegal website. Similarly, in the qualitative interviews, there were examples of people who gamble often only realising they have used an illegaly site when something goes wrong.

“I only thought twice about whether the site was licensed when it took a while for them to pay out. I’ve just gone to have another look at the site now and have seen it’s been taken down.”
Female, aged 35 to 44, Problem Gambling Severity Index Score (PGSI) 24


1This does not cover the complexity or entirety of the Commission’s licensing assessment process; however, to ensure clear comprehension for respondents, the requirements were simplified in the survey question text. For exact wording of the Commission’s licence conditions, see the [/licensees-and-businesses/lccp](Licence Conditions and Codes of Practice (LCCP)).

Potential indicators of illegal gambling activity

The most common reported potential indicators of illegal site usage selected by the 1,007 respondents were:

The full breadth of experiences, including more indirect potential indicators of illegal gambling than some of those detailed above (such as ‘using a glitchy website’, which could be the case for licensed websites) - are shown in Table 2. All other potential indicators, which were presented to respondents in different survey questions, are included in Tables 3 and 4.

Table 2: Also in the last 12 months, how often have you…?

Also in the last 12 months, how often have you…? (Question 3 in the quantitative survey)
Response options NET: Experienced any time in the last 12 months
(percentage)
PGSI 8 and over NET: Experienced at any time
(percentage)
Used a gambling website that was glitchy or crashed frequently 24% 63%
Gambled on a website I had not previously heard of 23% 73%
Experienced difficulty withdrawing my funds from a gambling website without any clear explanation 20% 66%
Used a gambling website where I did not need to provide ID or age verification upon sign up 20% 63%
Attempted to contact a gambling website but did not receive any acknowledgement or response 19% 66%
Gambled on a website that I knew didn't offer deposit limits or self-exclusion or other safer gambling tools 18% 69%
Tried to access a gambling website I have used previously, but found that it had been taken down 17% 63%
Gambled on foreign site and/or one where I had to change the default currency or language 13% 58%
Gambled using a Virtual Private Network (VPN) in order to bypass gambling blocking software 12% 54%
Gambled on a website that I suspected or knew was unlicensed 9% 51%

Base: All 1,007 respondents, Problem Gambling Severity Index score (PGSI) 8 and over: 149 respondents

Table 3. In the last 12 months, have you paid to gamble on a gambling website using...

In the last 12 months, have you paid to gamble on a gambling website using... (Question 4 in the quantitative survey)
Response options NET: Experienced any time in the last 12 months
(percentage)
PGSI 8 and over NET: Experienced at any time
(percentage)
Cryptocurrency (such as, Bitcoin) 6% 23%
Foreign currency (that is, not GBP) 4% 15%
Virtual assets such as NFTs 3% 9%
A credit card 15% 42%

Base: All 1,007 respondents, PGSI 8 and over: 149 respondents

Table 4. Thinking of the last 12 months, and your personal device(s), which of the following statements best applies to you?

Thinking of the last 12 months, and your personal device(s), which of the following statements best applies to you? (Question 7 in the quantitative survey)
Response options NET: Experienced any time in the last 12 months
(percentage)
PGSI 8 and over NET: Experienced at any time
(percentage)
I have a VPN, and I always use it when visiting gambling websites, specifically 5% 22%

Base: All 1,007 respondents, PGSI 8 and over: 149 respondents

All indicators were considerably higher among those with a Problem Gambling Severity Index (PGSI) score of 8 or more (149 respondents), as shown by in Tables 2, 3, and 4. Over half (51 percent) of the PGSI 8 and above group thought they had gambled on a site they knew or suspected was unlicensed, prior to being prompted by a brief explanation of what unlicensed gambling website is.

Reasons for using illegal gambling websites

Among respondents that indicated that they have previously used, currently use, or are open to starting to use illegal websites (179 respondents), the most commonly selected motivations were1:

Those that had previously used, or currently use illegal websites (97 respondents) were more likely to be motivated by better sign-up or bonus offers (50 percent compared to 39 percent of the sample referenced above) and playing or betting on products not offered by licensed websites (34 percent versus 26 percent of the sample referenced above).

The qualitative interviews mirrored this: low-risk entry points, attractive offers and alleged minimal deposit thresholds were key motivators for participation. In addition to this, individuals recounted they were able to enjoy a broader range of bet types and games, which enhances their experience compared to the licensed market.

“I suppose I’m a bit concerned that they’ll keep my money but if the offers good enough what the hell … I mean gambling’s risky anyway.”
Male, aged 25 to 34, PGSI 16.

“It’s just something different. More types of games and characters. It stops you from getting bored.”
Male, aged 25 to 34, PGSI 18.

Stricter rules could play a potential role in pushing individuals towards the illegal market: among those who don’t currently use illegal websites but would be open to using them in the future (82 respondents), 26 percent said that stricter rules for gambling companies requiring players to give more information (such as bank statements) could lead them to use an illegal website. From the qualitative interviews, this did not appear to be something respondents actively consider when deciding to gamble2.


1 Respondents were presented with a list of possible motivations, and from this list, were able to select all that applied.

2Albeit, this may not be true of all individuals who use these websites, as only a small sample of respondents were spoken to.

Pathways into illegal gambling websites

Amongst those who report having ever gambled on illegal websites (127 respondents), illegal websites were discovered via a variety of sources; most commonly, they were found via search engines (35 percent) or word of mouth (33 percent), as shown in Table 5.

Table 5. You indicated that you either currently, or have previously, gambled using unlicensed websites. How did you find out about these websites?

Dates and amounts
Source Percentage
Search engine 35%
Word of mouth 33%
Social media personality 29%
Gambling forum 28%
Paid advertising on social media 24%
Affiliate websites 20%

Base: 127 respondents who report having ever gambled using unlicensed websites.

How trustworthy these sources are considered to be, and the extent to which they are used, depends on the type of audience at-hand. This will be explained in subsequent sections of this report.

Illegal audiences

We have identified 4 key audience types who engage with this market1 .

At the outset of the qualitative depth interview phase, Yonder recruited respondents on the basis of their having experienced a range of potential indicators and pathways into the online illegal market, in addition to recruiting for a range of audiences, including:

However, upon interviewing these individuals it became clear that what distinguished them was their attitudes and motivations towards using illegal websites and the stories they had to tell. Our reporting has been directly informed by this, and this is why we have chosen to publish the insights through the lens of the four different key audience types that emerged.

  1. Self-Excluders: those who have chosen to self-exclude from all GB-licensed gambling websites by registering with GAMSTOP and who use illegal websites as a way to circumvent this self-exclusion.
  2. Skilled Advocates: committed users of illegal gambling websites who deliberately seek them out for recreational enjoyment and reward.
  3. Social Explorers: those for which gambling is a social activity; they are adventurous in seeking out new websites to recommend to others, and can as a result, unintentionally come across illegal gambling websites.
  4. Accidental Tourists: those who chance upon illegal websites inadvertently, when seeking better odds or through advertising when pursuing wider interests online.

Within subsequent chapters of this report, we will delve into the above audiences in more detail, covering the following for each:


1 Note, these audiences reflect attitudinal and behavioural leanings and have been drawn out of qualitative research. They have not been subject to any quantitative segmentation so remain directional.

2 See Appendix C for more details.

Self-excluders

This section explores the Self-Excluder audience in more depth, covering their reasons for using illegal gambling websites, pathways into illegal websites and wider attitudes towards these websites and regulation.

Reasons for using illegal websites

From the quantitative survey, just under a tenth (9 percent) of those who gamble online (1,007 respondents) had previously signed up to GAMSTOP – 5 percent within the past 12 months, with a further 4 percent having done so less recently than that. Expectedly, this was much higher among those with a Problem Gambling Severity Index (PGSI) score of 8 or more (38 percent).

The qualitative LEAP-facilitated focus groups found that respondents who had self-excluded often continued to gamble. For this group, the ability to access any gambling website whilst being self-excluded is the primary motivator. However, the ability to use credit cards or PayPal with these websites may also add to the appeal, as this enables them to access funds quickly, particularly if they have restricted access to funds (for example, if they have bank gambling blocks1 in place).

“I would just be looking for someone who would take my money right now.”

Male, Self-Excluder

Pathways into illegal websites

The main pathway into illegal websites is through the use of search engines, with individuals searching for websites that aren’t registered with GAMSTOP.

“I googled ‘gambling sites not on GAMSTOP’ and found them that way. At the time, I didn’t think about whether they were licensed or not, I just wanted to find someone I could gamble with.”

Female, Self-Excluder

However, this group also report receiving large quantities of direct marketing and targeted advertising on social media. These advertisements can incite this group to continue to gamble, as they report that they tended to act impulsively with less consideration. Some respondents recount illegal gambling companies making direct phone calls to encourage them to gamble.

“I’ve changed my phone number so many times but somehow, they still manage to get hold of me. It (gambling advertising) never stops.”

Female, Self-Excluder

This group report managing risks such as losing deposits or having difficulties in cashing out by conducting their own research into the illegal websites they used, but also recounted that the compulsion to gamble often outweighed the risks. Consequently, there is inconsistent evidence of due diligence being conducted prior to gambling.

Attitudes towards illegal websites and regulation

Self-Excluders tend to be more knowledgeable of the gambling sector than other groups. Some may know the difference between a licensed and an illegal website and have knowledge of who the Gambling Commission are and their role. However, the compulsion to play and need to subvert self-exclusion often means the risks of using an illegal website and licensing practices are rarely considered at the time of play.

However, when considering their interactions with illegal websites in hindsight, Self-Excluders are highly critical of this market, describing it as predatory. This sentiment appears to be fuelled by advertising and spam received, as well as their personal experiences with gambling.

“They advertise themselves as ‘not on GAMSTOP’ in the subject header. They are deliberately targeting people who have self-excluded.”

Male, Self-Excluder

“When they contacted me, it made me so angry. It was like someone had reached into my new life with something so intrusive.”

Female, Self-Excluder

Case study

Harriet, Aged 50, PGSI 16, Self-Excluder

Harriet first got into gambling when her boss recommended she try Virgin Games to play Bingo; she said they could chat on there and interact with other users as a fun pastime. She won a few times, and this prompted her to start doing wider casino gambling. She gambled for years, losing money, and borrowing money through credit cards. Her daughter helped her realise she had a problem and helped register her on GAMSTOP and her sister took control of her bank accounts temporarily.

Triggers
She wanted to find websites which would allow her to gamble while using GAMSTOP. She had 2 months remaining on her GAMSTOP ban but wanted to gamble there and then.

“I didn’t care who I was gambling with, I just wanted somewhere where I could play slots.”

Pathway
Harriet Google searched ‘sites which you can use while on GAMSTOP’ and clicked the first links which came up in the search results at the time. Once she’d done that, she started receiving emails from websites advertising themselves as not on GAMSTOP, which she used.

“I just googled sites which let you gamble with GAMSTOP and loads came up.”

Experience
Sometimes the websites worked but she also had experiences of:

  • glitchy websites kicking her out mid-play
  • winnings being miscalculated and changing mid-play
  • difficulty withdrawing money.

“It got to the point where I was taking screenshots of my winnings to prove they were right.”

Outlook
These websites make her feel angry – she doesn’t trust them and feels like they take advantage of people who self-exclude. She’s tried changing numbers and email addresses several times but still gets bombarded with marketing and calls, which frustrates her.

“They just won’t let you go. They call me and I don’t want to speak to them. It’s stressful and I know they’ll use techniques to try and bring me back.”

Names and identifying information have been changed.


1Individuals can block their bank account or debit card, which stops the account from being used for gambling transactions. For more details, see The Commission's guidance on blocking gambling payments with your bank.

Skilled Advocates

This section explores the Skilled Advocate audience in more depth, covering their reasons for using illegal gambling websites, pathways into illegal websites and wider attitudes towards these websites and regulation.

Reasons for using illegal websites

This group enjoy the variety of games and types of bets on offer, for example: new game types, new characters or languages being displayed, better odds, and free bets. This enhances their overall gambling experience.

“If I know I can find a platform with better odds, I’ll go for it. I often use free bets first and then my own money. I have several different accounts because you get daily free bets by regularly playing.”

Female, aged 25 to 34, PGSI 9

Navigating the illegal market also confers a sense of expertise, with this group enjoying employing their skills and seeking opportunities to improve their margin of success. This can feel personally rewarding to them.

“If you know how to use them and place sensible bets, these sites can be really fun to use.”

Male, aged 25 to 34, PGSI 22

This group report illegal websites having lower deposit and withdrawal thresholds, along with lower stakes. They therefore report being able to invest lower amounts when using these websites, which can create a perceived lower risk of loss.

The ability to use foreign or digital currencies can also mask the amount staked and can therefore be mentally disassociated from players’ main gambling expenses, as these currencies tend to be managed separately to mainstream currency (GBP) used for gambling on licensed websites.

Additionally, the ability to use these alternative currencies provides an opportunity to learn something new and potentially grow money through favourable exchange rates, making the use of these currencies a positive aspect rather than a drawback for some. Interestingly, this group includes self-proclaimed ‘side-hustlers’ looking for multiple ways to make money - a trend less common among those that were less aware they were gambling in the illegal market.

“I like looking at crypto. It’s something I feel I know well, and it feels good when the amount I have grows.”

Female, aged 25 to 34, PGSI 9

In private or open communities, such as WhatsApp, Facebook, Telegram, and Reddit, Skilled Advocates actively share knowledge and discuss where to find the best odds. Conversations about illegal websites are common and serve to help this group improve their skillset while bringing a sense of pride from being part of an exclusive club, as well as increasing social bonding and improving their status within the group.

“I’ve met friends through Telegram and become quite close with some, even meeting up at Wetherspoons.”

Male, aged 25 to 34, PGSI 22

“You learn more about these sites from others. We show each other which sites we’re using and primarily learn from each other on Telegram.”

Male, aged 25 to 34, PGSI 22

A streamlined sign-up process (for example, requiring only an email address instead of an ID verification process) further encourages play. It also helps mitigate perceived risks of encountering difficulties with withdrawal, where there can be a perception of licensed gambling companies deliberately asking for ID to create delays.

Some individuals have experienced not being able to withdraw winnings, but this appears to be something that this group feel able to manage by betting with lower stakes and by doing research prior to using these websites. Even among this engaged group, illegal gambling is primarily peripheral to their main gambling activity, which happens on licensed websites.

Pathways into illegal websites

Public platforms like Reddit and X (formerly Twitter) are particularly popular for obtaining recommendations from other users of the online illegal market and tend to be this group’s first port of call. These are used for increasing knowledge, staying informed, and vetting illegal websites for trustworthiness.

“I like to follow the conversation and see what people are recommending on Reddit. You never know what new thing someone might find to try.”

Male, aged 25 to 34, PGSI 18

“Affiliate sites often pop up with colourful games offering deals like deposit £5 and get £30. I think Reddit gets paid for promoting these. On Reddit gambling forums, you see pop-ups of these offers.”

Female, aged 25 to 34, PGSI 9

Search engines also remain popular among this group: even if someone recommends a website, Skilled Advocates will often use Google to confirm details or to find the best odds.

Social media influencers also play a role here, albeit a limited one, compared to search engines and word of mouth. The term ‘social media influencer’ broadly encompasses prominent consumers in gambling forums, word-of-mouth communities, YouTube personalities, and podcasters. These influencers may be viewed with caution, especially in gambling forums where players are wary of fake profiles and testimonials.

“With social media it’s hard to tell who’s a scammer. If it sounds too good to be true, I steer away”

Female, aged 25 to 34, PGSI 9

Paid advertising on social media is also a pathway into the market among this group. Similarly to Self-Excluders, they report receiving large amounts of spam and offers. However, players are wary of these communication tactics, and some even provide fake email addresses to manage the influx of communications.

Proceeding with caution, these individuals are conscious of the risks of using unlicensed websites and claim to take steps to protect themselves: appearing to invest smaller, controlled amounts and looking for unlicensed websites which are known for their reliability (that is, their willingness to pay out and the speed with which they do this).

Attitudes towards unlicensed websites and regulation

Skilled Advocates are often aware of the difference between a licensed and illegal website and the risks that using illegal websites pose. However, they feel these risks are reduced by:

“As long as it has good offers or odds and I get paid, that’s the main thing. Some of them have funny names or are a bit basic but I don’t mind.”

Male, aged 25 to 34, PGSI 18

Overall, this audience tend to perceive the unlicensed market in a more positive light than other users, appreciating the combination of enjoyable gameplay, perceived lower deposit and withdrawal thresholds, and the skill required to use digital currencies.

“Unlicensed sites often have amazing pay-out withdrawal processes with low thresholds. They may not look as professional as the big players, with less text or not perfectly formatted, but that doesn’t bother me because other features are fine.”

Male, aged 25 to 34, PGSI 2

Case study

Fatima, Aged 30, PGSI 9, Skilled Advocates

Fatima has multiple income streams: including beauty treatments, language tutoring and administration. She is a sports betting enthusiast, especially cricket. She consistently checks Oddschecker for the best odds. She describes how she has a ‘strategic’ approach to sports betting and experiences some success – she claims to have been banned from Bet 365 because of big wins. She ‘invests’ in digital currencies and has several crypto-wallets believing this is also a way of making money.

Triggers
She has had unsatisfactory experiences with licensed gambling companies. She experiences boredom with the range of games and types of bets, especially for sports betting and has a fascination and growing interest in digital currencies.

“I like to invest in crypto and virtual assets but with licensed sites it’s not a thing yet”

Pathway
She heard about a greater number of (unique) games being available with unlicensed providers from a social media group. She used Reddit and X forums to identify the most reliable websites (that is, those known for paying out).

“I asked in a forum for the top 5 most reliable sites to pay out and experimented with one of them”

Experience
She has had a positive experience of play with these providers and pay-out. She remains analytical in her approach and wary of social media influencers with fake profiles who promote accounts.

“The site I initially experimented with cashed out.”

“With unlicensed sites you get a lot of spins for a small amount with bitcoin”

“With social media it’s hard to tell who’s a scammer. If it sounds too good to be true I steer away”

Outlook
She sees unlicensed websites as increasing the opportunity to make money and enhance enjoyment. She is aware of the risks of using these providers but feels they exist with licensed gambling companies too

“I’ve used unlicensed sites where I’ve made money and haven’t been paid out but I’ve had similar experiences with licensed sites too”

Names and identifying information have been changed

Social Explorers

This section explores the Social Explorer audience in more depth, covering their reasons for using illegal gambling websites, pathways into illegal websites and wider attitudes towards these websites and regulation.

Reasons for using illegal websites

For Social Explorers, building social bonds and reciprocity is a key motivator for exploring gambling websites more widely. They are often part of family or friendship groups for whom gambling is a shared interest and will trial new companies with the aim of finding interesting games with compelling odds, which the whole group can enjoy.

Sharing experiences can also enhance and prolong the sense of enjoyment gained from gambling. This group do not actively consider whether companies are licensed or not and often stumble across unlicensed companies due to their appetite for exploring new websites.

However, when trialling new companies they do exercise some caution, typically spending lower amounts as they are aware there is no guarantee of pay-out. There is also a sense of trial and error: for most, a bad experience or loss is an acceptable consequence, and is seen as part of the nature of gambling (that is, that there are no guarantees).

“We’ll test drive a site if we’re not sure about it, by betting smaller amounts. Then I’ll report back to my friends about it.”

Male, aged 45 to 54

Pathways into illegal websites

Typically, these are individuals who have active groups of friends or family who also gamble and like to share information, such as where better odds can be found. Recommendations from friends and family are generally considered the most trustworthy, and individuals typically do not make recommendations until they’ve tried and tested the websites themselves.

"I chat to my friends on WhatsApp about the sites I use. If they’ve recommended a site to me, I like to do the same for them. I know they’ll have tried the site before telling me about it and I’ll do the same.”

Male, aged 35 to 44 years, PGSI 5

“It was a fun habit I got into with friends during COVID and then I searched ‘How to make money at home’ and discovered gambling with no deposits and started down that rabbit hole and my friends look at this sort of thing too.”

Female, aged 35 to 44, PGSI 24

Given this exploratory approach they are also, unsurprisingly, the subject of heavy social media and search engine advertising, and often encounter affiliate websites, meaning they are often exposed to a vast array of online gambling providers.

When looking to find new companies to test on behalf of the wider group, Social Explorers are opportunistic in their approach, taking advantage of offers as and when they see them advertised. This tends to be favoured over using search engines or seeking recommendations from unknown forums, which are often seen as more effortful avenues to pursue.

Attitudes towards illegal websites and regulation

Awareness of licensing within the gambling sector tends to be low among this audience, meaning the presence or absence of indicators of the Commission licensing these websites (such as their logo or the company’s account number with the Commission) is rarely actively sought or even considered.

“I can’t say I’ve ever looked for the Gambling Commission logo, nor have I looked up a site on their website. It’s just not something I’d think about.”

Male, aged 45 to 54

Instead, differences between licensed and illegal websites are recognised through differences in payment currencies, location of the gambling company (that is, Great Britain or overseas) and quality of design of the website. However, this group will tolerate less polished designs in exchange for better odds and positive pay-out experiences.

Upon realising they may have gambled with illegal websites, this group do not rule out using these websites in future. They feel protected from the risks associated with these websites through their cautious trial and error approach to using new gambling websites and will go with the companies that offer the best odds, irrespective of licensing status.

“Whether they’re licensed doesn’t really worry me. I normally trial new sites with small amounts or free spins so I’m not losing much if they don’t pay out.”

Male, aged 45 to 54

“I would be open to using these sites in the future. I might not place big bets or use free spins but if they had good offers I’d definitely consider it.”

Male, aged 45 to 54

Case study

Shaun, Aged 45, PGSI 18, Social Explorer

Shaun works as a manager in a large grocery store and lives with his wife and two kids in Oxford. He likes playing on online casinos in his free time, mainly on a weekday evening to unwind or at the weekend if he has the house to himself. He sees himself as a someone who gambles casually – it is something he sees as fun, which he likes doing a couple of times a week and then talking about with his friends. They normally WhatsApp each other while playing, sharing experiences and recommendations.

Triggers
A desire to spend time discussing new websites and experiences with friends – he enjoys pleasing his friends with recommendations and wants to reciprocate when they have given him hints and tips.
Boredom with current gambling websites – both the games available and the odds offered.

“I like to talk to my friends about gambling. It’s something we can do together.”

Pathway
Word of mouth recommendations from friends.He arrives at sites by clicking on ads on Facebook, X, and email advertising – he will click through to any site with a ‘good offer’. “They recommend sites to me, and I’ll do the same.” “I’ll click on any ad I come across if the offer is good, normally I see them on Facebook or I get emails.”

Experience
A generally positive experience of play and paying out. He will ‘trial’ websites: looking at the website design to assess quality, betting small amounts to see if they pay out before recommending the site to friends. There was one instance where a site did not pay out despite him having already ‘trialled’ it – he saw this as a learning experience to be more thorough when trialling websites in future.

“I’ll look at if it’s in English and if the site looks okay and seems to work. If that’s the case, then I’ll try a small bet and see what happens.”

Outlook
He sees losing money as part and parcel of using these websites and an acceptable loss as he doesn’t bet large amounts. He will continue to use these websites as they offer something new and fun which he and his friends can bond over.

“I’m okay with using these sites. As long as I know they work and I know my friends wouldn’t recommend a site if they hadn’t tried it first.”

Names and identifying information have been changed

Accidental Tourists

This section explores the Accidental Tourist audience in more depth, covering their reasons for using illegal gambling websites, pathways into illegal websites and wider attitudes towards these websites and regulation.

Reasons for using illegal websites

Similarly to Social Explorers, this subset of illegal website users chance upon the illegal market accidentally. Most were unaware they had used an illegal website until the potential indicators of unlicensed websites were pointed out to them as part of the research.

Two main motivations can inadvertently lead this group to illegal websites.

Firstly, the desire to win. As a group who label themselves as taking a more ‘casual’ approach to gambling, they put less value on complete immersion in the gambling experience and more emphasis on quick gambling sessions. With their gambling activity being more sporadic, they tend to prioritise better odds over novel game play experiences, as they want to make the most of these shorter sessions and increase their chances of success when the opportunity to gamble lands. For them, the prospect of winning is what makes this an enjoyable experience.

“The sites I’ve used initially drew my attention by having a large number of free spins on their games. I didn’t really notice much in the way of the experience using the site. I only realised they were unlicensed through the research.”

Male, aged 35 to 44 years, PGSI 5

Secondly, for some, gambling forms a small part of wider hobbies and interests and can enhance the enjoyment of these activities. For example, betting on their favourite sport.

“You can bet on more sports on these sites, like games in the US. For UK games, you can get better odds betting with a foreign site.”

Male, aged 55 to 64, PGSI 6

Pathways into illegal websites

Pathways into illegal websites stem directly from this group’s motivations. For those driven to seek better odds, search engines are a popular choice. This group tend to be less discerning in their selection of websites compared to others, selecting higher-ranking search results as a way to reassure themselves as to the reliability of these websites. This appears to create something of a herding effect among this group.

“I just Google search and then click the first link I see, after the paid ads. I know that must be a popular site, so it must be a good one to use.”

Male, aged 55 to 64, PGSI 4

For those who have a particular hobby or interest which gambling compliments, another pathway in is through advertising and recommendations given as part of sports podcasts or when watching YouTube videos of influencers gambling. This group tend to trust those who are popular and well-established within their given hobby.

“You get a lot of sites mentioned by YouTubers I follow, mainly in the US.”

Male, aged 55 to 64, PGSI 4

Attitudes towards illegal websites and regulation

Upon the realisation that some of their gambling activity may have been on illegal websites, this cohort remain open to using these websites in future. They feel that since they do not tend to gamble in large amounts, the risks associated with these gambling companies are relatively low.

“I don’t gamble all the time and I don’t gamble large amounts, so it’s not like I’m going to lose loads of money if they don’t pay out.”

Male, aged 18 to 24, PGSI 1

Case study

Daniel, aged 60, PGSI 4, Accidental Tourist

Daniel is retired and formerly worked for a company making educational resources. He’s a real sports enthusiast and likes to gamble on football because it adds a spark of excitement to the game and means he has to pay more attention to the outcome, making it more immersive. He normally uses SkyBet, Ladbrokes or 32 Red, as he doesn’t know of many other companies, and he knows these 3 will offer different promotions at different times.

Triggers
He felt his current providers’ odds and promotions were limited – looking for something more compelling and he is seeking something new and fun.

"I just felt the odds weren’t great and using the same sites again and again wasn’t as fun as it used to be.”

Pathway
He Googles site names which he’d heard of through word-of-mouth recommendations from podcast hosts and YouTube accounts he follows. He also clicks pop-up ads on YouTube.

“You get a lot of sites mentioned by YouTubers I follow, mainly in the US.”

“I like watching people on YouTube making high bets on sports, it makes it interesting. I also listen to podcasts.”

Experience
He didn’t realise these could be unlicensed websites at the time, as he had no issues with using them, nor did he notice anything different about the play experience. He experienced one or two instances of the websites not asking for his ID but this didn’t trouble him or make him think twice.

“I didn’t realise these sites might be illegal. I didn’t even think about their being UK based or otherwise.”

Outlook
He is open to using these websites in the future as he has gotten better odds through them which really enhances his enjoyment when watching sport. He doesn’t see them as too risky to use – if he knew a site was unlicensed, he might bet smaller amounts next time to feel ‘safer’.

“I haven’t had any trouble with the sites I’ve used. I don’t see a reason not to use them.”

Names and identifying information have been changed

Next steps

In this study, we have identified 8 potential indicators of engagement with illegal gambling websites for qualitative recruitment purposes. However, we wish to take these indicators into a more robust phase of research that will involve careful analysis of existing data to determine which potential indicators can accurately signify engagement in the illegal online space, particularly given those who gamble often struggle to identify whether they have used an illegal website.

Following this phase of research, our next step will be to use the analysis of existing data to inform a larger-scale quantitative survey, allowing us to validate the quantitative findings produced in this first phase. This will enable us to develop a set of questions to feed into the Gambling Survey for Great Britain (GSGB), which will allow for robust, ongoing tracking of consumer engagement with the online illegal market over time.

At the time of writing, the objectives of this stage have yet to be formulated but may include (whilst not being limited to):

Appendices

Appendix A – Quantitative quotas

Quantitative quotas

Months and rates
Type Percentage
Gender
Men 61%
Female 39%
Age
18 to 24 years 13%
25 to 34 years 26%
35 to 44 years 21%
45 to 54 years 19%
55 to 64 years 13%
65 years and over 8%
Social grade
AB 28%
C1 29%
C2 22%
DE 21%
Region
Scotland 8%
North East 5%
North West 13%
Yorkshire and the Humber 10%
West Midlands 9%
East Midlands 6%
Wales 5%
East of England 8%
London 16%
South East 11%
South West 8%

Appendix B – Quantitative survey questions

Survey name: Unlicensed gambling incidence questionnaire
Survey date: 17th April
Methodology: ONLINE
Survey length: 13 questions and Demogs. 10-minute survey.

Sample: 1,000 online gamblers (activity in the last 4 weeks) – that is, excluding only in-person gamblers, National Lottery, scratchcards and private betting (that is, any combination of only those activities).

Demographics

S1. Gender

(ASK ALL)

How do you identify? (SINGLE CODE)

  1. Man
  2. Woman
  3. Non-binary
  4. Prefer to use own term (Specify)
  5. Prefer not to say

S2. Age

(ASK ALL)

Please enter your age below.

(WRITE-IN)

(CLOSE IF LESS THAN 18 YEARS])

S3. Ethnicity

(ASK ALL) 

Which one of these groups best describes your ethnic group or background?

(SINGLE CODE)

(WHITE)

  1. English/ Welsh/ Scottish/ Northern Irish/ British
  2. Irish 
  3. Traveller or Irish Traveller
  4. Any other white background 

  5. (MIXED/ MULTIPLE ETHNIC GROUPS) 

  6. White and Black Caribbean
  7. White and Black African
  8. White and Asian
  9. Any other mixed / multiple ethnic background 

  10. (ASIAN AND BRITISH ASIAN)

  11. Indian 
  12. Pakistani
  13. Bangladeshi
  14. Chinese
  15. Any other Asian background 

  16. (BLACK AND BLACK BRITISH)

  17. Caribbean 
  18. African
  19. other Black/ African/ Caribbean background
  1. Prefer not to say 

S4. Socio-economic group

(ASK ALL) 
(SINGLE CODE)

Which one of these best describes the chief income earner in your household? 

The Chief Income Earner is the person with the largest income, whether from employment, pensions, state benefits, investments or any other source. If two or more related people in the household have equal income, please think of this question with the oldest in mind. 

If you / they are retired and living on a private pension, please choose your description based on what you / they did before you/ they retired. 

If you / they have been unemployed for six months or less, please choose your description based on your / their most recent main job. 

Dates and amounts
Code Description Socio-economic group (SEG)
1 High managerial, administrative or professional
(such as, doctor, lawyer, company director (more than 50 people), judge, surgeon, school headmaster, and so on).
A
2 Intermediate managerial, administrative or professional
(such as, school teacher, office manager, junior doctor, bank manager, police inspector, accountant, and so on).
B
3 Supervisor, clerical, junior managerial, administrative or professional
such as, policeman, nurse, secretary, clerk, self-employed (5 or more people) and so on
C1
4 Skilled manual worker, 
such as, mechanic, paramedic, cook, fitter, plumber, electrician, lorry driver, train driver, hairdresser, beautician and so on
C2
5 Semi-skilled or unskilled manual worker
such as, baggage handler, restaurant server, factory worker, receptionist, labourer, gardener and so on.
C2
6 Full-time responsibility for home and/or family  E
7 Unemployed E
8 Student C1
9 Retired and on state pension ONLY
(If retired but not only on state pension, please indicate the occupation just before retirement) 
E
10 Don't know X

S5. Socio-grader

(ASK ALL) 
(SINGLE CODE)

Please input the first 3 or 4 letters of the occupation of your household's Chief Income Earner below and click 'search'. 

(INPUT BOX)

Section 1: Current gambling habits

(ASK ALL)

For the next series of questions, we’d like you to think about gambling activities; by gambling we mean both spending money on games of chance where you can win money (i.e. betting) and/or free-to-play games where you do not have to pay to gamble.  

A1. Gambling activities

When, if ever, have you spent money on the following activities in the last 12 months?

ROWS, RANDOMISE

  1. Online fruit, slot or virtual gaming
  2. Online bingo
  3. Online betting on horse or dog races, including virtual races
  4. Online betting on football
  5. Online betting on other sports, including virtual sports and e-sports [GROUP CODE C, D AND E; ALWAYS SHOW CODE E BELOW CODE C AND D]
  6. Online betting on events (such as, political, entertainment, topical, current affairs, novelty)
  7. Online roulette, card/dice games, Poker, or non-lottery instant win games
  8. Another form of online gambling activity [ANCHOR]

(COLUMNS, SINGLE CODE)

  1. In the last 7 days
  2. In the last 4 weeks
  3. In the last 12 months
  4. More than 12 months ago
  5. Have never spent money on this

(THANK AND CLOSE IF CODE 4 TO 5 ON ALL OPTIONS)

A2. PGSI

(ASK ALL)
And thinking about the last 12 months…

ROWS, DO NOT RANDOMISE

  1. Have you bet more than you could really afford to lose?
  2. Have you needed to gamble with larger amounts of money to get the same feeling of excitement?
  3. When you gambled, did you go back another day to try to win back the money you lost?
  4. Have you borrowed money or sold anything to get money to gamble?
  5. Have you felt that you might have a problem with gambling?
  6. Has gambling caused you any health problems, including stress or anxiety?
  7. Have people criticized your betting or told you that you had a gambling problem, regardless of whether or not you thought it was true?
  8. Has your gambling caused any financial problems for you or your household?
  9. Have you felt guilty about the way you gamble or what happens when you gamble?

COLUMNS, SINGLE CODE

  1. Almost always
  2. Most of the time
  3. Sometimes
  4. Never

Section 2: Motivations and behaviours

(ASK ALL)

B1. Motivations and behaviours

In the last 12 months, I have…?

ROWS, RANDOMISE

  1. Gambled using a Virtual Private Network (VPN) in order to bypass gambling blocking software (such as, Gamban)
  2. Gambled on a foreign website and/or one where I had to change the default currency or language
  3. Gambled on a website I had not previously heard of
  4. Experienced difficulty withdrawing my funds from a gambling website without any clear explanation
  5. Used a gambling website where I did not need to provide ID or age verification upon sign up
  6. Attempted to contact a gambling website (via email, live chat or phone number) but did not receive any acknowledgement or response
  7. Used a gambling website that was glitchy or crashed frequently, such as, I had to restart games or bets because the website kept glitching
  8. Tried to access a gambling website I have used previously, but found that it had been taken down
  9. Gambled on a website that I knew didn’t offer deposit limits/self-exclusion/other safer gambling tools
  10. Gambled on a website that I suspected or knew was unlicensed [ANCHOR]

COLUMNS, (SINGLE CODE)

  1. In the last week
  2. In the last month
  3. In the last 3 months
  4. In the last 12 months
  5. I haven’t done this in the last 12 months
  6. Prefer not to say

(ASK IF SUSPECTS UNLICENSED (B1 = 10))

B1a. Unlicensed websites

You mentioned that you suspect or know that you have gambled on an unlicensed website. Could you tell us which website(s)?

[WRITE IN]

  1. Prefer not to say

B2. Adjacent offers

(ASK ALL) In the last 12 months, have you paid to gamble on a gambling website using…

MULTICODE, RANDOMISE

  1. Own disposable income
  2. Payday loans
  3. Cryptocurrency (such as, bitcoin)
  4. A foreign currency (i.e., not GBP)
  5. Virtual assets such as NFTs
  6. A credit card
  7. Something else (please specify)
  8. None of these [ANCHOR]
  9. Prefer not to say [ANCHOR]

(ASK ALL)

B3a. GamStop usage

Have you ever signed up to GamStop?

(POP-OUT WINDOW: GamStop is a free online tool that, if you sign up, prevents you from using gambling websites and apps run by companies licensed in Great Britain, for a period of your choosing.)

(SINGLE CODE)

  1. Yes, within the past 12 months
  2. Yes, but more than 12 months ago
  3. No
  4. Don’t know

(ASK ALL WHO HAVE USED GAMSTOP (B3a = 1-2))

B3b. Relationship with GamStop

I have…

(POP-OUT WINDOW: GamStop is a free online tool that, if you sign up, prevents you from using gambling websites and apps run by companies licensed in Great Britain, for a period of your choosing.)

(SINGLE CODE)

  1. Only gambled using websites that are blocked when I am signed up to GamStop
  2. Gambled on websites that are blocked when I am signed up to GamStop, and on websites that are not blocked when I am signed up to GamStop
  3. Only gambled using websites that are not blocked when I am signed up to GamStop
  4. Not gambled at all on gambling websites when I am signed up to GamStop
  5. I don’t know
  6. Prefer not to say

Section 3: Virtual Prime Networks (VPNs)

(ASK ALL)

C1. VPN

A Virtual Private Network (VPN) can protect your online identity by hiding your IP address when using the internet.

Thinking of the last 12 months, and your personal device(s), which of the following statements best applies to you?

(SINGLE CODE)

  1. I have a VPN and it is always on
  2. I have a VPN, and I always use it when visiting gambling websites, specifically
  3. I have a VPN, though I don’t check if I’m using it when visiting gambling websites
  4. I have a VPN, though I never use it when visiting gambling websites
  5. I do not have a VPN
  6. Prefer not to say

Section 4: General perceptions

(ASK ALL)

D1. Outright incidence

Gambling websites that are licensed by the British Gambling Commission typically include the Gambling Commission logo (pictured below) on their website, as well as their account number with the Commission. The Commission will not license a gambling website unless it:

Respondents would see the logo contains the word 'Gambling' on top of word 'Commission'. This will redirect you to Public and players home.

(Example of the logo)

When choosing where to gamble, and based on the explanation above, which of the following statements best applies to you?

(SINGLE CODE) FORWARD/REVERSE SCALE

  1. I only ever gamble using websites that I know are unlicensed
  2. I gamble using both licensed and unlicensed websites
  3. I have previously gambled using unlicensed websites but don’t anymore
  4. I have never gambled using unlicensed websites before, but would not rule it out in future
  5. I only ever gamble on websites that I know are licensed
  6. Prefer not to say

(ASK ALL)

D2. Consumer vigilance

When choosing where to gamble, what checks, if any, do you do on the gambling website?

MULTICODE, RANDOMISE

  1. Whether it is based in Great Britain
  2. Whether I recognise the name of the website
  3. I check customer reviews (such as, via Trustpilot)
  4. Whether there are safer gambling tools available
  5. Whether there is a Gambling Commission logo or account number on the website
  6. Whether the website is registered with GamStop
  7. Other (please specify) (ANCHOR)
  8. None of these [EXCLUSIVE, ANCHOR]

D3. Awareness route

(ASK THOSE THAT HAVE USED UNLICENSED WEBSITES (D1 =1-3))

You indicated that you either currently, or have previously, gambled using unlicensed websites.

How did you find out about these websites?

(MULTICODE, RANDOMISE)

  1. Via a search engine
  2. Through paid advertising on social media
  3. Via affiliate websites
  4. [POP-OUT WINDOW: Affiliate websites often collate lists of preferred gambling websites based on best odds, sign-up offers and whether they are regulated. They are often accessed through Google and provide links through which gamblers can access the websites to sign up.]

  5. Via a social media personality or influencer (such as, a Twitch streamer, or an X or Twitter affiliate)
  6. Via word of mouth (such as, friends or family, social media groups)
  7. Via a gambling forum
  8. Something else (please specify) [ANCHOR]
  9. Don’t know [ANCHOR]

(ASK ALL WHO SAY THEY MAY USE UNLICENSED IN FUTURE (D1 = 2-4)) 

D4. Push factors

What might be a factor in you using, or increasing your use of, an unlicensed gambling website in the future?

MULTICODE, RANDOMISE

  1. Getting the best odds
  2. Stricter rules for gambling companies which require them to conduct background checks about me (such as, financial risk checks) [ANCHOR ABOVE CODE 8]
  3. [POP-OUT WINDOW: Financial risk checks would potentially require gambling websites to perform frictionless checks on customers who spend over a certain threshold on gambling to find out whether they could afford their losses, via data such as credit history and income level.]

  4. Finding websites that are not on GamStop
  5. [POP-OUT WINDOW: GamStop is a free online tool that, if you sign up, prevents you from using gambling websites and apps run by companies licensed in Great Britain, for a period of your choosing.]

  6. Getting the best sign-up or bonus offers
  7. Ease or speed of withdrawal
  8. Playing games or betting on activities that are not offered by licensed gambling websites
  9. Changes to safer gambling tools that make them more limiting
  10. [POP-OUT WINDOW: Safer Gambling tools are tools available to support gamblers to help manage the amount they gamble or the way in which they gamble. Options include, but are not limited to: deposit or loss limits, self-exclusion, reality checks, gambling blocking software, and time outs.]

    Stricter rules for gambling companies which require me to provide information to them (e.g. Bank Statements) (ANCHOR BELOW CODE 2)

    (POP-OUT WINDOW: In the event that a financial risk check cannot be completed by a gambling website with information available from other sources, they may request that information from the customer)

  11. Other (please specify) [ANCHOR]
  12. None of the above [EXCLUSIVE, ANCHOR]

(ASK ALL)

X1. Close

Thank you for answering those questions. If these questions have raised any topics of concern, you can contact:

Samaritans on 116 123.

GamCare on 0808 8020 133

The questions you have just answered were on behalf of our client, the Gambling Commission. We are also looking to conduct some follow-up interviews to explore a range of pathways and experiences, as well as gauging knowledge and understanding of unlicensed gambling. This would involve taking part in a 1-hour online interview in either May or July 2024, where we would look to explore your perceptions and experience of gambling further. There may also be a ‘homework’ task that we would ask you to complete before the interview which would take between 15 to 30 minutes of your time.

Please note, your details will only be passed on if you agree and only for the purposes of this study. All details will be stored and transferred securely and will be deleted once the study is over and note your details will NOT be passed on to the Gambling Commission.

If you agree to take part and are selected to do the 60 minute online interview you would be provided with a voucher for your time and as a thank you for taking part of £50 (for the interview only) or of £65 (for the interview + completion of the homework).

You will need to provide your contact details to the researchers who will then send you the voucher.

The client would also like to see your answers to these question, but they will not be directly attributable to you.

If you agree to take part, we (Yonder Consulting) will collect your name, email address and phone number. We would then get in touch with you to further assess your eligibility and provide further details.

Would you be interested in taking part?

Yes
No THANK AND CLOSE

IF YES (X1 = 1)

X2. Details

Do you give permission to collect your name, email address, phone number and responses to this survey to contact you regarding this additional research, should you be eligible?

Yes
No
CLOSE

IF YES (X2 = 1)

X3. Give details

If you are no longer interested in taking part in this further research, please close your browser without sharing your details.

If you are interested, please provide your:

Appendix C – Depth interview participant profiles

Intentional unlicensed site users

Noah

Age: 25 to 34.
Problem Gambling Severity Index (PGSI): 2.
Type of gambling: Online casino.
Hard indicators: VPN, foreign site, credit card, crypto, ID verification.
Routes in: Affiliate website, search engine.
Used unlicensed: Yes.

Fatima

Age: 25 to 34.
PGSI: 9.
Type of gambling: Online casino.
Hard indicators: VPN, foreign site, credit card, crypto, ID verification.
Routes in: Social media influencer, affliate website, word of mouth, gambling forum.
Used unlicensed: Yes.

Yara

Age: 35 to 44.
Problem Gambling Severity Index (PGSI): 24.
Type of gambling: Online casino.
Hard indicators: VPN, foreign site, credit card, crypto, ID verification.
Routes in: Search engine, afiliate website, gambling forum.
Used unlicensed: Yes.

Shaun

Age: 45 to 54.
Problem Gambling Severity Index (PGSI): 18.
Type of gambling: Online casino.
Hard indicators: Foreign site, credit card, crypto.
Routes in: Social media influencer, paid advertising.
Used unlicensed: Yes.

Aware of unlicensed but stumbled across the sites

Abdullah

Age: 25 to 34.
PGSI: 22.
Type of gambling: Sports betting, Online casino.
Hard indicators: VPN, foreign site, credit card, crypto, ID verification, NFTs.
Routes in: Social media influencer, affiliate website, paid advertising.
Used unlicensed: Yes.

Neil

Age: 25 to 34.
Problem Gambling Severity Index (PGSI): 16.
Type of gambling: Sports betting, Online casino.
Hard indicators: VPN, ID verification, crypto.
Routes in: Affiliate website, paid advertising.
Used unlicensed: Yes.

Unaware of unlicensed sites until the research

Daniel

Age: 55 to 64.
Problem Gambling Severity Index (PGSI): 6.
Type of gambling: Sports betting, Online casino.
Hard indicators: Foreign site, VPN.
Routes in: Search engine, social media influencer paid.
Used unlicensed: Yes.

Sam

Age: 45 to 54
Problem Gambling Severity Index (PGSI): 4.
Type of gambling: Sports betting, Online casino.
Hard indicators: Foreign site, credit card.
Routes in: Affiliate website, paid advertising.
Used unlicensed: Yes.

Non users who would consider using in the future

Even though they classed themselves as non-users, they suspected they may have stumbled across unlicensed websites in the past.

Mark

Age: 35 to 44.
Problem Gambling Severity Index (PGSI): 5.
Type of gambling: Sports betting, Online casino.
Hard indicators: ID verification, payment via Paypal.
Routes in: Search engine.
Used unlicensed: Yes.

Tim

Age: 18 to 24.
Problem Gambling Severity Index (PGSI): 1.
Type of gambling: Sports betting.
Hard indicators: VPN, foreign site.
Routes in: Word of mouth.
Used unlicensed: Yes.

Appendix D – Depth interview discussion guide

Depth Interview Discussion Guide

  1. Introductions and warm-up (5 minutes)
  2. General gambling behaviour and pre-task recap (10 minutes)
  3. Licensing practices & vigilance checks (5 to 10 minutes)
  4. Context of unlicensed gambling sites: Exposure and usage (15 minutes)
  5. Deep dive into experiences of using unlicensed sites & hard indicators (15 to 20 minutes)
  6. Wrap-up and close (2 minutes).

Research objectives:

The overall objective of this research is to explore the consumer journey when engaging with online gambling, specifically their experience (if any) with unlicensed gambling operators and explore the factors which may drive and/or have driven consumers to using these unlicensed sites.

Interview objectives:

  1. Develop user journeys and generate case studies including:
    • internal motivations, external triggers and search process: specifically including role of various influences such as marketing offers, targeted advertising, affiliates, social media personalities, word of mouth and gambling forums
    • play experience – including in play and/or pay-out and/or customer service
    • future possibilities – What factors may drive gamblers to using unlicensed sites.
  2. Explore knowledge levels and gaps – to what extent are consumers aware of operating licensing practices in GB, what are the indicators of unlicensed operators for those that are aware and for those not aware, what was not obvious to them?
  3. Understand perceptions of unlicensed gambling: Understand the impact on play (and levels of harm) and perceptions of unlicensed gambling: are customers invested in controlling unlicensed gambling or do they not care?

Moderator to use responses from the pre-task to probe on areas that need further clarity or detail.

1. Introductions and warm up (5 minutes)

Moderator to introduce themselves, Yonder and its background as an independent research agency.

Thank you for completing the pre-task on your gambling habits and for joining us today to discuss your experiences gambling online.

Before we begin, there are a few key things that I’d like to mention we’re looking to understand more about your current attitudes, opinions and experiences around online gambling. This is for research purposes only and there will be no action taken off the back of what you tell us. There are no right or wrong answers, so please feel free to share what you really think – we’re just really interested to hear about your experiences. Rest assured that everything that you say will remain anonymous, and none of your personal details will be disclosed in our report. Just as a reminder, this session will last approximately 1 hour.

Data privacy and consent:

Your participation in this interview means that you consent to our use of your personal information for research purposes only. We assure you that any information shared will be treated confidentially and in accordance with the General Data Protection Regulation (GDPR) and Market Research Society (MRS) guidelines to protect your privacy and ensure ethical practice.

Please note that this interview will be recorded for the purpose of accurately capturing your responses and ensuring the quality of the research. Do you consent to this?

The recording will only be accessible to authorised researchers and will be securely stored for 6 months after which your data will be deleted. Do you have any questions before we start?

It would be great to get to know you a bit better. Please tell me:

2. General gambling behaviour and pre-task recap (10 minutes)

Objective: Build rapport and engagement with the participant, and recap on pre-task activities and reflections, as well as gaining a deeper understanding of influences on decision making.

Thank you for completing the pre-task.

How did you find the experience? Was there anything that stood out to you in particular? What stood out and why?

Moderator to explain we would like to start by hearing more about their gambling activity.

I'd like to start by discussing some of the key points you documented and hearing more about your gambling activity overall. As a reminder, some of these questions we will have asked during the pre-task but we just want to find out a bit more about your experience.

In the pre-task, we asked you to reflect on several aspects.

One such area was what makes you gravitate towards certain online gambling activities and sites. As a recap, can you tell me about what attracts you to these online gambling activities?

What does a typical experience look like for you when you’re gambling online?

We also asked you to speak about positive and negative experiences in relation to online gambling - can you please give me some examples?

You mentioned in the pre-task that you use particular sites when gambling online.

Why? What first attracted you to them? How do you decide which gambling companies to use? Probe into factors influencing their decisions and/or selection process…has this changed over time? Do you use multiple sites and/or companies? If so, how do they compare to one another? Are there some you prefer over others? Why?

Can you describe how you first encountered the gambling site(s) you currently use or have used? (for example online search, social media, word of mouth, advertisements)

Are there particular channels and/or people you tend to listen to over others? Why?

3. Licensing practices & vigilance checks (5 to 10 minutes)

Objective: Understand whether gamblers perform vigilance checks and whether licensing practices are something they take into consideration and/or care about.

Before taking part in this research, to what extent were you aware of the licensing practices governing gambling companies in GB?

Before taking part in this research, were you aware of the Gambling Commission or their role?

Note: if participants are not familiar, moderator to remind them of who the Gambling Commission are, such as an organisation which seeks to make gambling fairer and safer. It does so by licensing and regulating in the public interest and providing advice and guidance. It wants a fair and safe gambling market where all consumers and the interests of the wider public are protected.

Does any of the above impact your decision making when it comes to gambling?

How do you know if a gambling company is licensed or unlicensed? Do you ever check to see if a site is licensed? If so, how do you check and/or what do you check?

Before taking part in this research, was this something you even thought about or looked for? Why? How important is this to you?

Moderator to prompt respondents on potential indicators if they struggle to identify whether they have used an unlicensed site. Potential indicators of an unlicenced site can include: having to change the currency or language, having to use a Virtual Private Network (VPN) to access a gambling website, not requiring ID or age verification to sign up, having to use a foreign currency or cryptocurrency or pay using Virtual assets such as NFTs for example.

Note: Some may use sites which are licensed in other jurisdictions but not the UK if they are familiar with that country and/or domain.

Does this influence your decision to gamble on a site, or not at all?

4. Context of using unlicensed gambling sites: exposure and usage (15 minutes)

Objective: Understand the wider context of unlicensed gambling including perceptions, previous usage, internal motivations, external triggers, and routes in.
Now, I’d like to focus more on unlicensed gambling companies and websites, such as sites that aren’t licensed by the Gambling Commission.

Have you ever used an unlicensed gambling site, to your knowledge? Moderator to check whether this aligns with screening responses – if not, why?

For those who have:

Moderator to probe if not mentioned spontaneously: online search, paid advertising on social media, word of mouth, gambling forum, social media personality or influencer and so on.

What made these sources compelling or credible to them? Why did they follow their recommendation?

What made them realise this was an unlicensed site? What was and/or wasn’t clear to them about this?

When did they realise this?

How did this make them feel? Did this impact their play?

If sought out intentionally: If you have previously gambled using unlicensed websites, how did you find out about these?

Moderator to probe if not mentioned spontaneously: online search, paid advertising on social media, word of mouth, gambling forum, social media personality or influencer for example.

Why do you look to use these sites? If not mentioned, probe on role of regulator action (such as stricter checks, limits etc. as a driver to unlicensed)

What are the risks verses rewards of using these sites?

What are the positives of using these sites? Probe on role of sign-up offers and bonuses – what about these are attractive to people (amount offered, lack of wagering requirements for example)?

What are the negatives of using these sites, if any?

Are you still using these sites? Has anything changed in terms of how or when you use them?

How do you see this being different to gambling on a site that is licensed (if at all)?

For those who haven’t:

5. Deep dive into experiences of using unlicensed sites & potential indicators (15 to 20 minutes):

Objective: Dive deeper into specific customer journeys and experiences of using unlicensed sites, including hard indicators of unlicensed site usage.

(Note: this section applies to ‘current users’ and ‘less and/or unaware users’ only – do not ask ‘potential users’)

(Note: Usage of GAMSTOP may emerge spontaneously – if so, allow respondents to say their piece then move on without probing in-depth).

Now thinking about your use of online gambling sites it would be great to know if you have ever:

For each of these that you’ve done, could you please tell us more about your experience, in detail?

What were the highlights and/or positives of your experience?

What were the drawbacks and/or negatives of your experience?

Could you, if you recall, walk us through a typical experience when using one of these unlicensed sites?

How did you feel at the start? What were your expectations? Probe on any assumptions made and risks they were aware of going in.

What was the play experience like?

  • Did it live up to your expectations? Did anything come as a surprise?
  • What went well?
  • what went less well?
  • If they had a negative experience: What went wrong? How did this make them feel? Did they get a resolution in the end?
  • Do you think you will continue to use unlicensed sites in the future? Why and/or Why not?

    Gauge the role of: Getting the best odds, Getting the best sign-up or bonus offers, ease or speed of withdrawal, quality of user experience, customer service, playing games or betting on activities that are not offered by licensed gambling websites, actions taken by the regulator (for example checks, limit setting and so on) and so on.

    6. Wrap-up and close (2 minutes)

    Do you have any final thoughts you’d like to share on using licensed or unlicensed gambling sites as a whole?

    Invite participant to share any final thoughts, recommendations, or additional insights related to unlicensed gambling or wider online gambling behaviour.

    Reiterate the importance of their input in informing efforts to promote fairer outcomes for gamblers.

    Thank participant for their time and contributions, confirm incentive payment and close.

    Appendix E - LEAP-facilitated focus group discussion guide

    Topic areas to cover in the research sessions

    Please note this is not a script, rather a guideline of topics to cover. Please do feel free to make your own list of questions or notes for reference during the research session.

    Welcome and introductions – 5 minutes

    Meet and greet participants

    Moderator to introduce the purpose of the session and their role, any house rules, including:

    Ask each participant to introduce themselves, for example tell me your name and what kind of gambling they do and/or did.

    Online gambling and routes in – 10 minutes

    What forms of online gambling have they done? What particular providers and/or sites did they use? Why? How do they decide which to use?

    How do they find out about different sites? Through offers and/or paid advertising and/or gambling forums and/or word of mouth and/or social media and/or influencers and so on?

    Use of GAMSTOP and unlicensed sites – 40 minutes

    Have they ever gambled online while registered to GAMSTOP?

    What has been their experience of this? How did this work exactly?

    What enabled them to still access sites which the software would normally block?

    How much do they know about licensing and/or regulation and the difference between a licensed vs unlicensed site?

    Have they ever used unlicensed sites to their knowledge? Note indicators can include:

    What has been their experience of this?

    What are the positives of using these sites? What are the negatives?

    How did they stumble across/find out about these sites? Through offers and/or paid advertising and/or gambling forums and/or word of mouth and/or social media and/or influencers and so on?

    How do they weigh up the risks vs reward of using these sites?

    Where are they at with these sites now? How do they feel about them?

    Thank and close – 5 minutes

    Thank participants, and end the discussion – it’s a good idea to start signalling 5 to 10 minutes prior to the end that you’re coming towards the end of the session, so the end of the session doesn’t feel abrupt.