Illegal online gambling - Phase 2: Identifying indicators of consumer engagement with illegal gambling websites

Introduction

This report contains the findings from the second phase of the Gambling Commission’s research into the online unlicensed gambling market, specifically illegal websites, conducted in collaboration with Yonder Consulting (Yonder) as part of the Consumer Voice Research Programme.

The research was designed to refine the approach and to validate findings from the first phase of the project, conducted earlier in 2024.

The first phase was exploratory in nature, combining a quantitative incidence check with some broad indicators of illegal website use and follow-up qualitative depth interviews with those who have used illegal websites. This study found 4 qualitative broad audience groups: self-excluders, skilled advocates, social explorers; accidental tourists; and, additionally, outside of the scope of the illegal market: non-users and/or non-engagers – by far, the largest group.

The second phase was designed to have a narrower focus, developing a suite of questions on the online illegal market for the Commission’s Gambling Survey for Great Britain (GSGB), which would allow them to understand the level of engagement with the online illegal market in more detail going forward.

Objectives

The primary objective of this research project was to produce a set of indicators by which the Commission could track the consumer engagement with the online illegal market over time. This output objective was to develop a set of questions for the Commission’s GSGB. To accompany this output, Yonder provided a transparent explanation of the methodological approach used to select these questions and the composite scoring system designed to allow the Commission to monitor consumer engagement with illegal websites, which will be published in a forthcoming Phase 3 technical report.

A further research objective was to validate the routes into the online illegal market found in the first phase, and how these routes interact with, and feed into, the different types of audiences who use illegal gambling websites.

This report focuses on the indicators of illegal gambling as research findings, rather than their development for the GSGB, which is covered in an upcoming Phase 3 technical report.

Methodology

Timeline

Phase 2 methodology in detail

In December 2024, Yonder conducted an ad hoc online survey with a sample of 2,046 adults who had gambled at least once online in the last 4 weeks (excluding those that had only played National Lottery products). Adults who had gambled in the last 4 weeks were sampled specifically because their recall of websites used, products played, and experiences had, would be better than those that had gambled in a less recent timeframe.

The rationale for excluding those who only play National Lottery was both due to the nature of the survey content, which required some degree of engagement with other online gambling activities such as betting, casino or bingo games, and to ensure good representation of consumer experience with the wider gambling industry, rather than just the National Lottery.

Respondents were recruited to be broadly representative, using a quota-based sampling approach, with 4 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 frames (full sample details can be found in Appendix 1). After fieldwork, weights were applied to the data to correct any imbalance that occurred in sampling, to exactly match the quotas. Fieldwork took place between 18 and 23 December 2024.

Respondents were asked questions around their awareness of the illegal online gambling market, their engagement within it, and their engagement with a series of indicators of illegal website usage.

Building on this research report, a Phase 3 technical report will be published at the end of 2025 alongside the Commission’s GSGB Year 3 (2025) Wave 2 publication. The Phase 3 report will outline the process for one of the project’s key output objectives: the creation of a suite of ‘illegal questions’ to monitor consumer engagement with illegal online gambling market over time. These questions will support both this project and the Commission’s ongoing GSGB. Instructions on the calculation of this index will be detailed in the upcoming Phase 3 technical report.

How to read this report

The narrative in this report focuses on key findings from the quantitative phase of the Phase 2 research conducted in December 2024. For more detailed insight into quantitative findings, including splits by sociodemographic group, please refer to the attached data tables.

This report:

• provides a robust assessment of the motivations, indicators, and experiences associated with online illegal gambling website usage among people who gamble online
• cannot, however, be used to extrapolate findings to the population-level, due to the research’s developmental design.

The following guidance 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 provide:

• a robust assessment of the most common indicators of illegal website usage among people who gamble online
• a look at patterns within the data amongst different demographic groups.

The quantitative element of this research consisted of an online survey conducted by Yonder, focused on a sample of people who gamble online (excluding National Lottery only players). Therefore, the views and experiences voiced by our sample are not representative of either the general British population or the wider gambling community.

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

• calculate a population-level assessment of the illegal online gambling market
• extrapolate Problem Gambling Severity Index (PGSI) findings to population-level estimates.

A note on timeframes

Throughout the Phase 2 quantitative survey, respondents were asked to report their engagement with a range of different behaviours and experiences across multiple timeframes. Most commonly, respondents were able to indicate whether they had engaged in a behaviour or experience:

• in the last 4 weeks
• in the last 12 months
• ever
• never¹.

Phase 2 of this project served as a developmental, information-gathering exercise; by allowing respondents to identify behaviours that had occurred further in the past, the Gambling Commission was able build a more comprehensive picture of consumer engagement with indicators of illegal gambling.

Therefore, this report focuses mainly on the total proportion of respondents that ‘ever’ engaged in a behaviour – that is, those that do so within the last 4 weeks, past 12 months, or longer ago. Base sizes for engagement with the self-reported indicators were larger when using this longer timeframe, meaning Yonder and the Commission can observe some longer-term statistically significant differences between subgroups.

As this report will discuss, for some indicators, this means that the longer-term datapoints – that is, respondents selecting that they had engaged with a behaviour longer than 12 months ago – cannot always be definitively labelled as an indication of illegal gambling, due to factors such as poor respondent recollection and changes to the Commission’s Licence Conditions and Codes of Practice in recent years. Where appropriate and significant, differences within the ‘last 4 weeks’ cohort have therefore also been highlighted in this report.

Terminology

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

Cryptocurrencies: cryptocurrencies, for example Bitcoin, are digital or virtual currencies secured by cryptography. They are not controlled by central authorities (banks and governments) and also use blockchain technology. It is illegal for gambling operators in Great Britain to allow consumers to use cryptocurrency to deposit money.

GAMSTOP: GAMSTOP is a free website that allows people who gamble to self-exclude, by blocking them from logging into, or setting up accounts with, all licensed gambling operators in Great Britain. More information can be found by visiting the GAMSTOP website (opens in new tab)

NFTs and virtual assets: Non-Fungible Tokens (NFTs) are unique digital ‘assets’, recorded on a blockchain (an online ledger). Virtual asset is the broader term referring to a digital representation of value open to being traded or used as payment (NFTs can often serve as digital ‘proof of ownership’ of another virtual asset – for example digital art, or a song).

Path to Play: the “Path to Play” framework developed by the Commission to understand the typical consumer gambling journey. It examines key stages those who gamble go through, recognising that everyone’s experience may be slightly different.

PGSI: Problem Gambling Severity Index, a screening tool which measures ‘problem gambling’, such as gambling to a degree that compromises, disrupts, or damages family, personal or recreational pursuits. A PGSI score of 8 and over represents 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 2 represents low risk gambling.

Respondents: where directly referring to data from quantitative research we use the term ‘respondent(s)’.

VPNs: Virtual Private Networks (VPNs) provide secure, encrypted connections that allow for private and secure internet access, in which a user’s IP address is masked, and their data is encrypted. In the context of this study, they can be used to ‘move’ someone’s virtual location to somewhere outside of Great Britain, so they can use operators that are potentially not licensed to operate in Great Britain.

Online illegal gambling: terminology used throughout this report to describe gambling websites and providers which are not licensed by the Commission², for more details on the requirements for a gambling company to obtain a licence, see the Licence Conditions and Codes of Practice.

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 unlicensed 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, ‘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 Commission to do so.

References to the ‘online’ illegal gambling market refers explicitly to gambling activity undertaken on a gambling website only, and does not refer to the promotion of illegal gambling activities via apps, social media websites or apps, streaming platforms, or ‘gambling adjacent’ activities such as crypto currency trading platforms. The survey questions used were designed in a way that reflects this distinction.

Limitations

While care was undertaken 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. Quantitative research provides a valuable snapshot of attitudes and opinions, offering a broad view of trends and patterns across a specific sample. However, one key limitation is that quantitative results often lack the depth to explain why respondents hold certain views or what specific factors drive their responses.

The sample selection for the quantitative research also provides limitations in the interpretation of results. As outlined in the methodology section of this report, the sample selected was those who have gambled online in the past 4 weeks, excluding National Lottery only players. This was to ensure respondents had as accurate recollection of websites, products and experiences as possible, in order to collect the richest data possible to support this development phase. As such, findings should not be treated as representative of all those who gamble online, and caution should be taken in assessing the significance of sub-group differences such as gambling frequency and PGSI score, as these groups may also not be representative, and may represent a higher than natural proportion within the sample than they would in a survey of the general population.

There is also an inherent limitation in assessing illegal gambling in a survey environment, as the accuracy of the data relies on self-reported behaviour, meaning insight is limited to what respondents’ recollection and what they felt comfortable sharing. This latter limitation was mitigated as much as possible through consistent reassurance about confidentiality, and that it was not illegal to gamble on an illegal website, but only to operate one.

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¹Respondents were also presented with ‘Don’t know’ and ‘Prefer not to say’ options.

²Note: within 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

Motivations and routes

Overall, engagement with the motivations and factors associated with usage of illegal gambling websites was low. When choosing a website to gamble with, respondents identified as having used an illegal gambling website (through reporting intentionally doing so themselves, and/or through the reporting of indicators of illegal website usage), were significantly more likely to rank considerations relating to the illegal market in their top 3. Some of these factors related closely to the types of behaviours that are only available in the illegal market, namely:

• accessing games or products not available in Great Britain (16 percent of illegal gambling website users, compared with 4 percent of all respondents)
• avoiding bans or account restrictions (12 percent of illegal gambling website users, compared with 3 percent of all respondents)
• finding websites that do not require me to verify my age or identity before allowing me to gamble (12 percent of illegal gambling website users, compared with 3 percent of all respondents)
• finding websites that do not require me to verify my age or identity before allowing me to gamble (12 percent of illegal gambling website users, compared with 3 percent of all respondents)
• paying with different methods than usual (11 percent of illegal gambling website users, compared with 3 percent of all respondents)
• avoiding GAMSTOP (7 percent of illegal gambling website users, compared with 2 percent of all respondents)
• avoiding Gamban (5 percent of illegal gambling website users, compared with 2 percent of all respondents).

Additionally, illegal gambling website users were more likely to name high returns (that is, high return to player (RTP) percentages) (15 percent, compared with 9 percent of all respondents) in their top 3, as well as playing or discovering new games (13 percent, compared with 5 percent of all respondents).

These findings support the qualitative evidence from Phase 1 that there are a distinct group of individuals who gamble that are motivated to do so in the illegal market because of what it provides them that is not available in the licensed market – such as if they have been banned or blocked, or if they want to gamble using a specific payment method or product that is not available in Great Britain. For others, though, the illegal market is an extension of their overall approach to gambling, in which they seek out fun, new experiences, or better rewards for winning.

Illegal gambling website users were also asked how they became aware of the website(s) they used in the last 4 weeks. Mostly, respondents used self-find methods, such as search engines (23 percent), or used websites they had gambled with before (19 percent). Social media was another key route (30 percent), particularly Facebook (14 percent), Telegram (9 percent), WhatsApp (9 percent), and to a lesser extent, Instagram (8 percent) and Reddit (7 percent). Social media was more likely to be cited by those 18 to 24 years old (41 percent), those in the AB social grade (35 percent), but also by those that had self-excluded before using GAMSTOP (55 percent), indicating a potential concern of targeted advertising.

Additionally, one tenth (10 percent) of respondents specifically cited influencers as their route into an illegal gambling website. Again, this builds on findings from the first phase that both private and open communities for people who gamble served as routes into illegal websites for those searching for knowledge and discussion around their motivations for gambling.

Where respondents either directly self-reported gambling on illegal gambling websites or demonstrated they may have done so via identification with indicators, they were asked about their gambling habits in the last 4 weeks; the majority (52 percent) reported exclusively using licensed websites. 3 in 10 (30 percent) reported they had primarily used licensed websites, with 10 percent primarily reporting having used illegal websites, though none reported using illegal websites exclusively.

Features

Among illegal gambling website users, self-reported spend was more skewed towards licensed websites, with nearly three-quarters (74 percent) reporting that in the last 4 weeks they spent more money on licensed websites than on illegal websites¹. 3 in 20 (15 percent) of this group reported an equal distribution of spend on both types of websites, and only 4 percent reported spending more on illegal websites. These findings support the qualitative evidence from Phase 1 that while engagement with illegal gambling websites exists, it is typically supplementary rather than exclusive, with most favouring spending time or money on licensed platforms.

In the online illegal market, the types of activities reported to be the most engaged in were online betting on football (30 percent), online bingo (20 percent), and online fruit, slot, or virtual gaming (19 percent).

Indicators

For this phase of the research, indicators of illegal gambling website usage were given a strength rating, from ‘near certain’ through to ‘weaker’. The ratings were based on qualitative insights from Phase 1, contextualisation of respondent understanding via their verbatim responses to Phase 2, reliance on survey design and subject matter experience on the part of Yonder and the Commission, and an awareness of potential issues with self-reporting, particularly on a topic related to illegal activity (even where the illegality is on the part of the operator, rather than the respondent). The ratings were assigned to provide the Commission with a hierarchy of indicators through which they could assess an individual’s engagement with the illegal market.

This phase of the research included 3 self-reported ‘near certain’ indicators:

• intentional use of an illegal gambling website, with the website being verified as illegal by Yonder (9 percent of the total sample reported they had ever done so)
• signing up to a gambling website without age or identity verification (10 percent of the total sample reported they had ever done so)
• cancelling a withdrawal before it reached their bank or wallet (again, 10 percent reported they had ever done so).

In addition, there were 4 self-reported ‘strong’ indicators:

• finding a way to gamble on websites using own account despite GAMSTOP ban (4 percent of the total sample reported they had ever done so)
• using a VPN specifically to access a gambling website that was not otherwise available in Great Britain (9 percent of the total sample reported they had ever done so)
• depositing cryptocurrency (such as, Bitcoin) to gamble on a website (9 percent of the total sample reported they had ever done so)
• depositing NFTs or virtual assets to gamble on a website (7 percent of the total sample reported they had ever done so).

And, finally, one self-reported ‘weaker’ indicator – depositing money on a gambling website using a credit card (23 percent of the total sample reported they had done so, ever). Although this is the most commonly reported indicator, it is important to consider the legislative context for this indicator: in 2020, the Gambling Commission banned operators from allowing customers to deposit on a gambling website using a credit card. There was some room for respondents to have engaged in this activity pre-ban if they selected ‘Yes, ever’ (as 9 percent of respondents did), thus meaning it is a weaker indicator. For the remaining 14 percent, it is possible that there were some issues with understanding of what it means to deposit using a credit card versus a debit card².

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¹Spend here refers to the amount of money deposited onto gambling websites, and does not account for any withdrawals made.

²A fifth of Brits don't know the difference between credit and debit cards (opens in new tab)

Findings

Overview

One of the Gambling Commission’s central missions is to tackle illegal gambling in Great Britain – that is, gambling with operators that are not licensed to do so by the Commission. This multi-phase, developmental research scheme, in partnership with Yonder, has been designed and carried out to enable the Commission to come to the point at which they can state their understanding of consumer engagement with the online illegal market, using indicators that an individual has gambled with an illegal operator, and understanding their motivations for doing so, for the first time.

This report focuses on Phase 2 of the research, which employed a quantitative survey with 2,046 people who gamble online (excluding National Lottery only players), to validate findings from the first phase of the research which indicatively found 4 distinct qualitative groups of illegal gambling website users: self-excluders, skilled advocates, social explorers, and accidental tourists.

The research was also designed to assess the strength of a batch of indicators of illegal gambling website usage, by testing them with a larger sample. The findings in this section of the report are structured around the 4 groups found in Phase 1; throughout, reference will be made to the strength of indicators in relation to these groups. Often, ‘stronger’ indicators, that is, those that provide the Commission with a greater deal of certainty that someone has engaged with the illegal market – correlate with the more engaged groups – self-excluders, and skilled advocates.

4 degrees of strength have been assigned to the indicators and experiences detailed in this survey: ‘near certain’, ‘strong’, ‘weaker’, and ‘adjacent’. Details on how these strengths have been defined, and how indicators have been categorised within them, will be addressed in subsequent sections.

Throughout this report, motivations, routes, features and experiences are covered. Across a sample of people who gamble online, extensive research has already helped the Commission and other stakeholders to understand the factors that feed into all 4 themes. With a view to providing a new angle on these themes, this report focuses specifically on those that were identified as having used an illegal gambling website, either through their own admission, and/or through the reporting of indicators of illegal website usage in the last 4 weeks, detailed further within this report. This group will be referred to as ‘illegal gambling website users’ in this section.

Motivations and routes into the illegal market

The first few stages of the Gambling Commission’s Path to Play framework are ‘passive influences’, ‘external triggers’ and ‘internal impulses’. To understand these triggers, influences, and impulses, this phase of the research sought to understand the types of factors that people who gamble consider when choosing a website to gamble with. This question was asked of all respondents in the survey before delving into their potential illegal gambling website usage, to get a clean, unclouded understanding of the range of motivations across the whole sample.

Motivations

Given the approach stated previously, identification with motivations and factors specifically related to the illegal market was low.

These factors included:

• accessing games or products unavailable in Great Britain
• avoiding bank gambling blocks
• avoiding stake or spend limits
• avoiding bans or account restrictions
• finding websites that do not require age or identity verification
• using alternative payment methods (for example, credit cards, cryptocurrency, NFTs)
• avoiding GAMSTOP
• avoiding Gamban.

These factors tended to be less commonly selected than broader ranging motivations in their top 3 factors when choosing a website (ranging between 2 to 4 percent), suggesting that motivations uniquely offered by the illegal market are not of high priority for most who gamble.

However, when looking at the top 3 factors for those who reported using illegal gambling websites, there were some significant differences, as shown in Table 1. These differences centre around some specific motivations for illegal website usage (for example, avoiding GAMSTOP or Gamban), whereas others concern more adjacent motivations – such as, those that do not specifically relate to illegal website usage alone, but are often a pathway into the market, as was found in Phase 1 (for example, playing or discovering new games, or high return to player (RTP) percentages).

Table 1: Top 3 factors in choosing gambling website to gamble with in last 4 weeks: all, versus illegal gambling website users

Top 3 factors in choosing gambling website to gamble with in last 4 weeks: all, versus unlicensed gambling website users

Factor in website choice in last 4 weeks (Top 3)	Total sample (respondents who had gambled online in last 4 weeks) (percentage)	Illegal gambling website users in last 4 weeks (percentage)
High returns, that is, high Return to Player (RTP) percentages	9%	15%*
Playing or discovering new games that I haven’t played before	5%	13%*
Accessing games or products not available in Great Britain	4%	16%*
Avoiding bans or account restrictions placed on me by other gambling companies	3%	12%*
Avoiding bank gambling blocks	3%	6%*
To pay with different methods than usual (for example, credit card, cryptocurrency, NFTs)	3%	11%*
Finding websites that do not require me to verify my age or identity before allowing me to gamble	3%	12%*
Avoiding GAMSTOP	2%	7%*
Avoiding Gamban	2%	5%*

A5. When choosing a website to gamble with in the last 4 weeks, which of the following are factors in your decision? Top 3 Factors. All respondents (2,046), illegal gambling website users in last 4 weeks (117).

These findings lend credence to anecdotal evidence from Phase 1 that, for people who have self-excluded from gambling, either via GAMSTOP, Gamban, or a bank gambling block¹, illegal gambling websites hold more appeal.

When it comes to the perceived importance of gambling websites to have a licence to operate in Great Britain specifically, illegal gambling website users show less strength of feeling (46 percent finding it very important, with 3 percent finding it somewhat important) compared to the total sample of respondents (62 percent very important, 25 percent somewhat important). However, it is worth noting that, even with less strength of feeling, over 8 in 10 (84 percent) of illegal gambling website users grant at least some level of importance to operators having licences in Great Britain, specifically.

Interestingly, there is seemingly a cognizance of what it means to be at least licensed somewhere, with illegal gambling website users considerably more likely (71 percent) than those without an indication of using illegal gambling websites (41 percent) to report it is important to them that operators have a licence to operate somewhere else. It is likely that, for the latter group, since their gambling activities do not expand beyond the typical, licensed scope within Great Britain, an operator’s licensing status outside of the Commission’s jurisdiction is not something that is on their radar.

Routes

This research also sought to understand the ‘active search’ stage (of the Path to Play) for individuals who gamble, in particular relation to the online illegal market. To do so, illegal gambling website users – either intentional users, or those that may have done so based on behavioural indicators – were asked for their entry route into the website(s) they used in the last 4 weeks.

Most commonly, respondents used self-find methods such as search engines (23 percent) or using websites they had gambled with before (19 percent). This validates findings from Phase 1 that demonstrated search engines were a crucial discovery tool, particularly for those that had self-excluded from gambling, to find ways around their gambling restrictions. This sentiment was reflected in engagement with the Commission’s Lived Experience Advisory Panel group.

Illegal websites are often found through communication with others, with social media being especially strong as a source (NET: 30 percent), particularly Facebook (14 percent), Telegram (9 percent), WhatsApp (9 percent), and to a lesser extent, Instagram (8 percent) and Reddit (7 percent). 3 in 20 (16 percent) found the website(s) via word of mouth, with a tenth (10 percent) specifically citing an influencer². A further 9 percent reported that the website(s) was endorsed on a gambling forum, or reached them via direct marketing, respectively. Again, this builds on findings from the first phase that both private and open communities for individuals who gamble were routes into illegal websites for those searching for knowledge and discussion around their motivations for gambling.

Social media was more likely as an entry route among those that had self-excluded using GAMSTOP (55 percent), indicating a potential concern of targeted advertising.

Age is a significant factor in the route used to an illegal website, with word of mouth (25 percent), Telegram (17 percent), WhatsApp (17 percent) and Reddit (16 percent) all statistically significantly more likely to be sources among 18 to 24-year-olds; almost 0 individuals aged 65 years and over identified these routes into the market.

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^*Statistically significant difference between the total sample and the unlicensed gambling website users at a 95 percent confidence interval.

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 website.

²The term influencers refers to individuals who promote gambling activities to others via online platforms (for example Twitch streamers, YouTube streamers, social media celebrities).

Features

Before outlining the indicators of illegal gambling website usage, which are largely experiential, it is important to understand the features of the market itself. In this subsection, there is a specific focus on illegal gambling website users.

Balance of spend and activity

As shown in Figure 1 and Figure 2, just over half (52 percent) of illegal gambling website users reported exclusively using licensed websites in the last 4 weeks. 3 in 10 (30 percent) reported primarily using licensed websites, while one tenth (10 percent) reported primarily using illegal websites, and none reported exclusively using illegal websites.

Regarding expenditure, nearly three-quarters (74 percent) of illegal gambling website users indicated they spent more on licensed websites than illegal websites in the last 4 weeks. 3 in 20 (15 percent) reported an approximately equal distribution of spending between licensed and illegal platforms, while 4 percent reported higher spending on illegal websites.

Figure 1. Balance of activity among illegal gambling website users

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

Balance of activity among unlicensed gambling website users

Current activity balance	Total (percentage)
I only used licensed websites	52%
I mainly used licensed websites	30%
I used roughly an equal mix of licensed and unlicensed websites	10%
I mainly used unlicensed websites	1%
I only used unlicensed webistes	0%
Don't know	6%

C2b. Current balance - Thinking about your gambling in the last 4 weeks, which of the following statements best reflects your gambling activity?

Base: illegal gambling website users, determined via admission or selection of hard indicators (668)

Figure 2. Balance of spend among illegal gambling website users

Balance of spend spend among unlicensed gambling websites

Current spend balance	Total (percentage)
I spent more money on licensed websites	74%
I spent roughly an equal amount of money on licensed and unlicensed websites	15%
I spent more money on unlicensed websites	4%
Don't know	6%

C2c. Current spend balance - Thinking about your gambling in the last 4 weeks, which of the following statements best reflects your spend on gambling?

Base: illegal gambling website users, determined via admission or selection of hard indicators (668)

These findings suggest that, while engagement with illegal gambling websites exists, it is typically supplementary rather than exclusive, with most favouring spending time or money on licensed platforms. No respondents reporting gambling solely on illegal websites indicates that even those who engage with illegal markets still primarily used licensed operators for most gambling activities. However, it is also possible that misreporting influenced these results, as some respondents may lack awareness of which websites are licensed.

Types of products

Illegal gambling website users were also asked about the types of gambling activities they usually take part in when using illegal websites in the last 4 weeks. The activities engaged in most commonly include online betting on football (30 percent), online bingo (20 percent), and online fruit, slot, or virtual gaming (19 percent), as shown in Figure 3.

Figure 3. Types of gambling activity usually undertaken on illegal gambling websites

Types of gambling activity usually undertaken on unlicensed gambling websites

Types of gambling activities taken part in	Total (percentage)
Online betting on football	30%
Online bingo	20%
Online fruit, slot, or virtual gaming	19%
Online betting on other sports	14%
Online poker	14%
Online betting on horse and/or dog races, including virtual	14%
Online roulette	13%
Online betting on virtual and/or e-sports	13%
Online betting on events	12%
Online card or dice games	10%
Crypto casinos	7%
Another form of online gambling	2%
None of the above	24%

C3. When you have used unlicensed websites in the last 4 weeks, what types of gambling activities do you usually take part in?

Base: Those who reported illegal gambling either directly or via hard indicators (n=668).

Additionally, those who reported playing online fruit, slot, or virtual games when gambling on illegal websites in the last 4 weeks (19 percent of illegal gambling website users) were asked about their use of the autoplay and turbo, quick spin, and slam stop features.

Among this group, nearly 3 in 5 (57 percent) of these players reported they had used an autoplay feature while on illegal gambling websites¹.

However, this was indicatively higher among those with a PGSI score of 8 or more (74 percent). The automated nature of autoplay, which enables continuous betting without manual input, may be especially appealing to those who gamble more frequently and those with a higher PGSI score, as it allows for prolonged and uninterrupted play, potentially reinforcing harmful gambling behaviours.

Turbo, quick spin and slam stop features were less commonly used by this group in comparison (35 percent). These features accelerate gameplay, reducing the time between bets and increasing the pace of gambling elements that can also contribute to higher gambling intensity. This validates the anecdotal findings of Phase 1, where some illegal gambling website users cited speed of spins as one of their experiences.

Notably, at the time of fieldwork, autoplay and/or turbo and quick spin and/or slam stop features had not yet been banned for all products, with the ban being extended to a wider range of products on the 17 January 2025². As a result, we only asked respondents about their usage of the features for online fruit, slot and virtual games, for which the feature had been banned since October 2021. However, there is still potential for confusion regarding the types of games played with this feature among participants.

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¹ Note. Base=123. Subsequent subgroup analysis is indicative due to low base sizes.

² Gambling Commission, New rules boosting safety and consumer choice

Indicators

As aforementioned, the indicators of illegal website usage in this phase of the research were assessed for their ‘strength’ – that is, the level of confidence they give the Gambling Commission in asserting that a respondent had engaged with the online illegal gambling market. They were assigned ratings of ‘near certain’, ‘strong’, ‘weaker’, or ‘adjacent’ (with the latter not being an actual indicator of illegal website usage).

These strength ratings were assigned based on:

• qualitative insight: both from Phase 1 of the research, where we gained insight into the extent to which consumers understand the behaviours they are identifying, and from verbatims accompanying survey responses in Phase 2, which in some cases disputed indicator selection (such as, the naming of cryptocurrency trading websites, rather than gambling websites)
• survey design experience (that is, acknowledging where there is scope for misinterpretation or difference within a survey code)
• issues with self-reporting, that are common when asking people to reflect on behaviours that relate to an illegal market (even if the illegality is on the part of the operator, rather than the respondent).

Table 2 shows all indicators in one place, with the more engaged subgroups of men, those aged 18 to 34, and those who gamble more frequently, shown in comparison. Across all indicators, there does not look to be a clear distinction between the types of people that gamble with licensed websites versus illegal websites; instead, the proportion of subgroups engaged with illegal websites is more often an exacerbation of groups that are already known to be more typical online gamblers (men, younger people, those who gamble more frequently).

Table 2: Indicators of illegal gambling website usage

Table 2: Indicators of unlicensed gambling website usage

Indicator	Total (NET:EVER) (percentage)	Men (percentage)	Aged 18 to 34 years (percentage)	Those that gamble online at least a few times a week (percentage)
A1. Intentionally gambled on a website without a licence to operate in Great Britain	9%	12%*	20%*	18%
A4. I still have a way or found a way to gamble on websites on my own account while signed up to GAMSTOP**	4%	4%	8%*	7%
B1. Deposited money on a gambling website using a credit card	23%	26%*	30%*	33%*
B1. Cancelled a withdrawal before it reached my bank or wallet on a gambling website	10%	12%*	16%*	19%*
B1. Signed up to a gambling website because I knew I wouldn’t need to verify my age or identity	10%	11%*	20%*	18%*
B1. Deposited cryptocurrency (such as, Bitcoin) to gamble on a website	9%	11%*	20%*	19%*
B1. Used a VPN specifically to access a gambling website that was otherwise not available in Great Britain	9%	11*%	18*%	17*%
B1. Deposited NFTs or virtual assets to gamble on a website	7%	8%	16%*	15%*

A1: Have you intentionally gambled on a gambling website that did not have a licence to operate in Great Britain?

B1: Have you ever… NET: Yes, ever.

Base: All respondents (n= 2,046), Men (1,083), 18 to 34s (694), those that gamble online at least a few times a week (878).

A3. Does and/or did GAMSTOP entirely prevent you from using gambling websites with your own account?

Base: Those who had self-excluded at some stage (223).

* Significantly higher difference verses total.

** A4 was not answered over last 4 weeks timeframe.

In the following sections the indicators are explored in further detail in relation to their strength.

‘Near certain’ indicators

Near certain indicators were categorised as such as they give as close as possible to a bona fide indication that a respondent had engaged with the illegal market: the wording of the survey responses left almost no room for doubt, the earlier phase of research and stakeholder engagement meant the Commission were confident that respondents’ understanding of what was being asked of them was accurate, and concerns about the accuracy of self-reporting (which centre on a potential lack of willingness to admit to illegal behaviour, in other cases) were as limited as possible.

This survey included 3 self-reported ‘near certain’ indicators of illegal gambling website usage, namely:

• intentionally using a gambling website that did not have a licence to operate in Great Britain (and, if they had done so in the past 4 weeks, were able to name an illegal website)
• signing up to a gambling website because they knew they wouldn’t need to verify age or identity
• cancelling a withdrawal before it reached their bank and/or wallet on a gambling website.

Each is explored in more detail.

Intentional usage

Yonder and the Commission were aware that likelihood for consumers to report intentionally using the illegal market is low, but felt it was an important step in assessing the size of the small group that are aware of the illegal market, its characteristics, and whether it is something they have engaged with. Respondents were presented with a condensed definition of the Commission’s role as the regulator in licensing operators in Great Britain to provide gambling services online, as well as being provided with context that some online gambling websites do not hold this licence from the Commission¹.

Based on this definition and context, as shown in Figure 4, a minority of respondents (9 percent) self-reported having intentionally gambled on a gambling website that did not have a licence to operate in Great Britain. Among this group, only 2 percent had done so in the last 4 weeks²; a further 5 percent had done so in the last 12 months; and a further 3 percent had done so further into the past – that is, ever³. It is worth noting here that there is seemingly a lack of awareness among respondents as to what is, and what is not a licensed website: 6 percent of those that said they had never intentionally used an illegal website had demonstrated at least some indicators of doing so in the past 4 weeks, with 22 percent having demonstrated at least some indication, ever.

This lack of comprehension was also shown in survey verbatim responses after respondents were asked to name the illegal website(s) they had used in the last 4 weeks, with a minority (38 percent⁴) able to name an illegal website, and numerous respondents mistakenly naming legitimate, licensed operators.

Figure 4. Intentional usage of illegal gambling websites

Intentional usage of unlicensed gambling websites

Intentionally gambling on a gambling website that did not have a license to operate in Great Britain…	Total (percentage)
Yes, in the past 4 weeks	2%
Yes, in the past 12 months	5%
Yes, ever	3%
Do not know	15%
Prefer not to say	1%

A1. Have you intentionally gambled on a gambling website that did not have a licence to operate in Great Britain? We want to assure you that the information you provide in this survey is completely confidential, and that individuals who gamble with illegal websites are not engaging in illegal activity.

Base: All respondents (2,046).

Some groups were more likely to report having ever intentionally used an illegal gambling website, compared to the total:

• one-third of those with 5 or more gambling accounts (32 percent) versus 9 percent of all respondents
• one-fifth of those that gamble online at least a few times a week (18 percent) versus 9 percent of all respondents.

The 2 groups detailed in the bullet points are significantly more likely to be aged 18 to 34 years, who, in turn, are more likely than other age cohorts to report intentional illegal gambling website usage (20 percent) compared to 9 percent of all respondents.

While the majority of all respondents (75 percent) reported they had never intentionally used an illegal gambling website, 3 in 20 (15 percent) responded ‘Don’t know’. They were more likely to be slightly older (aged 35 to 54 years: 18 percent), indicating an unclear picture for some respondents as to the licensing status of the website they were using.

Placing these results in the context of Phase 1, it is clear that, while a small group, there are some people who gamble online that intentionally seek out illegal websites, either to circumvent gambling blocking schemes and/or software or account bans, or because they are skilled advocates that seek them out for recreational enjoyment and reward. Though they only make up 2 percent of the total sample of individuals who gamble online, they do comprise 31 percent of illegal gambling website users in total (defined either by intentional use, or identification with other indicators, as covered earlier in this report), indicating that about a third of respondents engaging with the illegal market do so on a deliberate basis.

Signing up to a website without age or identity verification

This indicator was deemed to be near certain as wording was clear, the survey data indicated a clear understanding as shown by the low incidence of “Don’t know” answers, and using a website that did not verify age or identity is a definitive way of asserting it was not a licensed operator, as this is a fundamental requirement for the Commission to license an operator⁵.

Figure 5. Signing up to a gambling website because they knew they would not need to verify age or identity

Signing up to a gambling website because they knew they would not need to verify age or identity

Signed up to a gambling website because I knew I wouldn’t need to verify my age or identity…	Total (percentage)
Yes, in the past 4 weeks	2%
Yes, in the past 12 months	4%
Yes, ever	4%
Do not know	3%
Prefer not to say	1%

B1. Have you ever signed up to a gambling website because you knew you wouldn’t need to verify your age or identity?

Base: All respondents (2,046)

A tenth (10 percent) of respondents said they had engaged in this indicator at some point, with 2 percent in the last 4 weeks.

In addition to men, those aged 18 to 34, and those that gamble more than a few times a week – the key subgroups pulled out in Table 2 - are more likely to have engaged with indicators across the board. Those in the AB social grade (12 percent) were also more likely to have engaged with this indicator.

Cancelling a withdrawal before it reaches bank or wallet

This was deemed to be a near certain indicator due to the clarity of the statement, and the specific nature of it; although the ability to cancel a withdrawal is a fairly niche example of what is possible on an illegal website, it does relate to a relatively recent piece of legislation: requirement RTS14B which, in 2021, banned operators from giving consumers the option to cancel withdrawal requests, based on evidence that doing so correlated with greater gambling harms. It was included as a strong indicator of respondents having gambled on an illegal website due to the legislation being in place for a few years now.

Figure 6. Cancelling a withdrawal before it reached bank or wallet

Cancelling a withdrawal before it reached bank or wallet

Cancelled a withdrawal before it reached my bank on a gambling website…	Total (percentage)
Yes, in the past 4 weeks	2%
Yes, in the past 12 months	4%
Yes, ever	4%
Do not know	2%
Prefer not to say	1%

B1. Have you ever cancelled a withdrawal before it reached your bank or wallet on a gambling website?

Base: All respondents (2,046)

As with age verification, a tenth (10 percent) of respondents said they had engaged in this indicator at some point, with 4 percent in the past 12 months and with 2 percent in the last 4 weeks.

‘Strong’ indicators

Strong indicators were deemed to be slightly weaker than the ‘near certain’ ones already detailed in this report; either because there was slightly more ambiguity in the wording of an option (an example of which, is a respondent’s verbatim response citing their use of cryptocurrency for gambling, when it was in fact for a trading website). However, all the following indicators still gave the Commission a strong signal that an individual had used an illegal gambling website.

This survey included 4 self-reported ‘strong’ indicators:

• finding a way to gamble on websites using own account despite GAMSTOP ban
• using a VPN specifically to access a gambling website that was not otherwise available in Great Britain
• depositing cryptocurrency (such as, Bitcoin) to gamble on a website
• depositing NFTs and/or virtual assets to gamble on a website.

Each is explored in more detail.

Circumventing GAMSTOP⁶

GAMSTOP is a free online tool that, if someone signs up, prevents them from using gambling websites and apps run by companies licensed in Great Britain, for a period of their choosing. Given that all gambling websites operated by licensed companies in Great Britain are inaccessible during a period of being signed up, it was determined that, if someone had been able to use their own account on a gambling website during this period, it was very likely that they had used an illegal website to do so.

This code was categorised as ‘strong’, rather than ‘near certain’, due to the slightly ambiguous wording that could have confused respondents if they were unaware that the effects of GAMSTOP (that is, no access to gambling websites) can be circumvented through the use of illegal websites.

Figure 7. GAMSTOP usage and circumvention

GAMSTOP usage

GAMSTOP Usage	Total (percentage)
Yes, I am currently signed up	3%
Yes, I have signed up in the past	7%
No	87%
Do not know	3%

A3. Have you ever signed up to GAMSTOP, an online tool that restricts access to gambling websites based on personal details you share?

Base: All respondents (2,046)

GAMSTOP circumvention

GAMSTOP Circumvention	Total (percentage)
Yes, I have not gambled or did not gamble on websites on my own account while signed up	52%
No, I still have a way or found a way to gamble on websites on my own account while signed up	40%
Do not know	8%

A4. Does and/or did GAMSTOP entirely prevent you from using gambling websites with your own account?

Base: Respondents who self-exclude (223)

One-tenth (10 percent) of people who had gambled online in the last 4 weeks had ever used GAMSTOP (3 percent were signed up at the time of fieldwork, with the other 7 percent having signed up in the past). Among them, 4-in-10 (40 percent) found a way to gamble using their own account, strongly indicating illegal website usage. This means that – at an overall sample level – 4 percent of respondents who gambled online had signed up to GAMSTOP and found a way to gamble with their own account.

Using a VPN to access a gambling website not available in Great Britain

This research focused specifically on the scope of licensed websites within Great Britain – that is, those within the jurisdiction of the Commission. As such, the use of a VPN to access any website that would otherwise be blocked in Great Britain – either a website that was licensed by another country’s gambling regulator, or an entirely illegal website – was deemed to be a ‘strong’ indicator. It was deemed as ‘strong’, rather than ‘near certain’, due to the possibility for inaccurate self-reporting by those that had used VPNs to access licensed websites within the UK (to bypass blocking software at their workplace, for example).

Figure 8. Use of a VPN specifically to gamble on non-GB websites

Use of a VPN specifically to gamble on non-GB websites

Used a VPN specifically to access a gambling website that was not otherwise available in Great Britain	Total (percentage)
Yes, in the past 4 weeks	1%
Yes, in the past 12 months	4%
Yes, ever	4%
Do not know	3%
Prefer not to say	1%

B1. Have you ever used a VPN specifically to access a gambling website that was otherwise not available in Great Britain?

All respondents (2,046)

Just under a tenth (9 percent) of respondents had ever engaged with this indicator, with 1 percent having done so in the last 4 weeks.

Men, those aged 18 to 34, those who gamble more frequently, and those in the AB social grade (12 percent) are the groups more likely to have engaged in this indicator, as well as the respondents outlined in Table 3.

Among those categorised as illegal gambling website users, VPN usage to access websites not available in Great Britain was high, with 63 percent having ever done so: a fifth (22 percent) in the past 4 weeks.

Depositing cryptocurrency or NFTs to gamble

Although these were 2 separate indicators in the survey, we have treated them in tandem here due to their close relationship, and their identical status as ‘strong’ indicators. They are ‘strong’, rather than ‘near certain’ due to the potential for respondents to confuse NFT or cryptocurrency trading with gambling, as evidenced by one verbatim which named a cryptocurrency trading website⁷.

Figure 9. Depositing cryptocurrency or NFTs to gamble

Depositing cryptocurrency or NFTs to gamble

Deposited cryptocurrency (for example Bitcoin) to gamble on a website	Total (percentage)
Yes, in the past 4 weeks	2%
Yes, in the past 12 months	4%
Yes, ever	3%
Do not know	1%
Prefer not to say	1%

Deposited NFTs or virtual assets to gamble on a website

Deposited NFTs or virtual assets to gamble on a website	Total (percentage)
Yes, in the past 4 weeks	2%
Yes, in the past 12 months	3%
Yes, ever	3%
Do not know	3%
Prefer not to say	1%

B1. Have you ever deposited cryptocurrency (for example Bitcoin) NFTs or virtual assets to gamble on a website?

Base: All respondents (2,046)

Cryptocurrency deposits were cited by 9 percent of people who gamble, with 7 percent⁸ citing NFT or virtual asset deposits.

Those that had deposited NFTs or virtual assets to gamble on a website showed an average engagement of 70 percent across the other indicators, suggesting this indicator or method of depositing is deeply embedded in the online illegal market, rather than something that could be stumbled across by a casual gambling website explorer.

76 percent of respondents who used NFT deposits to gamble also used cryptocurrency deposits to gamble. Those who have used these methods are also considerably more likely to have signed up to websites because they knew they wouldn’t need to verify their age or identity and used VPNs to access websites otherwise unavailable in Great Britain, as demonstrated in Table 3. This indicates that those using Crypto and/or NFT deposits appear more likely to intentionally using the illegal market.

Table 3: Whether respondents have gambled using cryptocurrencies or NFTs vs. using a VPN or signing up without providing verification

Table 3: Whether respondents have gambled using cryptocurrencies or NFTs vs. using a VPN or signing up without providing verification

Indicator	Deposited cryptocurrency to gamble on a website (percentage)	Deposited NFTs and/or virtual assets to gamble on a website (percentage)	Total (percentage)
Used a VPN specifically to access a gambling website that was otherwise not available in Great Britain	26%*	31%*	1%
Signed up to a gambling website because I knew I wouldn’t need to verify my age or identity	32%*	37%*	2%

B1. Have you ever… NET: Yes, ever.

Base: Total (2,046), Used a VPN (184), Signed up to a gambling website to avoid verification (200)

*Significantly higher difference verses total.

‘Weaker’ indicators

Depositing money on a gambling website using a credit card was deemed to be a ‘weaker’ indicator in the context of the wider set that this report has already detailed. It was the most reported indicator (23 percent having done so ever, as shown in Figure 10).

Despite this, it is important to consider the legislative context for this indicator: in 2020, the Commission banned operators from allowing customers to deposit on a gambling website using a credit card, based on research that showed it potentially correlated with greater gambling harms⁹. Given the scale options for this question, there is some room for respondents to have engaged in this activity pre-ban if they selected ‘Yes, ever’ (as 9 percent of respondents did), thus meaning it is a weaker indicator. For the remaining 14 percent, it is possible that there were some issues with understanding of what it means to deposit using a credit card compared to a debit card¹⁰.

Figure 10. Depositing money using a credit card

Depositing money using a credit card

Deposited money on a gambling website using a credit card	Total (percentage)
Yes, in the past 4 weeks	6%
Yes, in the past 12 months	8%
Yes, ever	9%
Do not know	2%
Prefer not to say	1%

B1. Have you ever deposited money on a gambling website using a credit card?

Base: All respondents (2,046)

With the previous caveats in mind, there is still a distinct group that use credit cards to gamble with illegal gambling websites, as we found in the Phase 1 qualitative work, with one self-excluder reporting using them to borrow money to continue gambling.

It does, however, look to be an isolated indicator, again lending credence to its categorisation as weaker. Across the other 5 indicators included in question B1 (VPN, cryptocurrency, NFT, age verification, withdrawal cancellation), an average of 30 percent of reported credit card depositers had shown engagement. When comparing this to the 70 percent engagement from people who gamble using NFTs, it suggests that credit card depositing does not seem to characterise respondents that have ‘deeper’ engagement with the illegal market.

These statements were used for Phase 2 to capture a broad range of possible indicators of unlicensed gambling. However, given some of their limitations such as ambiguity of phrasing, and concerns surrounding respondent comprehension, these statements will need to be refined further during Phase 3 before they are to be included in the Commission’s GSGB.

Adjacent indicators

Also included in the survey were several ‘adjacent’ indicators, which were added to help the Commission understand how other, common occurrences within the online gambling space may correlate with actual illegal website usage. These self-reported indicators were:

• gambling online using a foreign currency (that is, not GBP)
• being unable to close an account with a gambling website
• signing up to a gambling website using someone else's personal information or payment details.

They have not been given an actual strength rating as they sit outside of the scope of the work in developing a set of indicators that ladder up to illegal website usage; rationale for their exclusion is detailed in Figure 11.

Figure 11. Adjacent indicators of illegal gambling website usage

Adjacent indicators of unlicensed gambling website usage

Been unable to close an account with a gambling website	Total (percentage)
Yes, in the past 4 weeks	1%
Yes, in the past 12 months	3%
Yes, ever	7%
Do not know	5%
Prefer not to say	1%

B1. Have you ever been unable to close an account with a gambling website?

Base: All respondents (2,046)

Adjacent indicators of unlicensed gambling website usage

Gambled online using a foreign currency (not GBP)	Total (percentage)
Yes, in the past 4 weeks	3%
Yes, in the past 12 months	5%
Yes, ever	4%
Do not know	1%
Prefer not to say	1%

B1. Have you ever gambled online using a foreign currency (not GBP)?

Base: All respondents (2,046)

Adjacent indicators of unlicensed gambling website usage

Signed up to a gambling website using someone else’s personal information or payment details	Total (percentage)
Yes, in the past 4 weeks	1%
Yes, in the past 12 months	4%
Yes, ever	3%
Do not know	1%
Prefer not to say	1%

B1. Have you ever Signed up to a gambling website using someone else’s personal information or payment details?

Base: All respondents (2,046)

Given the possibility for these behaviours and experiences to span both illegal and licensed websites, it is unsurprising that the first 2 shown in Figure 11 were the most commonly reported from the battery list of statements, outside of credit card depositing. Being unable to close an account is not something that is synonymous with an illegal website, though, in line with the qualitative findings from Phase 1, does provide an indication of the types of barriers some people who gamble face in both the licensed and illegal space.

While gambling in Great Britain with a foreign currency (that is, not GBP) is possible when using licensed websites due to operators’ activity in various overseas markets, based on feedback from those with lived experience, the Commission understands it is not particularly common for people to seek gambling with a different currency on licensed websites. Despite this limitation of the indicator, similar subgroups showed a higher propensity to have taken this action as with the main batch of indicators: men (14 percent), those aged 18 to 34 (22 percent), those that gamble at least a few times a week (21 percent), and those with 5 or more accounts (48 percent).

The third adjacent indicator, signing up to a website with someone else’s information and/or payment details, is not strictly an indicator of illegal gambling as it is possible to do this on a licensed website, if the other person’s verification information and payment details were known. For instance, respondents could have interpreted it as applying to creating a gambling account for their family member which they may also use (with or without permission). The statement sat towards the lower end of the list, reported by fewer respondents for all statements except for NFT depositing. As a behaviour, it is more tied to those at higher risk of gambling harms, rather than engagement with the illegal market, being reported by 37 percent of those with a PGSI score of 8 or more. 

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¹ The full preamble is included in Appendix 2 - Sample questionnaire.

² This percentage was determined after the re-coding of those that were unable to name an actual unlicensed website used in the last 4 weeks when they were prompted to do so.

³ Percentages do not sum to the overall 9 percent due to rounding.

⁴ 34 respondents responded when asked to name an unlicensed website – of them, 13 correctly named an unlicensed website.

⁵ Gambling Commission, Age, ID and financial verification.

⁶Note: This indicator does not fit with the usual timeframe approach of last 4 weeks, last 12 months, and ever.

⁷The website named was unlicensed, but would fall under the Financial Conduct Authority’s jurisdiction, rather than the Commission’s, thus making it out of scope.

⁸Individual responses of Yes, in the past 4 weeks (2 percent), Yes in the past 12 months (3 percent), and Yes, ever (3 percent), shown in Figure 9, do not sum to 8 percent due to rounding.

⁹Gambling Commission, 2020: Gambling on credit cards to be banned from April 2020; research from the Commission: ‘Gambling participation in 2019: behaviour, awareness and attitudes’, showed that 22 percent of online gamblers using credits cards to gamble are classed as ‘problem gamblers’.

¹⁰ A fifth of Brits don't know the difference between credit and debit cards (opens in new tab).

Conclusions

Phase 2 of this research validated the findings from the first, qualitative-focused Phase, which found 4 key audience groups that engage with the illegal market:

• self-excluders
• skilled advocates
• social explorers
• accidental tourists.

Additionally, outside of the scope of the illegal market, this study included non-users and/or non-engagers, who were notably the largest group of respondents.

Based on earlier work, an ongoing hypothesis for this phase was that many individuals who gamble that have self-excluded online do continue to gamble online, with access being the primary motivator (that is, being able to circumvent gambling blocking schemes or software that they have in place). This is a small proportion of individuals who gamble online (with 4 percent having been able to gamble online with their own account while signed up to GAMSTOP), but a significant contributing factor to the online illegal market, nonetheless.

This group are particularly vulnerable to explicit illegal marketing that focuses on ‘not being on GAMSTOP’; indeed, in this study, social media was more likely as an entry route among those that had self-excluded previously using GAMSTOP (55 percent), highlighting the validity of concern around targeted gambling advertising.

Qualitatively, skilled advocates were grouped as such due to their more in-depth participation in the online illegal market. They enjoy the variety of games and bets on offer in this market and are consciously aware that they are using a website that does not have a licence to operate from the Gambling Commission. Again, this is a relatively small group but an important one in understanding the audience types within the illegal market. The group pose an interesting challenge for quantitative research, as issues with self-reporting, both in terms of readiness to admit engagement with an illegal operator, and ability to recall specific operators, pose especially heightened challenges.

Skilled advocates typically engage in conversations with other like-minded individuals who gamble, using forums, social media and word of mouth recommendations when choosing a website to gamble with.

Social explorers were hypothesised to explore illegal websites to build bonds with family or friends based on shared interests, and trial new companies to test their odds and offers and share more widely. This was demonstrated in the second phase of the research by the higher proportion of illegal gambling website users (13 percent) that were motivated by playing or discovering new games (compared to 5 percent of the total sample). Websites’ licensing status was often not considered as a part of their decision, based on the qualitative evidence. However, social explorers did exercise caution when trying new – often illegal – websites, due to an acknowledgement that it is not as ‘safe’ of a market; generally placing lower bets and stakes as part of their exploration.

However, while licensing status is not often explicitly considered by social explorers and accidental tourists, or amongst individuals who gamble online in general, respondents agreed it is important that operators have a licence to operate in Great Britain (87 percent), with 4-in-10 (43 percent) thinking rules on gambling in Great Britain are currently at an appropriate level, and a further half (47 percent) thinking there should be more rules in place.

In this phase of the research, the hypothesis that engagement with illegal gambling websites is typically supplementary rather than exclusive was supported, with most illegal gambling website users reporting favouring spending time or money on licensed websites rather than on illegal websites. No respondents reporting gambling solely on illegal websites indicates that even those who engage with illegal markets still primarily used licensed operators for most gambling activities.

Based on this evidence and the ongoing qualitative hypothesis, there looks to be a disconnect in individuals who gamble online, between the perceived importance of operators being licensed, and an actual understanding of whether or not operators hold this licence, and how this can be verified. This lack of comprehension was also shown in survey verbatim responses after respondents were asked to name illegal websites they had used, with a minority able to name an illegal website, and numerous respondents mistakenly naming legitimate, licensed operators.

Finally, accidental tourists were thought to prioritise quick wins, better odds, and Return to Player (RTP) percentages; their approach to choosing where to gamble was as such driven by these factors, rather than novel gameplay or a need to avoid gambling blocking schemes or software, demonstrated in the aforementioned audiences. Again, as with social explorers, websites’ licensing status was not a factor in their website choice. In this phase of the research, this is demonstrated by illegal gambling website users not only being more likely to be motivated by avoiding GAMSTOP, Gamban or bank blocks, but also by higher Return to Player (15 percent, compared with 9 percent of total sample) or finding websites that do not require age or identity verification (12 percent, compared with 3 percent of total sample).

Next steps

After Phase 2, a review and refinement of indicator statements took place, addressing weaknesses such as ambiguity and accuracy limitations. These refined indicators formed the basis for a Phase 3 technical study, which was conducted to assess the strength of each illegal indicator, both individually and in combination with the others. The objective of this study was to determine the level of confidence in identifying illegal usage based on these finalised indicators.

To achieve this, an index was developed, assigning respondents a score reflecting the likelihood of their engagement with illegal websites. Details of this index and its methodology are set to be published in the Phase 3 technical report.

In Phase 4, the final set of indicators will be established and included in the Gambling Commission’s Gambling Survey of Great Britain (GSGB) to estimate population-level engagement with illegal gambling websites on an ongoing basis. Continued monitoring of emerging trends in the illegal market remains essential to ensure the continued relevance of statements and the inclusion of new indicators as they arise.

Appendices

Appendix 1 - Sample profile

Months and rates

Categories	Total sample (online gamblers in the last 4 weeks, excluding National Lottery) (percentage)	Illegal gambling website users in last 4 weeks (as determined by index approach) (percentage)
Gender
Men	53%	66%
Female	47%	33%
Age
18 to 24 years	10%	17%
25 to 34 years	19%	39%
35 to 44 years	17%	25%
45 to 54 years	18%	12%
55 to 64 years	17%	6%
65 to 74 years	13%	1%
75 years and over	7%	0%
Social grade
AB	41%	49%
C1	27%	20%
C2	16%	22%
DE	17%	9%

All respondents (n= 2,046)

Appendix 2 - Sample questionnaire

Survey date: 18-23 December

Methodology: ONLINE

Survey length: 15-minute survey

Sample: 2,000 individuals who gamble online (activity in the last 4 weeks) excluding those who only play The National Lottery

Screener, demographics and gambling behaviours

(ASK ALL)

S1. Gender

How do you identify?

SINGLECODE

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

S2. Age

Please enter your age in the box

WRITE IN SCREEN OUT: S2 less than 18

(ASK ALL)

S3. Ethnicity

To which of the following ethnic groups do you consider you belong? SINGLECODE – CODES AS PER YDS LIST

(ASK ALL) S4. SEG

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. The Chief Income Earner can be of either sex, with no preference to either.

CODES AS PER YDS USUAL PRACTICE

(ASK ALL)

S5. Socio-grader

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

SINGLECODE

INPUT BOX

(ASK ALL)

S6. Gambling activity

SHOW INTRO ON SEPARATE SCREEN

For the next series of questions, we’d like you to think about gambling activities; by gambling we mean spending money on games of chance where you can win money.

When, if ever, have you spent money on the following activities?

By ‘online’, we strictly mean ‘websites’, rather than gambling apps.

SINGLE CODE, RANDOMISE ROWS, REVEAL IN TURN (TREAT ROWS c-f AS A BLOCK)

Gambling Activity

	1. In the last 7 days	2. In the last 4 weeks	3. In the last 3 months	4. In the last 12 months	5. More than 12 months ago	6. Never spent money on this
a. Online fruit, slot, or virtual gaming
b. Online bingo
c. Online betting on horse or dog races, including virtual races
d. Online betting on football
e. Online betting on other sports, including virtual and e-sports
f. Online betting on events (e.g. political, entertainment, topical, current affairs, novelty)
g. Online roulette, card/dice games, poker, or instant win games
h. Another form of online gambling [ANCHOR]

SCREENOUT: IF ALL FROM S6_X = 3-6, THANK AND CLOSE

ASK ALL WHO HAVE GAMBLED IN L4W

S6b. Gambling frequency

Thinking about all the activities you’ve spent money on in the past 4 weeks, how often have you spent money on them?

SINGLECODE, COLUMNS, REVEAL ROWS IN TURN.

Gambling frequency

	1. Daily	2. A few times a week	3. At least once a week	4. A few times in the last 4 weeks	5. Once in the last 4 weeks	6. Can’t remember
PULL THROUGH CODES IF S6_X = 1-2

(ASK ALL) S7. PGSI

And thinking about the last 12 months…

SINGLECODE, DO NOT RANDOMISE

PGSI

	1. Almost always	2. Most of the time	3. Sometimes	4. Never
a. Have you bet more than you could really afford to lose?
b. Have you needed to gamble with larger amounts of money to get the same feeling of excitement?
c. When you gambled, did you go back another day to try to win back the money you lost?
d. Have you borrowed money or sold anything to get money to gamble?
e. Have you felt that you might have a problem with gambling?
f. Has gambling caused you any health problems, including stress or anxiety?
g. Have people criticized your betting or told you that you had a gambling problem, regardless of whether or not you thought it was true?
h. Has your gambling caused any financial problems for you or your household?
i. Have you felt guilty about the way you gamble or what happens when you gamble?

(ASK ALL)

S8. Gambling accounts

How many active online gambling accounts do you currently have, with any gambling company?

By ‘active’ we mean accounts that you have used at least once to gamble or place a bet on any online activity in the last 12 months. Please exclude any accounts you have set up exclusively to make use of a marketing or bonus offer (e.g. free bets, free spins, welcome bonus etc.).

1. 1-5
2. 6-10
3. 11-15
4. 16-20
5. More than 20
6. Don’t know

(ASK ALL)

A5. Motivations When choosing a website to gamble with in the last 4 weeks, which of the following are factors in your decision? From the following list, please rank a maximum of five factors you consider to be most key to your decision-making.

MULTICODE, RANDOMISE. CAP RESPONSES AT FIVE. USE RANKING DESIGN.

1. Avoiding GAMSTOP
2. Avoiding Gamban
3. Avoiding bank gambling blocks
4. Avoiding stake and/or spend limits
5. Avoiding bans and/or account restrictions placed on me by other gambling companies
6. Easy / quick sign-up process
7. Accessing games/products not available in Great Britain
8. Finding websites that do not require me to verify my age/identity before allowing me to gamble
9. To be able to use the best offers (including sign up offers, bonuses, free spins, free bets, etc.)
10. To have fun while gambling
11. To pay with different methods than usual (e.g. credit card, cryptocurrency, NFTs)
12. Finding the best odds
13. High returns, i.e., high Return To Player (RTP) percentages
14. Playing/discovering new games that I haven’t played before
15. Knowing my personal information and/or data is secure
16. Quick and easy withdrawals
17. Gambling with websites that are well-known
18. Having access to safer gambling tools e.g. deposit limits
19. Gambling with websites that are licensed in Great Britain
20. Knowing my funds are protected
21. Other (please specify) [ANCHOR]
22. None of the above [EXCLUSIVE, ANCHOR]

(ASK ALL)

S9. Rules view Where would you say you sit on the scale below?

Here, we mean rules put in place for gambling companies that relate to: terms and conditions of offers, maximum stake sizes and prize amounts, changes to game features, and so on. SINGLE CODE – SCALE

1. There should be fewer rules in place on gambling
3. Rules on gambling in Great Britain are currently at an appropriate level
5. There should be more rules in place on gambling
6. Don’t know [ANCHOR]

(ASK ALL)

S10. Care about licensing When choosing which website(s) to gamble with, how important is it to you whether or not they have obtained the following licence(s) to operate from a gambling regulator? Gambling websites need to get a licence from each country's gambling regulator in order to operate there. The Gambling Commission is the regulator for Great Britain.

SINGLE CODE PER ROW, REVERSE COLUMN ORDER 50/50, DO NOT RANDOMISE

Care about licensing

	1. Not at all important	2. Not very important	3. Somewhat important	4. Very Important	5. Don’t know [ANCHOR]
a. A licence to operate in Great Britain, specifically
b. A licence to operate somewhere else (i.e. in another country)

Intentional unlicensed usage

(ASK ALL)

A1. Intentional unlicensed usage

SHOW INTRO TEXT ON SEPARATE SCREEN WITH FIVE SECOND DELAY

In Great Britain, gambling websites are regulated by the Gambling Commission. As the regulator, the Commission provides licences to companies allowing them to operate in Britain if they meet a set of rules and requirements.

Sometimes, however, there are some gambling companies that operate gambling websites in Great Britain without having a licence from the Commission. These websites may have a licence to operate in a different country, or not have one at all, from any country.

THEN QUESTION ON NEXT PAGE

Have you intentionally gambled on a gambling website that did not have a licence to operate in Great Britain?

We want to assure you that the information you provide in this survey is completely confidential, and that individuals who gamble with unlicensed websites are not engaging in illegal activity.

SINGLECODE

1. Yes, in the last 4 weeks
2. Yes, in the last 12 months
3. Yes, ever
4. No, never
5. Don’t know
6. Prefer not to say

ASK IF THINKS HAS USED UNLICENSED IN L4W (A1 = 1)

A2. Website check

Which gambling website(s) have you used in the last 4 weeks that you believe do not have a licence from the Gambling Commission?

Everything you tell us is completely confidential, we’ll only use this information to check the licensing status of these companies for research purposes.

Please enter your answers in the boxes below. You do not need to fill all the boxes to go to the next question.

WRITE-IN, FIVES BOXES WITH RESPONDENTS ALLOWED TO PASS WITHOUT FILLING ALL

99. Prefer not to say

(ASK ALL)

A3. GAMSTOP

Have you ever signed up to GAMSTOP, an online tool that restricts access to gambling websites based on personal details you share?

This tool is sometimes called ‘self-exclusion’ and applies across all licensed gambling websites.

SINGLECODE

1. Yes, I am currently signed up
2. Yes, I have signed up in the past
3. No
4. Don’t know

ASK ALL WHO SELF EXCLUDE (A3 = 1-2)

A4. GAMSTOP effectiveness

[A3 = 1: Does; A3 = 2; Did] GAMSTOP entirely prevent you from using gambling websites with your own account?

SINGLECODE

1. Yes, I [A3 = 1: have not gambled; A3 = 2: did not gamble] on websites on my own account while signed up
2. No, I still [A3 = 1: have a way; A3 = 2: found a way] to gamble on websites on my own account while signed up
3. Don’t know

Indicators

(ASK ALL)

B1. Deliberate behaviours

Have you ever…

SINGLECODE COLUMNS, RANDOMISE ROWS

Deliberate behaviours

	1. Yes, in the past 4 weeks	2. Yes, in the past 12 months	3. Yes, ever	4. No, never	5. Don’t know	6. Prefer not to say
a. Used a VPN specifically to access a gambling website that was not otherwise available in Great Britain
b. Deposited cryptocurrency (e.g. Bitcoin) to gamble on a website
c. Deposited money on a gambling website using a credit card
d. Deposited NFTs / virtual assets to gamble on a website
e. Signed up to a gambling website because I knew I wouldn’t need to verify my age or identity
f. Cancelled a withdrawal before it reached my bank/wallet on a gambling website
g. Signed up to a gambling website using someone else’s personal information and/or payment details
h. Gambled online using a foreign currency (not GBP)
i. Been unable to close an account with a gambling website

LICENSING DUMMY VARIABLE (LICDUM) for survey routing

LICENSING DUMMY VARIABLE (LICDUM) for survey routing
1. NET: Unlicensed for routing	A1 = 1-3 or any from B1_a-g = 1-3
2. NET: Licensed only for routing	All not in the above criteria
3. Self-reported unlicensed	A1 = 1-3
4. Strong indicators of unlicensed	Any from B1_a-g = 1-3

Unlicensed module

ASK LICDUM = 1

C1. Intro to focus

DECAPITALISE FIRST LETTER IN ITERATION PULLED THROUGH TO QUESTION TEXT. DON’T ALLOW SKIP TO NEXT SCREEN FOR 10 SECONDS

You [LICDUM = 3: said; LICDUM = 4; indicated] previously that you [LICDUM = 3: have; LICDUM = 4; may have] gambled on a gambling website that did not have a licence to operate in Great Britain. Some of these websites may only be licensed in other countries, and some websites may not hold a licence to operate anywhere.

For the rest of the survey, we’d like you to focus your answers on the websites you were considering in your previous answers, i.e. those websites that were likely not licensed to operate in Great Britain by the British Gambling Commission. [LICDUM = 4: These are the websites where you [PULL THROUGH RANDOM RESPONSE WHERE B1_a-g = 1-3; IF MORE THAN ONE FROM B1_a-g = 1-3; among other things.]

These websites will be referred to as ‘unlicensed’ for the rest of the survey. As a reminder, everything you tell us in this survey is completely confidential.

ASK LICDUM = 4

C2. Licensing awareness

At the time, were you aware that the website(s) you used was likely not licensed by the Gambling Commission?

SINGLECODE

1. Yes
2. No
3. Don’t know
4. Prefer not to say

ASK LICDUM = 1

C2b. Current balance

Thinking about your gambling in the last 4 weeks, which of the following statements best reflects your gambling activity?

SINGLECODE

Current Balance

1	2	3	4	5	6	7
I only used licensed websites	I mainly used licensed websites	I used roughly an equal mix of licensed and unlicensed websites	I mainly used unlicensed websites	I only used unlicensed websites	Don’t know	Prefer not to say

ASK LICDUM = 1 AND C2B = 2-4, 6

C2c. Current spend balance

Thinking about your gambling in the last 4 weeks, which of the following statements best reflects your spend on gambling?

This includes only your deposit onto gambling websites, rather than any withdrawals you may have made.

SINGLECODE. AUTOCODE C2B = 1 TO C2C = 1, AUTOCODE C2B = 5 TO C2C = 3.

Current Balance

1	2	3	4	5
I spent more money on licensed websites	I spent roughly an equal amount of money on licensed and unlicensed websites	I spent more money on unlicensed websites	Don’t know	Prefer not to say

ASK LICDUM = 1

C3. Product

When you have used unlicensed websites in the last 4 weeks, what types of gambling activities do you usually take part in?

(TREAT ROWS 3-6 AS A BLOCK)

(TREAT ROWS 8 to 11 AS A BLOCK)

MULTICODE

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
6. Online betting on virtual and e-sports
7. Online betting on events (e.g. political, entertainment, topical, current affairs, novelty)
8. Online roulette
9. Online card/dice games
10. Online poker
11. Online instant win games
12. Crypto casinos
13. Another form of online gambling (please specify) [ANCHOR]
14. None of the above in the past 4 weeks [EXCLUSIVE, ANCHOR]
15. Prefer not to say [EXCLUSIVE, ANCHOR]

ASK IF YES TO ONLINE FRUIT,SLOT, OR VIRTUAL GAMING (C3 = 1)

C4. Product specifics

When you have used unlicensed websites, have you used any of the following?

MULTICODE

1. Games that offer an Autoplay feature (i.e. allow you to play multiple spins without confirming each one separately)
2. Games that offer features such as turbo, quick spin and slam stops
3. None of the above [EXCLUSIVE, ANCHOR]

ASK IF LICDUM = 1

C5. Routes

Thinking now of the unlicensed website(s) you have gambled with in the last 4 weeks, how did you become aware of them? MULTICODE, RANDOMISE, BATCH 3-7

1. I have gambled with them before [ANCHOR]
2. Via an influencer (Twitch streamers, YouTubers, celebrities, former sportspeople, etc.)
3. Facebook
4. Instagram
5. Telegram
6. Reddit
7. WhatsApp
8. Via an affiliate website

   [POP-OUT ON HOVER: Affiliate websites do not offer gambling themselves, but often promote lists of preferred gambling websites based on best odds and offers, customer reviews, and key features]

9. They were endorsed on a gambling forum
10. Through word of mouth
11. Via a search engine
12. The gambling company sponsors a football team I watched
13. Direct marketing (e.g. emails or texts) from the gambling company
14. Another way (please specify) [ANCHOR]
15. Can’t remember [EXCLUSIVE, ANCHOR]