Report
Illegal gambling - Phase 4: Initial findings from new data on consumer engagement with illegal gambling websites
The initial findings from new data on consumer engagement with illegal gambling websites.
The Illegal Gambling Index
The Index uses survey responses to 7 indicators that reflect behaviours associated with use of illegal gambling websites. To reflect differing levels of confidence that an indicator represents engagement with an illegal gambling website, each indicator was assigned a strength rating8.
‘Near Certain’ indicators
The following indicators were assigned a ‘Near Certain’ strength rating.
Used a gambling website that was not on Gamstop – This was deemed a near certain indicator because all online licensed gambling operators in Great Britain are required to participate in Gamstop. If a gambling website is not registered with Gamstop, it is operating illegally.
Signed up to a gambling website because you knew you wouldn’t need to verify your age or identity - Using a website that does not verify age or identity is a near certain indication that the website is not being run by a licensed operator, as age and identity verification are fundamental requirements for Gambling Commission licensed operators.
Cancelling a withdrawal before it reached their bank and/or wallet on a gambling website – This is a feature that can be available on illegal gambling websites. Remote Technical Standards (RTS) 14B, introduced in 2021 prohibited gambling operators from allowing customers to cancel withdrawal requests following evidence that this practice was associated with increased gambling-related harm. As the requirement has been in place for several years now, this was considered a near-certain indicator of engagement with an illegal gambling website.
‘Strong’ indicators
The following indicators were assigned a ‘Strong’ strength rating.
Used a Virtual Private Network (VPN) specifically to access a gambling website that was not otherwise available in Great Britain – This was considered a strong indicator because the use of a VPN to access a website that would otherwise be blocked in Great Britain, whether a website licensed by another country’s gambling regulator or an entirely illegal website, provides a strong indication of illegal gambling. It was classified as strong, rather than near certain, due to the possibility of inaccurate self-reporting by respondents who had used VPNs to access websites licensed within Great Britain (for example, to bypass workplace internet restrictions).
Placed a bet and/or played a game on a gambling website using cryptocurrency (for example, Bitcoin) and Placed a bet and/or played a game on a gambling website using Non-Fungible Tokens (NFTs) or virtual assets – These indicators were considered strong, rather than near certain because respondents confuse NFT or cryptocurrency trading with gambling, as evidenced in earlier phases of this research.
‘Weaker’ indicator
The following indicator was assigned a ‘Weaker’ strength rating.
Placed a bet and/or played a game on a gambling website using money directly from your credit card (that can be paid off each month) – It’s 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, meaning that respondents reporting using a credit card to gamble, may be doing so on illegal gambling websites. However, it is important to acknowledge that respondents may have issues with recall of when they exhibited this behaviour, meaning it could have fallen in or outside of the window in which the behaviour is specifically indicative of usage of an illegal website. Additionally, it is possible that respondents could also be misunderstanding credit card versus debit card use. Research conducted by MoneySuperMarket (opens in new tab) found that as much as a quarter of British people do not know the difference between a credit and debit card. This could potentially lead to respondents misreporting their credit card depositing behaviours, decreasing the reliability of credit card usage as an indicator of illegal gambling.
Index scores are assigned in relationship to one another, based on strength. For calculating the Gambling Survey for Great Britain (GSGB) illegal gambling index:
- indicators rated as ‘Near Certain’ were assigned a score of 3
- indicators rated as ‘Strong’ were assigned a score of 2
- the indicator rated as ‘Weaker’ was assigned a score of 1.
To account for recall bias, scores are weighted according to when the behaviour was reported:
- within the past 4 weeks: 100% of assigned score
- within the past 12 months: 50% of the assigned score
- more than 12 months ago: 25% of assigned score
- never: 0.
Based on these strength ratings, the maximum feasible index score obtained when a respondent reports all 7 indicators in the past 4 weeks is 16 as shown in Table 1.
Table 1: Strength ratings given to indicators
| Indicator | Not on Gamstop | VPN | Crypto | Credit card | NFTs | Verification | Withdrawal cancellation |
|---|---|---|---|---|---|---|---|
| Strength | Near certain | Strong | Strong | Weaker | Strong | Near certain | Near certain |
| Past 4 weeks | 3 | 2 | 2 | 1 | 2 | 3 | 3 |
| Past 12 months | 1.5 | 1.0 | 1.0 | 0.5 | 1.0 | 1.5 | 1.5 |
| More than 12 months ago | 0.75 | 0.50 | 0.50 | 0.25 | 0.50 | 0.75 | 0.75 |
| Never | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
To create an easy-to-comprehend, single metric ranging from 0 to 100, scores are multiplied by 6.25 (100 divided by 16). Consequently, a respondent reporting all 7 indicators within the past 4 weeks would receive the maximum index score of 100.
Given the strength ratings assigned and the maximum combination of these totaling 100, the index calculations are show in Table 2.
Table 2: Index calculations for the indicators
| Indicator | Not on Gamstop | VPN | Crypto | Credit card | NFTs | Verification | Withdrawal cancellation |
|---|---|---|---|---|---|---|---|
| Strength | Near certain | Strong | Strong | Weaker | Strong | Near certain | Near certain |
| Initial rating | 3 | 2 | 2 | 1 | 2 | 3 | 3 |
| Multiplication factor | 6.25 | 6.25 | 6.25 | 6.25 | 6.25 | 6.25 | 6.25 |
| Past 4 weeks | 18.75 | 12.50 | 12.50 | 6.25 | 12.50 | 18.75 | 18.75 |
| Past 12 months | 9.38 | 6.25 | 6.25 | 3.13 | 6.25 | 9.38 | 9.38 |
| More than 12 months ago | 4.69 | 3.13 | 3.13 | 1.57 | 3.13 | 4.69 | 4.69 |
| Never | 0.0 | 0.0 | 0.0 | 0.0 | 0.0 | 0.0 | 0.0 |
Based on the strength of the ratings, 4 categories can be developed from the scoring:
Those who have engaged with illegal gambling websites in the past 4 weeks - Respondents who demonstrate at least 1 ‘Near certain’ indicator or 2 ‘Strong’ indicators within the past 4 weeks. This corresponds to meeting an index score of 18.75 when considering the past 4 weeks’ responses only.
Those who engaged with illegal gambling websites in the past 12 months - Where the past 4 week threshold isn’t met, indicators reported within the past 12 months are incorporated at a progressively lower strength rating to reflect the reduced recency of the reported behaviour. Respondents whose score then reaches the index threshold of 18.75 are assigned to this qualifying timeframe.
Those demonstrating limited indications – This includes respondents who report 1 or more indicators, but whose combination of indicator strength and recency does not reach the qualifying criteria for being categorised as an illegal gambling website user in the past 4 weeks or past 12 months. This may reflect either a score of below the 18.75 index threshold, or indicators that are historic (more than 12 months ago).
No indications – Respondents with a score of 0 who demonstrate no indication of engaging with illegal gambling websites.
Note on limited indications category
Within the GSGB, respondents were offered a ‘More than 12 months ago’ response option to ensure that those whose behaviour occurred several years earlier had an appropriate response available. However, because these responses relate to less recent activity and are more susceptible to recall error, they should be treated with caution.
Additionally, some indicators related to regulatory changes for licensed gambling websites that occurred years ago, such as the banning of credit card gambling and customers being able to cancel withdrawals. These changes were introduced in 2020 and 2021 respectively, so some respondents may report engaging in these behaviours prior to the bans occurring. For example, a respondent who recalls using a credit card on a gambling website 10 years ago may select ‘More than 12 months ago’, but this behaviour would not necessarily indicate illegal gambling website use as it occurred before this capability was banned on licensed gambling websites.
Some respondents in this category may achieve the 18.75 index score threshold, even after accounting for the reduced weighting and timeframe of the indicators they reported. However, where all relevant indicators relate solely to behaviours that occurred more than 12 months ago, these respondents remain classified within this category and are not considered illegal gambling website users.
It is important to note that although the Commission will publish findings relating to those demonstrating limited indications of engagement with illegal gambling websites, this is primarily for completeness of reporting. Interpretation and discussion should focus on respondents who meet the threshold for likely illegal gambling website use, rather than those in the limited indications category.
Further details of the rationale for the survey questions and approach taken for the illegal gambling composite index (including strengths and limitations) can be found in the technical report technical report.
Strengths and limitations of the GSGB can also be found in the Gambling Survey for Great Britain technical report.
References
8 Strength ratings were assigned based on quantitative and qualitative insights, survey methodology expertise, and evidence on the limitations of self-reported behaviours, particularly where responses may reflect confusion or differing interpretations.
Data collection
Last updated: 5 November 2026
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