Report
Illegal online gambling: Consumer engagement and trends
The Gambling Commission’s report into estimated trends in consumer engagement with illegal gambling websites.
Part 4 - Assumptions on use of Virtual Private Networks (VPNs)
Key point summary
Key points in this section are as follows:
- some web traffic to illegal gambling websites will be hidden by use of Virtual Private Networks (VPNs)
- in addition, consumers using websites which are licensed in other jurisdictions and correctly geo-block consumers from Great Britain will also be hidden by use of VPNs
- we use findings from our Consumer Voice research to make an assumption about the proportion of traffic which could be hidden by VPNs
- web traffic estimates are increased by between 24 and 51 percent to account for missing VPN traffic.
The data obtained from Similarweb represents an estimate of visits from consumers accessing these websites from Great Britain. This means that any individuals accessing these websites from Great Britain while using a VPN are not likely to be captured within our estimates.
Similarweb attempts to account for VPN use by attributing a visit to the country from which they detect an individuals’ first visit of the day. For example, if someone from country A logs onto their computer and visits a website, and then later connects to their VPN (routing their traffic through country B) and visits more websites throughout the day, all website visits for the entire day will be attributed to country A. This would partially account for VPN traffic, but if an individual always has a VPN on, or activates their VPN before accessing any websites, their traffic would not be attributed to the correct country.
As part of our Consumer Voice research into the online illegal market, a survey was conducted where participants were asked about their use of VPNs both in general and specifically when using gambling websites. This question asked, “A Virtual Private Network (VPN) can protect your online identity by hiding your IP address when using the internet. Thinking of the last 12 months, which of the following statements best applies to you?”. Of those respondents who report to know and admit to usage of unlicensed websites, 26 percent use a VPN either all the time, or specifically when visiting gambling websites. Further detail on responses can be found in Annex C.
These findings give useful insights into consumers use of VPNs specifically for gambling, but it should be noted that it is based on a relatively small sample and may not be representative of all individuals who use illegal gambling websites. Because of this, a 95 percent confidence interval can be constructed to reflect the uncertainty around the findings from the small sample. This results in between 19 and 34 percent of individuals using a VPN all the time, or specifically to visit gambling websites. Applying this to our web traffic data, it would imply that our current data accounts for between 66 and 81 percent of consumers visiting gambling websites. To scale this up to account for 100 percent of traffic, including those using a VPN, we would need to use a multiplier of between 1.24 and 1.51 times our current figures.
For context, a recent study on the illegal gambling market in France surveyed over 11,000 adults in 2023. It found that of the respondents identified as having engaged in illegal gambling online, 35 percent said they used a VPN to do so, suggesting that an estimate based on non-VPN web traffic would need to be increased by about 54 percent. This is only slightly higher than the upper bound of the confidence interval generated from our consumer research. The online legal market is significantly more restricted in France than it is in Great Britain, meaning it may be more likely that individuals will use a VPN to access gambling websites that are illegal in France.
We have noted that consumer behaviour around VPN use is undergoing a period of change related to implementation of the Online Safety Act. It will be important to monitor what impact this has over future months of data collection.
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Illegal gambling: Consumer engagement and trends - Conclusions
Last updated: 30 September 2025
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