Report
Illegal online gambling - Phase 1: Exploring consumer pathways into using illegal gambling websites
The Gambling Commission's report on the first phase of the Consumer Voice illegal gambling project.
How to read this report
For the purposes of reporting, the narrative has been structured to largely focus on the consumer pathways uncovered by the qualitative phases, rather than exploring the quantitative data question by question. For more detailed insight into quantitative findings, please refer to the data tables which will be published at a later date.
The guidance set out in the following paragraphs is designed to help anyone who wishes to use data from this report to ensure it is interpreted and reported correctly.
Findings from this study can be used to:
- look at patterns within the data amongst different demographic groups
- highlight a range of attitudes and behaviours of some individuals who use illegal online gambling websites
- explore common motivations for using illegal online gambling websites and the range of pathways used when accessing the illegal market.
This research consisted of an online self-reporting survey conducted by Yonder, which focused on a sub-sample of people who gamble online. This specific sample of people was chosen as it was determined that their insight and perceptions would be most relevant to the objectives of the study. Therefore, the views and experiences voiced by our sample may not be representative of either the general British population or the wider gambling community.
Therefore, findings from this study should not be used to:
- calculate a population-level incidence rate of engagement in the online illegal gambling market
- gross up Problem Gambling Severity Index (PGSI) findings to population-level estimates.
Sample sizes used within the qualitative stages of the research are small by nature and represent the views of several sub-groups of those who gamble online, such as: self-excluded individuals and those who may use illegal websites. Therefore, insights from these stages should be taken as exploratory rather than conclusive. Quotes included from these stages serve to illustrate key points and should not be taken as representing the views of all respondents.
Terminology used
Specific terminology is used within this report, the definitions and the rationale behind them can be found in the following sections.
GAMSTOP: A free tool that allows people to self-exclude from all licensed gambling websites in Great Britain. More information can be found on the "About GAMSTOP" page on GAMSTOP website (opens in new tab) .
PGSI: Problem Gambling Severity Index, a screening tool which measures ‘problem gambling’, that is, gambling to a degree that compromises, disrupts, or damages family, personal or recreational pursuits. A PGSI score of 8 and over represents problem gambling by which a person will have experienced adverse consequences from gambling and may have lost control of their behaviour. A PGSI score of 3 to 7 represents moderate risk gambling. A PGSI score of 1 to represents low risk gambling. For more details on the PGSI, see the Commission’s report on Problem gambling screens.
Unlicensed gambling: Terminology used throughout this report to describe gambling websites and providers which are not licensed by the Gambling Commission1, for more details on the requirements for a gambling company to obtain a licence, see the Licence Conditions and Codes of Practice (LCCP).
During the scoping phase of the study, alternative terms that are commonly used within gambling research and lived experience communities were considered for use with consumers: primarily, ‘unlicensed’, ‘unregulated’, and ‘illegal’. However, desk research, stakeholder engagement, and conversations with those with lived experience led the Commission to the decision that ‘unlicensed’ was the most suitable term to be used when discussing this topic with consumers and those with lived experience.
Using the term ‘illegal gambling’ when speaking to individuals would be problematic for several reasons. The term ‘illegal’ can imply that the individuals engaging with unlicensed gambling websites are behaving unlawfully, when in fact, it is the gambling companies that are conducting illegal activities by not complying with the regulations in Great Britain. Building on this, engagement with Lived Experience Advisory Panel (LEAP) revealed that people who gamble may find the term ‘illegal gambling’ to be stigmatising, and subsequently be less inclined to be honest about their experiences with the illegal market if they have the misperception that they could be penalised for engaging with it.
For some, the term ‘unregulated gambling’ may be perceived to refer to gambling activities not being subject to certain laws or regulations, and that there is not a governing body responsible for ensuring the safety of consumers. An example of an ‘unregulated’ gambling activity would be non-commercial private betting between friends and family, as this activity is not regulated by the Commission or by any other governing body. Therefore, the term ‘unregulated’ does not provide enough clarity for consumers; not all unregulated gambling activities in Great Britain are considered to be ‘unlicensed’ or ‘illegal’ by the Commission or by other bodies.
For reporting purposes, the term ‘illegal gambling’, however provides a clearer definition: gambling companies that offer their products to consumers in Great Britain without having obtained the necessary licence from the Gambling Commission to do so.
Limitations
While Yonder took care to ensure the robustness of the findings through the research design and application, there are a number of limitations which should be considered when reading this report.
All insights gathered from this study are based on self-reported behaviour rather than observed behaviour, meaning insight is limited to what respondents felt comfortable revealing to us in the research setting.
Furthermore, as respondents could struggle to identify whether they had in fact used a licensed or unlicensed website, this can impact the accuracy of their recall. For self-excluded individuals (registered to GAMSTOP), all had previously used these websites over 12 months prior to the research, which could also impact the accuracy of recalled behaviours and experiences.
Quantitative
The questionnaire was designed to inform the qualitative phase by gathering information on awareness and potential indicators of engaging in illegal gambling among those who gamble online. As a result, a range of potential indicators of illegal gambling were included. These are not definitive indications that someone has used an illegal website. In fact, some potential indicators included have more potential to occur both when using licensed and illegal websites – for example, difficulties with withdrawing winnings can also occur when using licensed websites.
However, the questionnaire was designed in this exploratory way to provide a wealth of sample information – including less conclusive occurrences such as withdrawal issues, and the eight potential indicators for the qualitative phase, which Yonder used to provide the Commission with more depth of understanding on the pathways into illegal gambling, and the potential pull and/or push factors. Yonder defined a set of eight potential indicators of unlicensed gambling (for example, paying to gamble on a website using a credit card) that are less likely, or in some cases, not possible to occur on licensed websites. This helped inform recruitment criteria to ensure the subsequent qualitative phase spoke to those using unlicensed websites.
This approach did mean, however, that landing on an incidence rate for illegal gambling was not within the scope of this research. This may serve as a potential area of focus for upcoming research with the Commission, now that the qualitative phase has provided the sufficient depth of understanding into this element of the sector.
General limitations of quantitative research: results provide a snapshot of attitudes and opinions but provide little insight into why respondents feel the way they do, and the specific drivers behind responses. Hence, the overall research design including a qualitative element to allow deeper insight into the ‘why’ behind respondents’ responses. Further, respondents were provided with pre-coded lists of responses which may not have captured the full range of responses that exist. To mitigate against this, open-ended responses were also included to allow respondents to provide more detail on the reasons for their responses.
Qualitative
Qualitative sample sizes are by their nature small, so conclusions can only be directional, unless contextualised by quantitative data. For example, depth interviews were conducted largely with individuals who have recently used illegal websites. As a result, they may be more likely to have positive perceptions and experiences of these websites compared to those who previously used them, but don’t currently. Therefore, their opinions should not be taken to be representative of those who gamble online as a population.
Qualitative research heavily relies on the skills and experience of researchers, which can introduce potential researcher bias. This is mitigated by employing a grounded theory approach, using excel grids to capture qualitative data and notes and developing narratives through rigorous analysis of this data.
A next step within a further phase of research into this topic will be to further contextualise the qualitative findings, with further quantitative validation.
References
1Within this definition of illegal websites, there remains the possibility that some of these websites may be licensed elsewhere, that is, in other markets outside of Great Britain.
Methodology - Illegal online gambling: Phase 1 Next section
Executive summary - Illegal online gambling: Phase 1
Last updated: 18 September 2025
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