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.
Methodology
A multi-phased approach was used within this study. The following timeline presents an outline of the methodology used. Each stage is explained in detail in the following sections.
Timeline
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March 2024 - Scoping phase
To inform the scope of the research, Yonder spoke to subject matter experts within the Gambling Commission to understand how the Commission conducts its enforcement activity and to build a better understanding of the online illegal market and its complexities. This included speaking to the Gambling Commission’s enforcement team and communications team, reviewing contact centre data and learning about the data project mentioned data project mentioned on the previous page. Yonder also spoke to members of the Gambling Commission’s Lived Experience Advisory Panel (LEAP) to inform development of research materials.
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27 March 2024 - Initial qualitative phase
Focus group with 11 members of LEAP to capture insights into the online illegal market and ways into it, and to test questionnaire content with this audience, to ensure a range of experiences and behaviours were covered.
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17 to 22 April 2024 - Quantitative phase
Online survey of 1,007 individuals who gamble online, with the aim of gathering information on potential indicators of illegal gambling and gaining consent for recontact. Respondents were asked key questions regarding their gambling activities, such as their GAMSTOP usage, and whether they believed their activity was with legal or illegal websites.
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June 2024 - Concluding qualitative phase (part 1)
10 online depth interviews with respondents who completed the online survey, with the objective to delve into their pathway into illegal gambling, recounting: levels of awareness of engagement with illegal websites, the role of regulation, whether they do any research to vet these websites, their motivations for using these websites, and attitudes towards future use of illegal websites.
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July 2024 - Concluding qualitative phase (part 2)
2 focus groups with a total of 7 individuals recruited from the Gambling Commission’s wider lived experience network, peer facilitated by members of LEAP, exploring experiences of using illegal gambling websites while registered to GAMSTOP.
Initial qualitative phase
At the start of the project, a 90-minute online focus group was conducted with 11 members of LEAP1. The aim of this stage was twofold.
- To capture insights into the illegal market and ways into it, how aware people who gamble might be that they are gambling on illegal websites and how they feel about this.
- Test questionnaire content with this audience to ensure it reflected their perceptions of the illegal gambling market in Great Britain, and to ensure the language used in the questionnaire was accessible and non-stigmatising. Respondents were sent the questionnaire ahead of the focus group to review, before feeding back on the content within the main discussion.
Members of this group were spoken to as a first step within the research because the Commission was aware that many of these individuals have direct experience of using the illegal market, and anticipated that it would likely be challenging to find a wider group of individuals with this experience, due to the perceived low prevalence of use of unlicensed illegal websites.
Quantitative phase
Yonder conducted an ad hoc online survey with a sample of 1,007 people who had gambled online at least once in the last four weeks, excluding those who only: gamble in person, play National Lottery draws, play scratch cards, or participate in private betting (that is, any combination of only these activities).
The rationale for excluding those who only play National Lottery was due to the nature of the survey content, which required some degree of understanding and engagement with typical online gambling activities such as betting, casino products, or bingo games.
Respondents were recruited to be broadly representative, using a quota-based sampling approach, with four key demographics tracked: age, gender, UK region and social grade, to match the known incidence of those who gamble as occurring in the general population using random stratified sampling frames2 .
This incidence was taken from the nationally representative ‘Cost of Living’ survey that Yonder carried out for the Commission. After fieldwork, weights were applied to the data to correct any imbalance that occurred in sampling, to exactly match the quotas. Fieldwork for the online survey took place between 17 and 22 April 2024.
The core purpose of the quantitative research was to inform the qualitative phase, by gathering information on awareness of, and potential indicators of engaging in, illegal gambling and gaining consent for recontact.
Concluding qualitative phase (part 1): depth interviews
10 respondents were recruited to take part in one-hour online depth interviews, which were conducted in June 2024. These respondents were recruited through recontacting a sub-set of individuals who took part in the quantitative survey.
Most respondents were recruited on the basis that they had either reported they had knowingly used or had suspected they had used illegal gambling websites. To this end, 8 indicators from the quantitative survey were used for recruitment purposes.
Of the behaviours we asked respondents about, the following 8 listed were determined to be less likely, or in some cases, not possible to be encountered by consumers when using legal gambling websites.
A spread of these indicators was recruited for across the sample – each of the 8 indicators are provided (in no particular order), alongside a reference to its corresponding question on the quantitative survey3 , and also a short explanation of why it was considered to be an indicator for the purpose of recruiting for the qualitative research stage.
- Used a gambling website where they did not need to provide ID or age verification upon sign up
All legal online gambling businesses must ask individuals to prove their age and identity before they gamble, for more details, see requirements for Age, ID and financial verification on The Commission's website. - Tried to access a gambling website they had used previously, but found that it had been taken down
A core role of the Commission’s Enforcement team is to make it difficult for companies to provide illegal gambling at scale to customers in Great Britain. One way of achieving this is through conducting disruption activity, which can involve shutting down illegal gambling websites. For example, from April 2023 to March 2024, the Commission’s referrals to search engines resulted in 33,316 URLs and 126 websites being removed from search engines. For more information on this, see Activity to tackle unlicensed gambling and outcomes from The Commission's Impact Metrics.
It is therefore plausible that a consumer discovering that a website they previously used has been taken down could be an indicator that it was an illegal website that was removed. - I have a VPN, and I always use it when visiting gambling websites, specifically
There are some gambling websites that are not licensed in Great Britain but are licensed in other countries. Consumers may not be able to access these websites as the website can identify that the consumers are located in Great Britain. It is possible that using a VPN specifically when accessing gambling websites could indicate that a consumer is intending to use websites that are not licensed in Great Britain. - Paid to gamble using a credit card
In Great Britain, paying to gamble using credit cards in has been banned since 2020, meaning that licensed gambling companies are not able to accept them as a payment method. For more details, see The Gambling Commission's news article on the ban. - Gambled on a foreign website and/or one where they had to change the default currency or language
Changing the payment option from a non-British Pound Sterling (GBP) currency (such as Euros) to GBP may indicate that the website has set its default language or currency to be that of its country of origin, that is, not Great Britain. This may indicate that the site, although possibly licensed in a country outside of Great Britain, is not licensed by the British Gambling Commission. - Paid to gamble using foreign currency (that is, not GBP)
Paying using a non-GBP currency (such as Euros) may indicate that the website and its core consumer base is located outside of Great Britain. This may indicate that the site, although possibly licensed in a country outside of Great Britain, is not licensed by the British Gambling Commission. - Paid to gamble using cryptocurrency
It is very unlikely that the Commission would grant licences to gambling companies that accept blockchain technology payments such as cryptocurrency from consumers, as these companies are not typically able to verify the source of their funding. Verifying a gambling company’s source of funds is a core component of reviewing a licence application, as the Commission must be assured that the company is not being funded by the proceeds of crime. Therefore, it is unlikely that a gambling website accepting cryptocurrency payments is licensed by the Commission. For more information, see the Commission’s guidance on Blockchain technology and crypto-assets. - Paid to gamble using non-fungible tokens (NFTs)
It is very unlikely that the Commission would grant licences to gambling companies that accept blockchain technology payments such as Non-Fungible Tokens (NFTs) from consumers, as these companies are not typically able to verify the source of their funding. Verifying a gambling company’s source of funds is a core component of reviewing a licence application, as the Commission must be assured that the company is not being funded by the proceeds of crime. Therefore, it is unlikely that a gambling website accepting NFT payments is licensed by the Commission. For more information, see the Commission’s guidance on Blockchain technology and crypto-assetts.
A spread of pathways into illegal gambling websites were also represented across the qualitative sample, including individuals who had found out about these websites via search engine, word of mouth, social media, gambling forums, paid advertising, and affiliate websites. Demographic profiles, Problem Gambling Severity Index (PGSI) scores, and context surrounding these respondents’ engagement in the 8 indicators and pathways into illegal websites can be found in Appendix C.
Respondents took part in a 30-minute online digital pre-task which captured details about themselves, their online gambling behaviours and preferences, and their levels of awareness and experiences of using illegal gambling websites.
Depth interviews were then conducted with these respondents to further delve into their pathway into illegal gambling, recounting levels of awareness of illegal websites, the role of regulation and whether they do any research or vetting of these websites, their positive and negative experiences, and attitudes towards future use4.
Concluding qualitative phase (part 2): focus groups
Two 90-minute focus groups were conducted online in July 2024, to understand experiences of using illegal gambling websites for those who have self-excluded from licensed gambling websites (that is, those who had used GAMSTOP in the past).
Unlike with the depth interviews, these focus groups took a peer-to-peer approach, meaning these sessions were facilitated by LEAP members. The LEAP facilitators were provided with a condensed discussion guide containing core objectives and a short list of questions for the session. They were thus less prescriptive than the depth interview sessions, which allowed the discussion to develop more organically. It also helped ensure that respondents felt at ease by being interviewed by someone they already knew, who could directly relate to their experiences5.
Respondents for these focus groups were recruited through the Gambling Commission’s wider lived experience network rather than recontacted from the quantitative survey. Respondents consisted of members of gambling support groups, who the LEAP facilitators were already connected with. This approach was taken primarily due to ethical considerations: Yonder and the Commission felt that in order to explore this sensitive topic appropriately, risk of harm to respondents needed to be minimised and therefore, a higher level of safeguarding protections needed to be available.
To participate, respondents were required to have gambled online and used an illegal gambling site 12 months ago or more, that is, within a recent enough period to recall experiences, but not so recent as to risk harm or distress during the focus groups.
During recruitment, potential respondents were provided with a list of the topics and questions that would be covered during the session. This was to ensure they had time to consider their levels of comfort in answering these questions beforehand.
Respondents met with their respective LEAP facilitators prior to, and after their sessions to receive additional peer support.
After the focus group session, respondents were provided with a support sheet, which contained prompts to encourage self-care, resources for confidential professional support services, and the contact details of the Commission’s Lived Experience Coordinator, who was present during the sessions and available for support both before and after.
The first focus group consisted of 4 respondents and was an all-female sample, ensuring coverage of a female perspective as this can be underrepresented in gambling research. The second group consisted of 3 male respondents.
Discussions revolved around online gambling activity (including preferred activities, providers, and pathways in) as well as experiences of using unlicensed gambling websites while registered to GAMSTOP.
References
1LEAP is a panel of individuals who have experienced gambling harm in the past. It provides advice, evidence and recommendations to the Commission to inform decision making and raise standards. More information on LEAP can be found on the Commission's governance committees and boards page.
2 See Appendix A for quota table.
3 See Appendix B for the quantitative survey.
4 The discussion guide used in these depth interviews is included in Appendix D.
5 The discussion guide used in these focus groups is included in Appendix E.
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Last updated: 18 September 2025
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