Report
Illegal online gambling - Phase 2: Identifying indicators of consumer engagement with illegal gambling websites
The Gambling Commission's report on the second phase of the Consumer Voice illegal gambling project.
Contents
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.
References
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.
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Executive summary - Illegal online gambling: Phase 2
Last updated: 18 September 2025
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