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
Indicators
As aforementioned, the indicators of illegal website usage in this phase of the research were assessed for their ‘strength’ – that is, the level of confidence they give the Gambling Commission in asserting that a respondent had engaged with the online illegal gambling market. They were assigned ratings of ‘near certain’, ‘strong’, ‘weaker’, or ‘adjacent’ (with the latter not being an actual indicator of illegal website usage).
These strength ratings were assigned based on:
- qualitative insight: both from Phase 1 of the research, where we gained insight into the extent to which consumers understand the behaviours they are identifying, and from verbatims accompanying survey responses in Phase 2, which in some cases disputed indicator selection (such as, the naming of cryptocurrency trading websites, rather than gambling websites)
- survey design experience (that is, acknowledging where there is scope for misinterpretation or difference within a survey code)
- issues with self-reporting, that are common when asking people to reflect on behaviours that relate to an illegal market (even if the illegality is on the part of the operator, rather than the respondent).
Table 2 shows all indicators in one place, with the more engaged subgroups of men, those aged 18 to 34, and those who gamble more frequently, shown in comparison. Across all indicators, there does not look to be a clear distinction between the types of people that gamble with licensed websites versus illegal websites; instead, the proportion of subgroups engaged with illegal websites is more often an exacerbation of groups that are already known to be more typical online gamblers (men, younger people, those who gamble more frequently).
Table 2: Indicators of illegal gambling website usage
| Indicator | Total (NET:EVER) (percentage) |
Men (percentage) |
Aged 18 to 34 years (percentage) |
Those that gamble online at least a few times a week (percentage) |
|---|---|---|---|---|
| A1. Intentionally gambled on a website without a licence to operate in Great Britain | 9% | 12%* | 20%* | 18% |
| A4. I still have a way or found a way to gamble on websites on my own account while signed up to GAMSTOP** | 4% | 4% | 8%* | 7% |
| B1. Deposited money on a gambling website using a credit card | 23% | 26%* | 30%* | 33%* |
| B1. Cancelled a withdrawal before it reached my bank or wallet on a gambling website | 10% | 12%* | 16%* | 19%* |
| B1. Signed up to a gambling website because I knew I wouldn’t need to verify my age or identity | 10% | 11%* | 20%* | 18%* |
| B1. Deposited cryptocurrency (such as, Bitcoin) to gamble on a website | 9% | 11%* | 20%* | 19%* |
| B1. Used a VPN specifically to access a gambling website that was otherwise not available in Great Britain | 9% | 11*% | 18*% | 17*% | B1. Deposited NFTs or virtual assets to gamble on a website | 7% | 8% | 16%* | 15%* |
A1: Have you intentionally gambled on a gambling website that did not have a licence to operate in Great Britain?
B1: Have you ever… NET: Yes, ever.
Base: All respondents (n= 2,046), Men (1,083), 18 to 34s (694), those that gamble online at least a few times a week (878).
A3. Does and/or did GAMSTOP entirely prevent you from using gambling websites with your own account?
Base: Those who had self-excluded at some stage (223).
* Significantly higher difference verses total.
** A4 was not answered over last 4 weeks timeframe.
In the following sections the indicators are explored in further detail in relation to their strength.
‘Near certain’ indicators
Near certain indicators were categorised as such as they give as close as possible to a bona fide indication that a respondent had engaged with the illegal market: the wording of the survey responses left almost no room for doubt, the earlier phase of research and stakeholder engagement meant the Commission were confident that respondents’ understanding of what was being asked of them was accurate, and concerns about the accuracy of self-reporting (which centre on a potential lack of willingness to admit to illegal behaviour, in other cases) were as limited as possible.
This survey included 3 self-reported ‘near certain’ indicators of illegal gambling website usage, namely:
- intentionally using a gambling website that did not have a licence to operate in Great Britain (and, if they had done so in the past 4 weeks, were able to name an illegal website)
- signing up to a gambling website because they knew they wouldn’t need to verify age or identity
- cancelling a withdrawal before it reached their bank and/or wallet on a gambling website.
Each is explored in more detail.
Intentional usage
Yonder and the Commission were aware that likelihood for consumers to report intentionally using the illegal market is low, but felt it was an important step in assessing the size of the small group that are aware of the illegal market, its characteristics, and whether it is something they have engaged with. Respondents were presented with a condensed definition of the Commission’s role as the regulator in licensing operators in Great Britain to provide gambling services online, as well as being provided with context that some online gambling websites do not hold this licence from the Commission1.
Based on this definition and context, as shown in Figure 4, a minority of respondents (9 percent) self-reported having intentionally gambled on a gambling website that did not have a licence to operate in Great Britain. Among this group, only 2 percent had done so in the last 4 weeks2; a further 5 percent had done so in the last 12 months; and a further 3 percent had done so further into the past – that is, ever3. It is worth noting here that there is seemingly a lack of awareness among respondents as to what is, and what is not a licensed website: 6 percent of those that said they had never intentionally used an illegal website had demonstrated at least some indicators of doing so in the past 4 weeks, with 22 percent having demonstrated at least some indication, ever.
This lack of comprehension was also shown in survey verbatim responses after respondents were asked to name the illegal website(s) they had used in the last 4 weeks, with a minority (38 percent4) able to name an illegal website, and numerous respondents mistakenly naming legitimate, licensed operators.
Figure 4. Intentional usage of illegal gambling websites
| Intentionally gambling on a gambling website that did not have a license to operate in Great Britain… | Total (percentage) |
|---|---|
| Yes, in the past 4 weeks | 2% |
| Yes, in the past 12 months | 5% |
| Yes, ever | 3% |
| Do not know | 15% |
| Prefer not to say | 1% |
A1. Have you intentionally gambled on a gambling website that did not have a licence to operate in Great Britain? We want to assure you that the information you provide in this survey is completely confidential, and that individuals who gamble with illegal websites are not engaging in illegal activity.
Base: All respondents (2,046).
Some groups were more likely to report having ever intentionally used an illegal gambling website, compared to the total:
- one-third of those with 5 or more gambling accounts (32 percent) versus 9 percent of all respondents
- one-fifth of those that gamble online at least a few times a week (18 percent) versus 9 percent of all respondents.
The 2 groups detailed in the bullet points are significantly more likely to be aged 18 to 34 years, who, in turn, are more likely than other age cohorts to report intentional illegal gambling website usage (20 percent) compared to 9 percent of all respondents.
While the majority of all respondents (75 percent) reported they had never intentionally used an illegal gambling website, 3 in 20 (15 percent) responded ‘Don’t know’. They were more likely to be slightly older (aged 35 to 54 years: 18 percent), indicating an unclear picture for some respondents as to the licensing status of the website they were using.
Placing these results in the context of Phase 1, it is clear that, while a small group, there are some people who gamble online that intentionally seek out illegal websites, either to circumvent gambling blocking schemes and/or software or account bans, or because they are skilled advocates that seek them out for recreational enjoyment and reward. Though they only make up 2 percent of the total sample of individuals who gamble online, they do comprise 31 percent of illegal gambling website users in total (defined either by intentional use, or identification with other indicators, as covered earlier in this report), indicating that about a third of respondents engaging with the illegal market do so on a deliberate basis.
Signing up to a website without age or identity verification
This indicator was deemed to be near certain as wording was clear, the survey data indicated a clear understanding as shown by the low incidence of “Don’t know” answers, and using a website that did not verify age or identity is a definitive way of asserting it was not a licensed operator, as this is a fundamental requirement for the Commission to license an operator5.
Figure 5. Signing up to a gambling website because they knew they would not need to verify age or identity
| Signed up to a gambling website because I knew I wouldn’t need to verify my age or identity… | Total (percentage) |
|---|---|
| Yes, in the past 4 weeks | 2% |
| Yes, in the past 12 months | 4% |
| Yes, ever | 4% |
| Do not know | 3% |
| Prefer not to say | 1% |
B1. Have you ever signed up to a gambling website because you knew you wouldn’t need to verify your age or identity?
Base: All respondents (2,046)
A tenth (10 percent) of respondents said they had engaged in this indicator at some point, with 2 percent in the last 4 weeks.
In addition to men, those aged 18 to 34, and those that gamble more than a few times a week – the key subgroups pulled out in Table 2 - are more likely to have engaged with indicators across the board. Those in the AB social grade (12 percent) were also more likely to have engaged with this indicator.
Cancelling a withdrawal before it reaches bank or wallet
This was deemed to be a near certain indicator due to the clarity of the statement, and the specific nature of it; although the ability to cancel a withdrawal is a fairly niche example of what is possible on an illegal website, it does relate to a relatively recent piece of legislation: requirement RTS14B which, in 2021, banned operators from giving consumers the option to cancel withdrawal requests, based on evidence that doing so correlated with greater gambling harms. It was included as a strong indicator of respondents having gambled on an illegal website due to the legislation being in place for a few years now.
Figure 6. Cancelling a withdrawal before it reached bank or wallet
| Cancelled a withdrawal before it reached my bank on a gambling website… | Total (percentage) |
|---|---|
| Yes, in the past 4 weeks | 2% |
| Yes, in the past 12 months | 4% |
| Yes, ever | 4% |
| Do not know | 2% |
| Prefer not to say | 1% |
B1. Have you ever cancelled a withdrawal before it reached your bank or wallet on a gambling website?
Base: All respondents (2,046)
As with age verification, a tenth (10 percent) of respondents said they had engaged in this indicator at some point, with 4 percent in the past 12 months and with 2 percent in the last 4 weeks.
‘Strong’ indicators
Strong indicators were deemed to be slightly weaker than the ‘near certain’ ones already detailed in this report; either because there was slightly more ambiguity in the wording of an option (an example of which, is a respondent’s verbatim response citing their use of cryptocurrency for gambling, when it was in fact for a trading website). However, all the following indicators still gave the Commission a strong signal that an individual had used an illegal gambling website.
This survey included 4 self-reported ‘strong’ indicators:
- finding a way to gamble on websites using own account despite GAMSTOP ban
- using a VPN specifically to access a gambling website that was not otherwise available in Great Britain
- depositing cryptocurrency (such as, Bitcoin) to gamble on a website
- depositing NFTs and/or virtual assets to gamble on a website.
Each is explored in more detail.
Circumventing GAMSTOP6
GAMSTOP is a free online tool that, if someone signs up, prevents them from using gambling websites and apps run by companies licensed in Great Britain, for a period of their choosing. Given that all gambling websites operated by licensed companies in Great Britain are inaccessible during a period of being signed up, it was determined that, if someone had been able to use their own account on a gambling website during this period, it was very likely that they had used an illegal website to do so.
This code was categorised as ‘strong’, rather than ‘near certain’, due to the slightly ambiguous wording that could have confused respondents if they were unaware that the effects of GAMSTOP (that is, no access to gambling websites) can be circumvented through the use of illegal websites.
Figure 7. GAMSTOP usage and circumvention
| GAMSTOP Usage | Total (percentage) |
|---|---|
| Yes, I am currently signed up | 3% |
| Yes, I have signed up in the past | 7% |
| No | 87% |
| Do not know | 3% |
A3. Have you ever signed up to GAMSTOP, an online tool that restricts access to gambling websites based on personal details you share?
Base: All respondents (2,046)
| GAMSTOP Circumvention | Total (percentage) |
|---|---|
| Yes, I have not gambled or did not gamble on websites on my own account while signed up | 52% |
| No, I still have a way or found a way to gamble on websites on my own account while signed up | 40% |
| Do not know | 8% |
A4. Does and/or did GAMSTOP entirely prevent you from using gambling websites with your own account?
Base: Respondents who self-exclude (223)
One-tenth (10 percent) of people who had gambled online in the last 4 weeks had ever used GAMSTOP (3 percent were signed up at the time of fieldwork, with the other 7 percent having signed up in the past). Among them, 4-in-10 (40 percent) found a way to gamble using their own account, strongly indicating illegal website usage. This means that – at an overall sample level – 4 percent of respondents who gambled online had signed up to GAMSTOP and found a way to gamble with their own account.
Using a VPN to access a gambling website not available in Great Britain
This research focused specifically on the scope of licensed websites within Great Britain – that is, those within the jurisdiction of the Commission. As such, the use of a VPN to access any website that would otherwise be blocked in Great Britain – either a website that was licensed by another country’s gambling regulator, or an entirely illegal website – was deemed to be a ‘strong’ indicator. It was deemed as ‘strong’, rather than ‘near certain’, due to the possibility for inaccurate self-reporting by those that had used VPNs to access licensed websites within the UK (to bypass blocking software at their workplace, for example).
Figure 8. Use of a VPN specifically to gamble on non-GB websites
| Used a VPN specifically to access a gambling website that was not otherwise available in Great Britain | Total (percentage) |
|---|---|
| Yes, in the past 4 weeks | 1% |
| Yes, in the past 12 months | 4% |
| Yes, ever | 4% |
| Do not know | 3% |
| Prefer not to say | 1% |
B1. Have you ever used a VPN specifically to access a gambling website that was otherwise not available in Great Britain?
All respondents (2,046)
Just under a tenth (9 percent) of respondents had ever engaged with this indicator, with 1 percent having done so in the last 4 weeks.
Men, those aged 18 to 34, those who gamble more frequently, and those in the AB social grade (12 percent) are the groups more likely to have engaged in this indicator, as well as the respondents outlined in Table 3.
Among those categorised as illegal gambling website users, VPN usage to access websites not available in Great Britain was high, with 63 percent having ever done so: a fifth (22 percent) in the past 4 weeks.
Depositing cryptocurrency or NFTs to gamble
Although these were 2 separate indicators in the survey, we have treated them in tandem here due to their close relationship, and their identical status as ‘strong’ indicators. They are ‘strong’, rather than ‘near certain’ due to the potential for respondents to confuse NFT or cryptocurrency trading with gambling, as evidenced by one verbatim which named a cryptocurrency trading website7.
Figure 9. Depositing cryptocurrency or NFTs to gamble
| Deposited cryptocurrency (for example Bitcoin) to gamble on a website | Total (percentage) |
|---|---|
| Yes, in the past 4 weeks | 2% |
| Yes, in the past 12 months | 4% |
| Yes, ever | 3% |
| Do not know | 1% |
| Prefer not to say | 1% |
| Deposited NFTs or virtual assets to gamble on a website | Total (percentage) |
|---|---|
| Yes, in the past 4 weeks | 2% |
| Yes, in the past 12 months | 3% |
| Yes, ever | 3% |
| Do not know | 3% |
| Prefer not to say | 1% |
B1. Have you ever deposited cryptocurrency (for example Bitcoin) NFTs or virtual assets to gamble on a website?
Base: All respondents (2,046)
Cryptocurrency deposits were cited by 9 percent of people who gamble, with 7 percent8 citing NFT or virtual asset deposits.
Those that had deposited NFTs or virtual assets to gamble on a website showed an average engagement of 70 percent across the other indicators, suggesting this indicator or method of depositing is deeply embedded in the online illegal market, rather than something that could be stumbled across by a casual gambling website explorer.
76 percent of respondents who used NFT deposits to gamble also used cryptocurrency deposits to gamble. Those who have used these methods are also considerably more likely to have signed up to websites because they knew they wouldn’t need to verify their age or identity and used VPNs to access websites otherwise unavailable in Great Britain, as demonstrated in Table 3. This indicates that those using Crypto and/or NFT deposits appear more likely to intentionally using the illegal market.
Table 3: Whether respondents have gambled using cryptocurrencies or NFTs vs. using a VPN or signing up without providing verification
| Indicator | Deposited cryptocurrency to gamble on a website (percentage) |
Deposited NFTs and/or virtual assets to gamble on a website (percentage) |
Total (percentage) |
|---|---|---|---|
| Used a VPN specifically to access a gambling website that was otherwise not available in Great Britain | 26%* | 31%* | 1% |
| Signed up to a gambling website because I knew I wouldn’t need to verify my age or identity | 32%* | 37%* | 2% |
B1. Have you ever… NET: Yes, ever.
Base: Total (2,046), Used a VPN (184), Signed up to a gambling website to avoid verification (200)
*Significantly higher difference verses total.
‘Weaker’ indicators
Depositing money on a gambling website using a credit card was deemed to be a ‘weaker’ indicator in the context of the wider set that this report has already detailed. It was the most reported indicator (23 percent having done so ever, as shown in Figure 10).
Despite this, it is 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, based on research that showed it potentially correlated with greater gambling harms9. Given the scale options for this question, there is some room for respondents to have engaged in this activity pre-ban if they selected ‘Yes, ever’ (as 9 percent of respondents did), thus meaning it is a weaker indicator. For the remaining 14 percent, it is possible that there were some issues with understanding of what it means to deposit using a credit card compared to a debit card10.
Figure 10. Depositing money using a credit card
| Deposited money on a gambling website using a credit card | Total (percentage) |
|---|---|
| Yes, in the past 4 weeks | 6% |
| Yes, in the past 12 months | 8% |
| Yes, ever | 9% |
| Do not know | 2% |
| Prefer not to say | 1% |
B1. Have you ever deposited money on a gambling website using a credit card?
Base: All respondents (2,046)
With the previous caveats in mind, there is still a distinct group that use credit cards to gamble with illegal gambling websites, as we found in the Phase 1 qualitative work, with one self-excluder reporting using them to borrow money to continue gambling.
It does, however, look to be an isolated indicator, again lending credence to its categorisation as weaker. Across the other 5 indicators included in question B1 (VPN, cryptocurrency, NFT, age verification, withdrawal cancellation), an average of 30 percent of reported credit card depositers had shown engagement. When comparing this to the 70 percent engagement from people who gamble using NFTs, it suggests that credit card depositing does not seem to characterise respondents that have ‘deeper’ engagement with the illegal market.
These statements were used for Phase 2 to capture a broad range of possible indicators of unlicensed gambling. However, given some of their limitations such as ambiguity of phrasing, and concerns surrounding respondent comprehension, these statements will need to be refined further during Phase 3 before they are to be included in the Commission’s GSGB.
Adjacent indicators
Also included in the survey were several ‘adjacent’ indicators, which were added to help the Commission understand how other, common occurrences within the online gambling space may correlate with actual illegal website usage. These self-reported indicators were:
- gambling online using a foreign currency (that is, not GBP)
- being unable to close an account with a gambling website
- signing up to a gambling website using someone else's personal information or payment details.
They have not been given an actual strength rating as they sit outside of the scope of the work in developing a set of indicators that ladder up to illegal website usage; rationale for their exclusion is detailed in Figure 11.
Figure 11. Adjacent indicators of illegal gambling website usage
| Been unable to close an account with a gambling website | Total (percentage) |
|---|---|
| Yes, in the past 4 weeks | 1% |
| Yes, in the past 12 months | 3% |
| Yes, ever | 7% |
| Do not know | 5% |
| Prefer not to say | 1% |
B1. Have you ever been unable to close an account with a gambling website?
Base: All respondents (2,046)
| Gambled online using a foreign currency (not GBP) | Total (percentage) |
|---|---|
| Yes, in the past 4 weeks | 3% |
| Yes, in the past 12 months | 5% |
| Yes, ever | 4% |
| Do not know | 1% |
| Prefer not to say | 1% |
B1. Have you ever gambled online using a foreign currency (not GBP)?
Base: All respondents (2,046)
| Signed up to a gambling website using someone else’s personal information or payment details | Total (percentage) |
|---|---|
| Yes, in the past 4 weeks | 1% |
| Yes, in the past 12 months | 4% |
| Yes, ever | 3% |
| Do not know | 1% |
| Prefer not to say | 1% |
B1. Have you ever Signed up to a gambling website using someone else’s personal information or payment details?
Base: All respondents (2,046)
Given the possibility for these behaviours and experiences to span both illegal and licensed websites, it is unsurprising that the first 2 shown in Figure 11 were the most commonly reported from the battery list of statements, outside of credit card depositing. Being unable to close an account is not something that is synonymous with an illegal website, though, in line with the qualitative findings from Phase 1, does provide an indication of the types of barriers some people who gamble face in both the licensed and illegal space.
While gambling in Great Britain with a foreign currency (that is, not GBP) is possible when using licensed websites due to operators’ activity in various overseas markets, based on feedback from those with lived experience, the Commission understands it is not particularly common for people to seek gambling with a different currency on licensed websites. Despite this limitation of the indicator, similar subgroups showed a higher propensity to have taken this action as with the main batch of indicators: men (14 percent), those aged 18 to 34 (22 percent), those that gamble at least a few times a week (21 percent), and those with 5 or more accounts (48 percent).
The third adjacent indicator, signing up to a website with someone else’s information and/or payment details, is not strictly an indicator of illegal gambling as it is possible to do this on a licensed website, if the other person’s verification information and payment details were known. For instance, respondents could have interpreted it as applying to creating a gambling account for their family member which they may also use (with or without permission). The statement sat towards the lower end of the list, reported by fewer respondents for all statements except for NFT depositing. As a behaviour, it is more tied to those at higher risk of gambling harms, rather than engagement with the illegal market, being reported by 37 percent of those with a PGSI score of 8 or more.
References
1 The full preamble is included in Appendix 2 - Sample questionnaire.
2 This percentage was determined after the re-coding of those that were unable to name an actual unlicensed website used in the last 4 weeks when they were prompted to do so.
3 Percentages do not sum to the overall 9 percent due to rounding.
4 34 respondents responded when asked to name an unlicensed website – of them, 13 correctly named an unlicensed website.
5 Gambling Commission, Age, ID and financial verification.
6Note: This indicator does not fit with the usual timeframe approach of last 4 weeks, last 12 months, and ever.
7The website named was unlicensed, but would fall under the Financial Conduct Authority’s jurisdiction, rather than the Commission’s, thus making it out of scope.
8Individual responses of Yes, in the past 4 weeks (2 percent), Yes in the past 12 months (3 percent), and Yes, ever (3 percent), shown in Figure 9, do not sum to 8 percent due to rounding.
9Gambling Commission, 2020: Gambling on credit cards to be banned from April 2020; research from the Commission: ‘Gambling participation in 2019: behaviour, awareness and attitudes’, showed that 22 percent of online gamblers using credits cards to gamble are classed as ‘problem gamblers’.
10 A fifth of Brits don't know the difference between credit and debit cards (opens in new tab).
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Last updated: 18 September 2025
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