Report
Illegal online gambling - Phase 3: Understanding push factors for consumer engagement with illegal gambling websites
The Gambling Commission's research into consumer engagement with the illegal online gambling market.
Conclusions and next steps
Notes for readers:
- A definition of terminology mentioned in this section, such as know your customer (KYC) checks and GamStop, can be found in our How to read’ section
- More information on each phase of research discussed is in the ‘Introduction’ of this report
- The ‘Findings’ section includes a description of the personas and detailed results for each of the conclusions discussed in this section.
From foundational insight to robust measurement
This report represents the culmination of a multi-phase research journey designed to understand the complexities of the illegal online gambling market. The Gambling Commission’s series has evolved deliberately, starting from a point of limited knowledge and building progressively towards a more robust form of statistical measurement of consumer engagement in this market. Each stage of the journey has added incremental value to get to where we are today:
- Phase 1 provided the initial discovery, using qualitative methods to identify the core consumer personas (Skilled Advocates, Social Explorers, Accidental Tourists and Self-Excluders) that form the foundation of our understanding
- Phase 2 began the process of quantification, using a survey to validate these audiences and identify the most reliable indicators of illegal gambling website engagement
- This report, Phase 3, provides the granular detail behind the numbers. By deploying a large-scale quantitative survey and advanced analytical techniques, it has explored the attitudes of self-excluders, skilled advocates, social explorers and accidental tourists, and identified the specific push factors that are most influential in driving consumers towards the illegal market. The qualitative deep dive then brought this data to life, explaining the human motivations and attitudes behind the statistics.
The work to-date allows the Commission to now move forward with a high degree of confidence, using robust evidence to understand who is using illegal gambling websites and why.
Core conclusions from Phase 3
Before detailing these conclusions, it is important to reiterate the overarching context of this research: individuals who use illegal gambling websites represent a small minority of those who gamble. The following insights explore the specific dynamics amongst this audience and within this space.
1. Illegal gambling websites are a significant and complex space, with distinct audiences driving engagement
Illegal gambling website users are not a homogenous group, nor do they strictly segment into distinct groups, based on our research. However, they do tend to align with the below personas, each with their own attitudes.
Self-Excluders: A small group, that use illegal gambling websites to circumnavigate GamStop.
Skilled Advocates: Those that self-report intentionally gambling on illegal websites. When assessing their attitudes, they are driven by a strong sense of distrust of the licensed market and the pursuit of better value and personal freedom.
Social Explorers: Those that do not self-report intentionally gambling on illegal websites, but that have given an indication of illegal gambling website usage through some self-reported experiences. Looking at their wider attitudes, they are experience-led deal seekers who particularly trust peer recommendations. While they can find friction in the licensed market frustrating, they generally view it with pragmatic acceptance.
Accidental Tourists: Another group that have given at least some indication of illegal gambling website use through self-reported experiences but also do not self-report intentionally gambling on illegal websites otherwise. Qualitatively, their use of illegal gambling websites appears as typically unintentional and casual, driven by a desire for frictionless play and a growing frustration with the licensed market.
Pulling apart the latter groups – social explorers and accidental tourists – was a key aim of this phase of research. Where previous phases had provided a rules-based approach to defining Self-Excluders and Skilled Advocates, a forthcoming allocation tool, based on learnings from this phase will enable this analysis to take place on the GSGB. The Commission will be able to distinguish between 2 groups that, although aligned on behaviour (that is, illegal gambling website use), are not always aligned on attitudes and motivation.
2. The search for ‘not on GamStop’ has become a primary gateway to illegal gambling websites
This research concludes that, for those who intentionally gambling on illegal websites, their pathway is facilitated by a specific and widely understood language of search. Digital intelligence reveals that the term ‘not on GamStop’ has evolved far beyond its literal meaning. It no longer refers only to circumventing self-exclusion.
Instead, it now functions as a shortcut for a suite of features associated with the illegal market: less friction, fewer identity checks, faster payouts, and the availability of features like credit card or cryptocurrency betting. This search behaviour creates a well-trodden and normalised pathway to the illegal market, making it easier for a broad range of consumers to find and use these websites.
3. A clear hierarchy of 'push factors' has emerged, with friction over access and data in the legal market being key
The Key Drivers Analysis demonstrates how strongly each surveyed factor is linked to illegal gambling website use, relative to the other push factors measured. Across the whole sample, the key factors found are not common experience-focused factors like searching for better odds, but instead are deliberate, access-related issues, namely:
- looking for sites not blocked by Gamstop, whether to circumnavigate Gamstop itself, or as a coded shortcut for illegal gambling websites
- using websites that the consumer knew would not ask for much personal data.
As earlier findings display, there is an element of confusion across all groups as to whether a check is identity, commercial, anti-money laundering and/or source of funds (KYC), financial, or something else, with Consumers often using KYC as a blanket term.
However, this research found that push factors that are present in the legal market, for example KYC-ID or finance-related checks, are also reportedly present in the illegal market. This creates a cycle where users, frustrated by checks in the licensed market, move to illegal gambling websites only to face the same issues in a less trusted environment.
4. Attitudes towards trust and authority fundamentally shape behaviour
Underlying mindsets have a significant impact on likelihood to use illegal gambling websites. Skilled Advocates' anti-establishment views mean they distrust gambling companies and the regulator equally, justifying their use of illegal gambling websites as an expression of personal freedom. In contrast, Social Explorers and Accidental Tourists are more ambivalent, placing trust in peer recommendations over official channels and viewing friction as an inconvenience rather than an injustice. This highlights that for these personas, the journey to an illegal website is not driven by a desire to break rules, but by a search for an easier, more rewarding and trusted user experience.
Implications and next steps
Monitoring and measurement
The findings from this research provide the Commission with a robust toolkit for ongoing monitoring of consumer usage of illegal gambling websites and a clear evidence base to inform future strategy.
The validated Illegal Incidence Index and a forthcoming allocation method for the Illegal Gambling Personas will enable indicative tracking of illegal gambling website user composition via the GSGB, and how regulatory interventions and gambling company practices may impact on this composition.
Future research priorities
This research has established a strong foundation, but specific knowledge gaps remain:
Longitudinal tracking: continue to measure the key drivers to illegal gambling websites and user composition to understand the real-world impact of market interventions.
Exploring the role of educational interventions: while exploring the role of education when it comes to illegal website usage was not the central focus of the project, broader qualitative conversations provided valuable groundwork for future research priorities. From these discussions, several early-stage hypotheses emerging regarding how different personas might respond to interventions.
Strengthening understanding and identification of Skilled Advocates: currently Skilled Advocates are defined as individuals who we’ve identified as illegal gambling website users, who self-report intentionally engaging with illegal gambling websites within the past 12 months. This approach has some limitations associated with recall, misunderstanding of the question and the potential overstating of actions. Future, forthcoming allocation design is needed to strengthen the identification of this audience to ensure more accurate understanding.
Initial indications suggest that Social Explorers and Accidental Tourists are likely to be more receptive to education. These groups would theoretically respond well to communications focused on raising awareness of the indicators of illegal gambling websites and increasing hesitancy by highlighting the real risks of no legal recourse, data theft, and unfair practices. Highlighting the danger of relying solely on peer recommendations is also likely to be important within this.
Conversely, early-stage hypotheses suggest that Skilled Advocates are most unlikely to be persuaded by educational messaging.
For this group, future research could examine the impact of enforcement action aimed at disrupting the illegal gambling website ecosystem, particularly the extent to which any interventions affect the ease of accessing and using illegal websites. Research could also explore the factors that these consumers identify as validating their use of illegal gambling websites, and understand the potential for modifying these factors, and the impact of any resulting changes to them.
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Appendices - Illegal online gambling research
Last updated: 20 October 2026
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