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.
Executive summary
Background and approach
Responding to the illegal online gambling market is a primary focus of the Gambling Commission’s corporate strategy. To do this effectively requires a robust, evidence-led understanding of this complex and often hidden market. This report represents the culmination of a multi-phase research programme, conducted by Yonder, designed to move from a position of limited knowledge of the nature of the market to one of robust statistical measurement of the engagement in the market.
This journey has been key in building a complete picture of illegal gambling website engagement. It began with qualitative discovery to identify the core consumer personas (Phase 1), moved to quantitative validation of these personas and the indicators of illegal website use (Phase 2), and then to the development of a composite Illegal Incidence Index for use on the Gambling Survey for Great Britain (GSGB)1.
This report details the findings from Phase 3, which uses a mixed-method approach: combining digital intelligence, a large-scale quantitative survey and in-depth qualitative interviews, to provide a comprehensive picture of who uses illegal gambling websites; both in terms of their demographics, but also crucially their wider motivations and attitudes, and how they apply these views to gambling.
It is important to contextualise the findings in this report; using illegal gambling websites remains a behaviour that is undertaken by a small minority of all individuals who gamble. This report deliberately focuses in on this specific subset to understand their motivations, rather than reflecting the habits of all those who gamble in general, where illegal gambling website use is not prevalent,
Among the broader audience of people who gamble, this research found there is in fact an appetite for more rules and regulation within the gambling market.
Key insights and findings
1. The illegal online gambling market is a complex space, with distinct audiences driving engagement
Illegal gambling website users are neither 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. This phase of the research has built on previous phases by including this attitudinal picture as an integral part of the quantitative survey, enabling the cross-analysis of personas with their broader societal mindsets and motivations, as well as their gambling-specific attitudes. Below is a short summary of how each persona group is defined, and the key attitudinal themes we see arising in both the qualitative and quantitative phases of the research.
Self-Excluders: Defined as users who acknowledge using illegal gambling websites by their circumnavigation of GamStop. When looking at their attitudes, they tend to be community-influenced, with a tendency to explore new game types, sites and products.
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 have given an indication of illegal gambling website use 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.
2. The search for ‘not on GamStop’ has become a primary gateway to the illegal online gambling market
Digital intelligence reveals that the language individuals use online provides a clear window into how they find illegal gambling websites. The term ‘not on GamStop’ has evolved far beyond its literal meaning. It is no longer a niche term used only by those who are self-excluded. It has become a widely understood shortcut for a suite of features believed to be associated with the illegal online gambling market: less friction, fewer identity checks, faster payouts, and the availability of features like credit card or cryptocurrency betting.
While we know from the quantitative phase of the research that some users are genuinely circumnavigating Gamstop by using illegal gambling websites, the existence of this practical, code-like language demonstrates that an additional, select group of users are not passively stumbling upon these websites but are actively and deliberately seeking them out using specific, known terminology. This search behaviour creates a well-trodden and normalised pathway to illegal online gambling for these individuals.
3. A clear hierarchy of push factors has emerged, with friction over access and data in the legal market being key
The quantitative phase of this research, undertaken with over 4,000 people who had gambled in the last 4 weeks (excluding lottery-only players), uses a Key Drivers Analysis to demonstrate how strongly each surveyed factor is linked to illegal gambling website usage, relative to the other factors measured. Across the whole sample, the key factors found are not common experience-focused factors such as 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 gambling websites that the consumer knew would not ask for much personal data.
At a whole sample level these are not common factors, but the frequency with which they are reported does increase among Self-Excluders and Skilled Advocates in particular.
These 2 factors are the most strongly linked to illegal gambling website usage across all personas, except for Accidental Tourists, where self-reported trouble with withdrawals emerges as a more strongly linked factor than looking for websites not blocked by Gamstop.
It is worth noting upfront that push factors that are present in the legal market, for example, Know Your Customer (KYC) ID or finance-related checks, are also reportedly present in the illegal market. This creates a cycle where users, frustrated by certain push factors in the licensed market, move to illegal gambling websites only to face the same issues in a less protected environment.
4. Underlying attitudes towards trust and authority fundamentally shape behaviour and risk
The qualitative phase of this research found that different groups react differently to the same push factors.
Skilled Advocates often display an anti-establishment or anti-authority mindset, being significantly less likely to trust gambling companies, the government and the regulator. For many in this group, an overarching sense of ‘friction’ on licensed websites is perceived as an injustice that validates their decision to operate outside the system. This friction includes elements such as ID, KYC checks and slow payouts, which act as independent frustrations that while experienced separately, cumulatively drive a broader sense of injustice.
Social Explorers and Accidental Tourists tend to be more pragmatic. They often view friction as an inconvenience rather than an injustice. Their journey to an illegal gambling website is driven by convenience and primarily by a search for a more seamless and trusted user experience, often guided by recommendations from friends and family.
Implications
The findings from this research provide the Commission with a robust toolkit for ongoing monitoring of illegal gambling website usage and a clear evidence base to inform future strategy.
For monitoring
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.
For communications and disruption
Early indications from this research suggest that a one-size-fits-all approach will likely be ineffective according to differences in audience perspectives. Further research is needed to explore this, but findings suggest that interventions should be tailored: education and awareness campaigns are likely to be more effective for Social Explorers and Accidental Tourists, whereas disrupting the ecosystem through enforcement and addressing core friction points will likely be more effective for Skilled Advocates. Dedicated research to explore in more detail is recommended.
References
1 A technical report outlining the development of the Index will be published by the Commission alongside findings from the first four waves of GSGB illegal gambling data. These publications are scheduled for release in November 2026, and thus will form Phase 4 of this research series.
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Introduction - Illegal online gambling research
Last updated: 20 October 2026
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