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.
How to read this report
This report is structured around the main findings from each phase of the research: digital intelligence, quantitative and qualitative, and explains how each stage informed the next.
Unless otherwise stated, charts, tables and written analysis refer to the total sample which consists of individuals surveyed who gamble on illegal websites. For more detailed findings, including demographic breakdowns, please refer to the data tables. When discussing quantitative subgroup differences, this report will reference the subgroup result versus the total (for example, “Subgroup A is more likely to say this (X% vs. Y% of the total average”). The report only uses this language where the subgroup in question is statistically significantly higher or lower than the total average, which represents the result across the whole sample.
The qualitative findings are illustrative rather than representative and are intended to provide depth and context to the wider patterns seen in the digital and quantitative phases.
All findings take a consumer-focused approach. Consumer understanding of the regulatory landscape is often limited and this influences the responses provided in each phase of research. However, when combined with other data sources (such as estimated web-traffic on illegal gambling websites and online search data), it provides a holistic view of the illegal online gambling market in Great Britain.
Terminology used
Specific terminology is used within this report, the definitions and rationale behind which can be found in the following paragraphs.
Illegal online gambling
Terminology used throughout this report to describe gambling websites and providers used by consumers in Great Britian which are not licensed by the Gambling Commission, for more details on the requirements for a gambling company to obtain a licence, visit the Licence Conditions and Codes of Practice on the Commission's website.
We utilise this term consistently throughout the report, with the exception being where participants have quoted the term ‘unlicensed’ directly, within qualitative interviews or in online posts or discourse.
Participants, personas and players
In this report, we use participants when referring to individuals who took part in the research directly, including those involved in the qualitative focus groups and quantitative survey. When referring to groups of illegal website users (Self-Excluded, Skilled Advocates, Social Explorers, Accidental Tourists), we use the term ‘persona’ or ‘group’. Where findings relate specifically to the digital intelligence phase, we use players or online users to refer to individuals. This distinction is used for clarity and applied consistently throughout the report.
Return to player (RTP)
The average percentage of all wagered money that a game or gaming machine is programmed to return to players over time. As outlined by the Commission, RTP is an average measured over an extensive volume of plays (often millions), rather than a guarantee for an individual player’s single session. More information can be found on the Return to player - how much gaming machines payout page on the Gambling Commission's website.
GAMSTOP
A free tool that allows individuals to self-exclude from all licensed gambling websites in Great Britain. More information can be found on the GAMSTOP website (opens in new tab).
PGSI
The Problem Gambling Severity Index (PGSI) is a screening tool used to measure problem gambling, defined as gambling to a degree that compromises, disrupts or damages family, personal or recreational pursuits. A PGSI score of 8 or more indicates that a person is likely to have experienced adverse consequences from gambling and may have lost control of their behaviour. A PGSI score of 3 to 7 indicates moderate-risk gambling. A PGSI score of 1 to 2 indicates low-risk gambling.
Know Your Customer (KYC) checks
Know Your Customer checks are used to verify a customer’s identity in order to ensure compliance, help prevent financial crime and protect both customers and businesses. They are used by regulated businesses, including banks and other financial institutions, and form part of wider legal obligations under anti-money laundering and counter-terrorism financing regulations.
Source of funds checks
Source of funds checks prove where money used for a specific transaction or period of gambling came from for the purposes of preventing money laundering. This involves high customer involvement since they may need to provide documentation such as a recent payslip, bank statement, or proof of a property sale. For more information, see the Commission's page on what gambling businesses want to know about your finances.
Financial checks
Refers to assessment of a customer’s financial circumstances. These include the following checks that are either directly or indirectly named in this research.
Gambling company-led financial checks: Help identity customers at risk of financial distress and triggered by loss limits set by individual gambling companies. These checks may involve customers providing their bank statements, payslips, P60, or related financial documents to assess whether a consumer is at risk of harm due to their gambling1.
Financial vulnerability checks: Financial vulnerability checks are a targeted and non-intrusive way of using publicly available information to establish if a customer is subject to publicly recorded credit events such as bankruptcy orders, county court judgements, or individual voluntary arrangements. Introduced as a requirement from 31 August 2024 and must include at a minimum a customer-specific public record information check for significant indicators of potential financial vulnerability.The customer is not asked to provide any data as part of a check. However, if a check identifies potential financial vulnerability such as bankruptcy, the gambling operator may take some customer interaction actions to support a customer (such as setting a deposit limit) or they may choose to ask for financial information if they consider that appropriate. From 28 February 2025, the relevant threshold is where the customer’s deposits minus withdrawals exceeds £150 in a rolling 30-day period. For more detail on financial vulnerability checks, visit the Gambling Commission's LCCP, Condition 3.4.4.
It is important to note that participants generally do not distinguish between the different types of checks. Indeed, they often conflate different checks with one another, and use checks as a blanket term for both different types of identity verification, age verification, financial checks, KYC and source of funds checks for anti-money laundering purposes. Additionally, they are often not always clear on how they work.
References to financial checks in this report do not include Financial Risk Assessments, as these checks have yet to be implemented within the gambling market. That being said, due to the aforementioned consumer confusion surrounding different types of checks, they can mistakenly assume they have been subjected to a Financial Risk Assessment.
Account restrictions
Measures implemented by gambling companies to limit a customer's activity. These restrictions are applied for 2 primary reasons:
- Commercial Risk: To manage profitability by limiting the activity of skilled or successful players (a practice colloquially known as 'gubbing').
- Safer Gambling: To protect vulnerable customers from harm by intervening when behaviour indicates a risk of problem gambling.
Restrictions can include limiting maximum stakes, removing eligibility for bonuses, or imposing deposit limits. From the customer's perspective (and from the perspective of this research), it is not possible to distinguish between a commercial or a safer gambling restriction, as operators rarely disclose the specific reason.
Crypto casinos
Gambling websites that are currently not regulated, which allow customers to deposit, wager, and withdraw funds using cryptocurrencies such as Bitcoin and Ethereum.
References
1 The Betting and Gaming Council's website has the Industry Voluntary Code on customer checks and documentation requests based on spend (opens in new tab) (PDF).
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Methodology - Illegal online gambling research
Last updated: 20 October 2026
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