Report
Phase 4: Illegal Gambling Index – Technical Report
The Gambling Commission’s technical report detailing the development of the Illegal Gambling Index.
Final strength ratings for the index
Of the 7 indicators taken forward for the final Illegal gambling Index, 3 have been assigned a ‘Near Certain’ rating, 3 have a ‘Strong’ rating, and 1 is deemed to be ‘Weaker’.
Index scores are assigned in relationship to one another, based on strength. For calculating the final Gambling Survey for Great Britain (GSGB) illegal gambling index:
- indicators rated as ‘Near Certain’ were assigned a score of 3 (Not on Gamstop, age verification issues, and cancelling a withdrawal)
- indicators rated as ‘Strong’ were assigned a score of 2 (VPN use, cryptocurrency use and NFT use)
- the indicator rated as ‘Weaker’ was assigned a score of 1 (credit card use).
‘Near Certain’ indicators
The following indicators were assigned a ‘Near Certain’ strength rating.
Used a gambling website that was not on Gamstop – This was deemed a near certain indicator because all online licensed gambling operators in Great Britain are required to participate in Gamstop. If a gambling website is not registered with Gamstop, it is operating illegally.
Signed up to a gambling website because you knew you wouldn’t need to verify your age or identity - Using a website that does not verify age or identity is a near certain indication that the website is not being ran by a licensed operator, as age and identity verification are fundamental requirements for Gambling Commission licensed operators.
Cancelling a withdrawal before it reached their bank and/or wallet on a gambling website – This is a feature that can be available on illegal gambling websites. Remote Technical Standards (RTS) 14B, introduced in 2021 prohibited gambling operators from allowing customers to cancel withdrawal requests following evidence that this practice was associated with increased gambling-related harm. As the requirement has been in place for several years now, this was considered a near-certain indicator of engagement with an illegal gambling website.
‘Strong’ indicators
The indicators assigned a ‘strong’ strength rating were as follows.
Used a Virtual Private Network (VPN) specifically to access a gambling website that was not otherwise available in Great Britain – This was considered a strong indicator because the use of a VPN to access a website that would otherwise be blocked in Great Britain, whether a website licensed by another country’s gambling regulator or an entirely illegal website, provides a strong indication of illegal gambling. It was classified as strong, rather than near certain, due to the possibility of inaccurate self-reporting by respondents who had used VPNs to access websites licensed within Great Britain (for example, to bypass workplace internet restrictions).
Placed a bet and/or played a game on a gambling website using cryptocurrency (for example, Bitcoin) and Placed a bet and/or played a game on a gambling website using Non-Fungible Tokens (NFTs) or virtual assets – These indicators were considered strong, rather than near certain because respondents confuse NFT or cryptocurrency trading with gambling, as evidence by one verbatim response in earlier research.
‘Weaker’ indicator
The indicator assigned this strength rating was Placed a bet and/or played a game on a gambling website using money directly from your credit card (that can be paid off each month). 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, meaning that respondents reporting using a credit card to gamble may be doing so on illegal gambling websites. However, it is possible that respondents could also be misunderstanding credit card versus debit card use.
Next sectionCalculating the index
Last updated: 5 November 2026
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