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Report

Phase 4: Illegal Gambling Index – Technical Report

The Gambling Commission’s technical report detailing the development of the Illegal Gambling Index.

Published
5 November 2026

Last updated
5 November 2026 - Changes

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Contents

Statement development during Phase 2

Initial design

Based on the qualitative findings from Phase 1, and further consultation with key stakeholders, Yonder and the Gambling Commission developed an adapted set of indicators of illegal gambling website usage to enter quantitative fieldwork with.

Advisory groups consultation

Following desk research and an initial draft of the indicators, the Commission’s Lived Experience Advisory Panel (LEAP) and Industry Forum, were convened to investigate indicators of engagement with the online illegal gambling market. Members of Yonder’s research team attended a 1-day workshop on illegal gambling at the Commission’s office, with a 1-hour session during the day set aside for an ‘at-scale cognitive test’ with all representatives, from both Industry Forum and LEAP.

The objective of the discussion was to conduct a rigorous and comprehensive analysis of engagement in with illegal gambling websites, and the types of experiences that fall within it, to inform how it can best be identified in a survey environment. By bringing together diverse perspectives, the panel and forum aimed to develop insights that would contribute to more effective and sensitive approaches to understanding illegal gambling. While LEAP were able to speak to their experiences of using illegal gambling websites and understanding from a gameplay, marketing, and engagement perspective, Industry Forum representatives added value by discussing how regulation has a part to play in the shape and scope of the illegal market.

Quantitative phase

Following the LEAP and Industry Forum workshop from Phase 2, and input from an academic from the University of Glasgow, Yonder finalised a list of indicators of illegal gambling website usage, as well as 4 bespoke questions that would sit outside the indicator list (concerning intentionality of usage and Gamstop circumvention, respectively), to take forward into the quantitative study.

An online survey was developed and conducted via Yonder Data Solutions’ proprietary online panel. The sample for the survey was 2,000 adults in Great Britain aged 18 years and over who had participated in any online gambling activity in the past 4 weeks, to ensure that questions were posed to a relevant audience, and those with timely recall of their behaviours and actions. Given the nature of the statements, it was decided that those who only used lottery products (that is, National Lottery draws or scratchcards) would not be included in the survey sample.

Quotas were set on age, gender, work status, and region to ensure the sample was designed to be broadly representative of the population. Weighting was then applied to the final achieved sample to ensure the key demographic groups are proportionally reflected in the final data, improving its accuracy and representativeness5 .

Questionnaire content

Overview of questionnaire content

Phase 2 survey questions relevant to the objective of assessing prevalence of consumer engagement with illegal gambling websites can be found in the following sections. A brief description and rationale for the inclusion of each indicator is explained in the following paragraphs.

Question A1

Asks all respondents if they have ever intentionally used an illegal gambling website to gauge the level of awareness consumers may have about their engagement with illegal gambling websites.

Question A2

If respondents report that they have intentionally used an illegal gambling website, asks them to name (at least) of these websites. This question was included to verify individuals’ responses to Question A1.

Question A3

Ask all respondents whether they have ever signed up to Gamstop.

Question A4

Asks those respondents who have ever signed up to Gamstop (or are currently signed up) whether Gamstop prevented them from using gambling websites with their own account(s). All gambling websites licensed by the Commission are required to participate in Gamstop. This question aimed to identify respondents who have used gambling websites whilst being registered to Gamstop, indicating that they used illegal gambling websites.

Question B1

Asks all respondents whether they have engaged in specific behaviours that may indicate their engagement with illegal gambling websites. Phase 1 identified that many consumers are not aware of their use of illegal gambling websites or do not know how to identify such a website. The specific behaviours we asked about can to some extent be considered ‘proxy indicators’ for engagement with an illegal gambling website as they relate to common characteristics or experiences consumers may have on these websites.

Asking about intention

All respondents were asked about their intentional usage of illegal gambling websites through a multiple-choice question (see the question in the following paragraphs).

Question A1

(Ask all respondents. Show intro text on a separate screen, allow respondents to proceed to the question after a 5 second delay.)

In Great Britain, gambling websites are regulated by the Gambling Commission. As the regulator, the Commission provides licences to companies allowing them to operate in Britain if they meet a set of rules and requirements. 

Sometimes, however, there are some gambling companies that operate gambling websites in Great Britain without having a licence from the Commission. These websites may have a licence to operate in a different country, or not have one at all, from any country. 

(Question shown on next page)

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 unlicensed websites are not engaging in illegal activity. 

  1. Yes, in the last 4 weeks 
  2. Yes, in the last 12 months
  3. Yes, ever 
  4. No, never
  5. Don’t know
  6. Prefer not to say

Ask respondents who answer ‘Yes, in the last 4 weeks’

Question A2

Which gambling website(s) have you used in the last 4 weeks that you believe do not have a licence from the Gambling Commission?

Everything you tell us is completely confidential, we’ll only use this information to check the licensing status of these companies for research purposes. Please enter your answers in the boxes below. You do not need to fill all the boxes to go to the next question.

(Open text box, Respondents can choose to enter a maximum of 5 websites.)

99. Prefer not to say

To ensure respondents’ understanding of the illegal market was appropriate, a definition of illegal gambling websites which highlights the role of licensing by the Gambling Commission was included, which also outlined that some illegal websites in Great Britain could be licensed in other jurisdictions.

The definition was included to ensure a base-level understanding among respondents of what the Commission’s role is within the gambling market, and what it means to be a ‘licensed’ website within this context. The full definition of the Commission’s role, and how licensing is decided on an operator-by-operator basis, was shortened due to survey design principles of not overloading respondents, and keeping the information provided to them concise, engaging and understandable.

Respondents were also assured about the confidentiality of the information they provide during the survey, and this question in particular, to attain the most accurate responses possible.

Where respondents reported they had intentionally used an illegal website in the last 4 weeks, they were prompted to name the website; we used this to verify their responses against the Commission’s list of licensed operators, with two-fold aims: firstly, to gauge the level of understanding among respondents; secondly, to re-code the data where necessary to ensure utmost accuracy.

Asking about Gamstop

To determine the usage of Gamstop, respondents were asked if they had ever signed up to it, and the survey outlined how it restricts access to gambling websites based on personal details. The survey assessed whether Gamstop entirely stopped respondents from using gambling websites with their own account. The specific wording was chosen to ensure respondents only report incidents where they were able to use their own personal details to gamble despite Gamstop, serving as a strong indicator they had used an illegal website to do so.

(Ask all respondents)

Question A3

Have you ever signed up to GAMSTOP, an online tool that restricts access to gambling websites based on personal details you share?

This tool is sometimes called ‘self-exclusion’ and applies across all licensed gambling websites.

  1. Yes, I am currently signed up 
  2. Yes, I have signed up in the past 
  3. Yes, ever 
  4. No, never
  5. Don’t know

(Asked to all those who reported being signed up currently or in the past to Gamstop)

Question A4

Does or did GAMSTOP entirely prevent you from using gambling websites with your own account?6

  1. Yes, I have not gambled or did not gamble on websites on my own account while signed up 
  2. Yes, I have signed up in the past 
  3. Don’t know

The list of indicators 

We have compiled the following list of indicators of illegal gambling to assess whether respondents have gambled on illegal websites unintentionally. The indicators mark features that would not be available on licensed websites, thus, if engaged in, suggesting a person has gambled on an illegal website.

(Ask all respondents)
(Randomise statements)

Question B1

Have you ever:

  • Used a Virtual Private Network (VPN) specifically to access a gambling website that was not otherwise available in Great Britain
  • Placed a bet and/or played a game on a gambling website using cryptocurrency (for example Bitcoin)
  • Placed a bet and/or played a game using money directly from my credit card (that is, using money lent to me by the bank, rather than my own)
  • Placed a bet and/or played a game on a gambling website using Non-Fungible Tokens (NFTs) or virtual assets 
  • Signed up to a gambling website because I knew I wouldn’t need to verify my age or identity 
  • Cancelled a withdrawal before it reached my bank and/or wallet on a gambling website 
  • Deliberately used a gambling website that I knew was not on Gamstop
  1. Yes, in the past 4 weeks 
  2. Yes, in the past 12 months 
  3. Yes, ever 
  4. No, never
  5. Don’t know
  6. Prefer not to say

Post-fieldwork analysis and refinement

Correlation

To assess which behaviours are associated with each other, responses to the indicators were plotted against each other in a grid. This allowed us to see which indicators were primary and secondary, by highlighting those that had broad reach across other behaviours, and those that were more distinct (that is, where a respondent had engaged with the specific behaviour, they were unlikely to have engaged in others).

Credit card deposits were determined to be a secondary indicator, as where multiple indicators were chosen, credit card depositing was often among them. Other crossovers that stood out include using cryptocurrency to gamble, which had a high correlation with signing up to gambling websites that didn’t require verification. The most convincing singular indicator of engagement with the illegal gambling market, based on correlation, is the depositing of NFTs: where respondents identified this behaviour, they were often likely to select others in combination.

Analysis of verbatims

We asked the respondents who reported intentional use of illegal gambling websites about the specific website(s) they used. The verbatims for the question suggest the understanding of the illegal market is poor, with around half of respondents giving names of websites that are licensed. In addition, understanding of the mechanics of cryptocurrency and/or NFT gambling seemed poor, with some respondents naming cryptocurrency trading websites, which are out of scope for the Commission.

Analysis of research beyond this survey

One of the limitations to this research is people’s understanding of the types of payment cards. As noted in research conducted by MoneySuperMarket (opens in new tab), as much as a quarter of British people do not know the difference between a credit and debit card. This could potentially lead to respondents misreporting their credit card depositing behaviours, decreasing the reliability of credit card usage as an indicator of illegal gambling. In addition, credit card deposits on licensed gambling websites was only prohibited in 2021 by the Commission; respondents may have issues with recall of when they exhibited this behaviour, meaning it could have fell either in or outside of the window in which the behaviour is specifically indicative of usage of an illegal website.

Legislation around reversing withdrawals before they reach banks and/or wallets has also changed relatively recently (2021). As with credit card depositing, those who have reported making a reverse withdrawal, could have done so before the feature was prohibited by the Gambling Commission in 2021, which at the time would not have been an indicator of an illegal gambling website.

Refinement needed for the GSGB

The Commission required a distinct, battery list of statements that they could include on their GSGB survey. While the initial question around intentional usage of illegal sites was kept separate to this list of statements, owing to the need to include a detailed description of illegal sites before assessing intentionality, the 2 questions about Gamstop usage and Gamstop circumvention needed to be condensed into 1 statement in order to be included in the battery list of statements, guided by the space available on the GSGB survey. The statement list used is included the next section.

Academic input

A final draft list of statements was shared with a specialist in gambling research at the University of Glasgow. Her feedback led to the inclusion of some example licensed operators in the question concerning intentional usage, and reframed the language around codes concerning ‘depositing’ cryptocurrency and/or NFTs and/or with a credit card to more commonplace language (‘placed a bet' and/or ‘played a game'). An academic from the Bristol Hub for Gambling Harms also provided an academic review, which led to the addition of a clarification to the credit card statement.

Advisory group input

LEAP and the Industry Forum were then invited to comment on the finalised list of statements, to suggest any final tweaks that they saw fit from the consumer and industry angles, respectively. Their feedback focused mostly on avoiding prejudicing responses and creating an environment in which respondents felt comfortable in giving truthful answers. Based on this feedback, the indicator list was moved before the question on intentional usage, to avoid desirability bias, and the word ‘deliberately’ was removed from a code concerning Gamstop usage and circumvention to reduce stigma.

Wider Commission colleague input

Commission colleagues who had little to no prior knowledge of the research were also invited to feedback on the updated set of draft statements. Their feedback focused largely on respondent comprehension of the questions. As a result of their feedback, the response option of ‘yes, ever’, was changed to ‘yes, more than 12 months ago’. Feedback suggested that this would help to avoid ambiguity in what was meant by ‘yes, ever’ and to promote accurate reporting in timeframes7.

References

5A full list of quotas and weighting schemes are provided in the appendices.

6 'With your own account' was underlined when presented to respondents to emphasise this element of the survey question.

7 This feedback was also provided by LEAP and Industry Forum.

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Statement development during Phase 1 Next section
The final statements for the GSGB
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