Key Moments:
- The Gambling Commission has not yet published an estimate of illegal online gambling activity in Great Britain.
- Measurement challenges stem from unlicensed operators’ opacity, offshore bases, and masking tactics.
- The Commission is prioritizing alternative methodologies and deeper cooperation to improve future data accuracy.
Policymaker Imperatives: Why a Reliable Estimate Matters
After:
Estimating the true scope of illegal online betting in Great Britain carries significant weight. It affects regulatory strategies and government decision-making. The Gambling Commission says that knowing the size of the unlicensed market helps allocate resources. It also informs enforcement actions and guides future reforms. The Commission says a credible estimate helps them understand risks to consumers and the public. It also guides how they allocate resources. A baseline also shows whether regulatory changes push players toward or away from unlicensed providers. It gives insight into consumer harm in less-protected areas. In periods where evidence-based policymaking comes under scrutiny, the lack of a clear figure brings greater uncertainty.
Inherent Hurdles: Why Illegal Markets Evade Measurement
The nature of illegal gambling poses persistent challenges to credible measurement. The Gambling Commission notes, “estimating amounts of illegal activity in any sector is a significant challenge, due to its nature.” The ability of unlicensed operators to remain hidden, leverage offshore jurisdictions, and utilize technologies to mask payments and user locations complicates review processes.
Three primary methods were assessed by the regulator, each with its own drawbacks:
| Method | Commission’s Findings |
|---|---|
| Dwell Time | Translates online activity into spend, but “requires multiple assumptions” and “each additional assumption adds additional margins for error, collectively these can add up to create significant uncertainty over the estimates.” |
| Channelisation | Balances engagement between licensed and unlicensed sites, but “this approach also requires multiple assumptions which, when combined, introduce significant margins for error.” |
| Survey Based | Was not pursued due to unreliable underlying data and poor consumer recall: “we have not pursued developing a survey based methodology as we consider the underlying data to be too unreliable” and “consumers’ recall of past expenditure in gambling surveys is generally poor.” |
Additional obstacles include consumers not realizing when they are accessing unlicensed sites, the use of VPNs and social media to reach offshore operators, and alternative forms of digital payments that obscure transaction data.
Current Insights and Persistent Unknowns
Although the Commission is unable to provide a market size estimate at this time, it has reaffirmed that the unlicensed sector constitutes “a serious threat to consumers and to the integrity of the regulated market.” The Commission also states, “we will never know the exact amount that is being spent within the illegal market.” Existing evidence does not indicate a clear increase in engagement with illegal providers, but the data available remains limited. The Commission recognizes scenarios in which some illegal play may not be a direct result of displacement from regulated channels, such as individuals excluded from the licensed market.
Drawing parallels to other underground economies, the report reiterates that “secretive nature of illegal operators make precise measurement nearly impossible.”
Steps Toward Refined Measurement
Looking forward, the Gambling Commission is taking several actions to improve the robustness of future estimates. These include revisiting and expanding the sample bases for dwell time and channelisation models and seeking out stronger data sources within the licensed sector. The Commission is also working to improve collaboration with foreign regulators, payment providers, and digital platforms due to the extraterritorial nature of much of this activity.
However, these measures do not promise immediate solutions. The Commission underlines that it will publicize a figure “that we judge to be credible and fit for public use,” signaling that the release of any data will be contingent on improved evidence quality.
Implications for Market Participants
For operators, suppliers, and policymakers, the current situation is marked by ambiguity regarding the scale of illegal gambling activity. This uncertainty complicates enforcement planning and policy debates around regulatory measures. Rather than offer speculative numbers, the Commission maintains transparency about the limitations of available data and urges the industry to focus on vigilance, collaborative information efforts, and realistic expectations about what can currently be measured.
- Author
Daniel Williams
