Key Moments:
- The Gambling Commission has stated that current methodologies remain insufficient for accurately estimating British players’ spending with unauthorized gambling operators.
- Dwell time and channelization analyses were the main focus, but neither produced definitive conclusions regarding the illegal market size.
- A 0.5% shift in channelization estimates could impact Gross Gambling Yield (GGY) figures by £34.5 million, according to the Commission.
Regulators Continue to Grapple with Elusive Market Data
The UK Gambling Commission (GC) has acknowledged ongoing uncertainties concerning the true scale of illegal online gambling in Britain. In the final chapter of its research into unlicensed online gambling, the regulator emphasized that current research techniques fall short in generating trustworthy estimates regarding British users’ spending with illicit operators.
Evaluating Methods for Estimating the Unlicensed Sector
The GC assessed three main strategies for sizing up the illegal market: the dwell time approach, which evaluates user engagement and time spent to estimate spending; the channelization method, comparing legal and illegal platform use; and survey-based techniques relying on users to report their spending. The regulator discounted the survey option, pointing out that “consumers’ recall of past expenditure in gambling surveys is generally poor.” Only dwell time and channelization were further developed, though both yielded inconclusive outcomes.
| Methodology | Description | Findings | Limitations |
|---|---|---|---|
| Dwell Time | Converts engagement/time spent data into estimated spending, referencing legal market patterns | Sports betting identified in 34% of cases; bingo 14%; slots and instant win games 13% among 117 participants | Results limited by small, non-representative sample |
| Channelization | Measures engagement on legal vs. illegal platforms | Channelization shows potential for better estimates | Web traffic data lacks insight into app-based gambling behavior |
| Survey-Based | Relies on player self-reporting | Not pursued further by the Commission | Players struggle to accurately recall past spending in surveys |
Shortcomings and Statistical Sensitivity
Through its dwell time analysis, the regulator followed the activities of 117 users on illegal sites. Among these, sports betting accounted for 34% of activity, bingo for 14%, and slots and instant win games for 13%. However, the small sample size and its lack of representativeness weakened the data’s credibility. The report also cited the 2018–19 ‘Patterns of Play’ data, with casino games generating £1.12 GGY per minute compared to £0.32 for slots. The latest figure for slot GGY per minute, averaging £0.24 as of March 2025, was noted as more current but did not lead to conclusive estimates.
The Commission commented: “Dwell time approach allows us to attempt to convert objective estimates of engagement data using known data from the legal market. This requires several assumptions to be made – each introducing additional uncertainty to these estimates. Further work on these actions is required before we will reach a position where reliable estimates can be published.”
Channelization Approach Under Review
Efforts to evaluate the distribution of legal versus illegal gambling through the channelization approach revealed additional challenges. The Commission stated that web traffic figures from SimilarWeb, for example, do not reflect the full extent of app-based gambling. The GC pointed out: “Given the likely strong degree of app-based spend in the legal market, we also need to obtain web traffic data for both app-based and website-based engagement with legal sites. SimilarWeb provides estimates of both. Ideally, we would benefit from operators’ insights to help us verify the accuracy of these estimates.”
Highlighting the market’s sensitivity, the Commission observed that even a 0.5% discrepancy in channelization estimates could shift GGY calculations by £34.5 million.
Strategies for Improvement and Future Plans
Looking forward, the GC suggested several avenues for improvement. These included gathering more direct data from consumers who use illegal platforms, updating its “Patterns of Play” analysis, and increasing oversight of VPN usage and search engine activity connected to unlicensed operators.
The Commission cautioned: “Developing this estimate is a worthwhile exercise… we urge caution over use of estimates where the methodologies are not clear and levels of uncertainty are not set out.”
John Pierce, the GC’s Director of Enforcement and Intelligence, reinforced the regulator’s ongoing commitment: “Illegal gambling is not a static threat. It is adaptive, opportunistic, and increasingly embedded in digital ecosystems on the international stage. Through targeted disruption, strategic partnerships, and continued investment in capability, we are building a resilient and effective framework to protect consumers and uphold the integrity of the regulated sector.”
- Author
Daniel Williams
