The Gambling Commission in Great Britain is grappling with the challenge of determining how much money players are spending with illegal online gambling operators. Current methodologies for measurement and monitoring are falling short, providing limited insight into the scope of the problem.
These concerns were outlined in the fourth and final chapter of the regulator’s comprehensive research on illegal online gambling. The report addressed the complexities involved in estimating the size of the illicit market and proposed recommendations for further advancement.
The Commission explored three main approaches to gauge the scale of illegal online gambling in Britain: the dwell time approach, which translates engagement data and ‘time-spent-on-site’ into expenditure estimates; the channelisation approach, which compares data on legal and illegal gambling channels; and the survey-based approach, involving player responses to predetermined questions.
However, only the dwell time and channelisation approaches were pursued in the Commission’s detailed report. The survey-based method was dismissed because data from surveys was deemed unreliable due to the generally poor recall that consumers have about their past gambling expenditures.
Despite these efforts, the regulator acknowledges that neither the dwell time nor the channelisation methods have yielded sufficient data to form an accurate understanding of the illegal market. More work is needed to achieve meaningful progress.
Minimal findings emerged from the dwell time approach. By examining data from 117 players engaging with illegal websites, the regulator found that sports betting was the most popular activity, with participation from 34% of players. This was followed by bingo at 14%, and both slots and instant win games at 13%. Yet, the small and unrepresentative sample size posed a significant limitation to these findings.
Further analysis within this approach included ‘Patterns of Play’ research on expenditure per minute in the legal market. This showed that the casino sector led with a gross gambling yield (GGY) of £1.12 per minute, followed by slots at £0.32. However, the data, drawn from the period 2018-19, is considered outdated in light of current market conditions.
The research also looked at online slots GGY per minute from 2020 to 2025, noting a relatively steady rate, with the latest being £0.24 as of March this year. The regulator conceded that several assumptions must be made within the dwell time approach, each adding uncertainty to the estimates. Further work is necessary before reliable estimates can be published.
The channelisation approach also presented challenges. While it offers potential insights, the regulator stated that more work is needed to verify the accuracy of web traffic and app use estimates within the legal market to derive reliable channelisation rates. A list of websites associated with commission-licensed operators was created, and digital data company SimilarWeb was used for estimates of visit numbers and duration. However, limitations persist, particularly regarding app-based illegal websites not typically observed by SimilarWeb.
The Gambling Commission noted, “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, and ideally, we would benefit from operators’ insights to help us verify the accuracy of these estimates.”
Further limitations involve GGY data and its use in estimating illegal market activity, particularly concerning the margins of error in estimates. For instance, statistics from April 2023 to March 2024 indicated a total online GGY of £6.9 billion. A mere 0.5% error in channelisation rate estimates could lead to a discrepancy of £34.5 million in the associated GGY estimate.
In its conclusion, the regulator admitted that while each method has its drawbacks, there are pathways to develop a “robust estimate” of illegal online gambling in Britain. For the dwell time approach, options include leveraging data from consumers who have used illegal websites to understand differences from legal operators. The Commission also considers using data from licensed operators to elucidate betting spend and engagement, along with updating the Patterns of Play report with new data.
Additionally, the Commission may examine VPN download trends to assess how many players might be accessing illegal overseas sites, focusing on key search terms for unlicensed sites and their search engine volume.
Developing a trustworthy estimate is seen as a valuable endeavor by the Commission, yet it cautions against estimates with unclear methodologies and unspecified uncertainty levels.
The report’s conclusion echoed sentiments from John Pierce, the Commission’s director of enforcement and intelligence, who emphasized the regulator’s commitment to refining its strategies to research and combat illegal gambling in Britain. Efforts include enhancing intelligence capabilities and forming new partnerships across technological, financial sectors, and international regulators. Furthermore, the Commission is investing in developing new tools, training its teams adequately, and engaging in targeted research and data collection.
Pierce remarked, “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.”
He concluded with a note of optimism: “We are making progress; and we are committed to going further.”
3.9/5
