Gambling Commission Data Tests Black Market Assumptions
The Gambling Commission has published research that dents one of the industry's most repeated warnings. The claim goes that unlicensed operators are pulling customers away from the regulated market. The Commission's analysis of bank transactions points to a different pattern. Most punters who bet repeatedly with illegal sites are still active with licensed ones.
Small study, mind. It covers 3,426 transactions made by 179 individuals. Of those with repeated detected unlicensed transactions, 91% also placed bets with licensed operators. That overlap is the headline finding. It also sits awkwardly with the argument that black market use means abandoning the regulated sector, a line operators have pushed for years in debates over affordability checks and advertising restrictions.
The data doesn't settle the argument outright. SBC News editor Ted Orme-Claye, discussing the findings, said the figures don't fully discredit the industry's claim that consumers are drawn to unlicensed sites. What they do show: the two markets run side by side for many players. One doesn't replace the other.
Risk profile is where the numbers get more uncomfortable. Orme-Claye pointed to the finding that 45% of people scoring eight or more on the Problem Gambling Severity Index had transacted with the illegal market. An eight-plus PGSI score indicates problem gambling. On that reading, offshore firms draw a significant share of their custom from the very players the licensed market is meant to protect. Some of those customers may be self-excluded players deliberately targeted by "non-GamStop" brands, he added.
Methodology deserves a caveat. The sample is small, and both commentators acknowledged limitations in how the Commission built it. SBC Media editor Ted Menmuir still argued the research has real value. Why? It follows actual transactions rather than relying on what people say in surveys. Bank records don't flatter the respondent.
The panel agreed on where the work should go next: research into why players seek out unlicensed sites in the first place. Blocking payments addresses the symptom, Orme-Claye said, and won't treat the underlying problem. That distinction matters for operators and for the regulator. Payment blocking is one of the few enforcement tools available at scale, and its limits are now clearer.
For licensed operators, the practical read is that black market exposure doesn't show up as lost customers. It shows up as customers who are also gambling elsewhere, often at higher risk. Player protection teams tracking self-exclusion and PGSI scores have reason to treat repeat unlicensed activity as a marker rather than an anomaly.
No compliance deadline or enforcement timetable has been attached to the findings, which are research rather than rulemaking. The next step the panel identified is motivational research, and that is the piece operators should watch. Until it lands, the 91% overlap figure stands as the most concrete number in the debate.