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UK Gambling Commission Challenges in Measuring the Black Market’s Size

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The UK Gambling Commission (UKGC) has released a critical industry report addressing the issue of illegal online gambling. This report is the fourth and final installment in a series that delves into the various aspects of the black market in iGaming.

On November 6, 2025, the UKGC emphasized the complexity of quantifying a hidden activity like illegal online gambling. Previous reports in this series examined consumer awareness, engagement, and potential disruption strategies, but this final report focuses on the daunting task of measuring the black market’s size—a task made difficult by the inherent secrecy of these operations.

In the report titled “Estimating the Size of the Illegal Online Gambling Market,” the UKGC outlines the challenges faced in evaluating the scale of illegal gambling. The commission pointed out that reliable data is scarce, which means regulators often have to rely on assumptions to fill information gaps. This reliance inherently restricts the confidence in any single estimate. The UKGC compared this situation to other illicit markets, such as the illegal tobacco trade, where making accurate estimates is similarly challenging.

Key insights from the report highlight the absence of a single, definitive estimate of the illegal online gambling market’s size. Despite this, the UKGC continues to collect evidence to better understand why consumers choose unlicensed operators and the strategies used by offshore companies to attract UK players. The findings suggest that customer motivations for using illegal sites vary widely, and many users are unaware that the sites they frequent are illegal. This underscores a pressing need for increased public awareness.

Interestingly, the report notes that not all black market activities detract from the legal market. Some participants in the black market include individuals who are otherwise unable to gamble legally, such as those who have self-excluded from licensed operators.

On a more positive note, there is no evidence indicating a continued increase in engagement with illegal gambling sites in the UK. The UKGC, along with other authorities, industry stakeholders, and international partners, is actively working on various methods to disrupt the black market’s influence. The commission stressed that the fight against illegal gambling requires a coordinated response involving collaboration across agencies, industry stakeholders, digital platforms, and payment companies.

Andrew Rhodes, the chief executive of the UKGC, highlighted the significant threat posed by illegal online gambling. He expressed concern for both consumer safety and the integrity of the regulated gambling industry. Despite the difficulties in fully assessing the black market’s scale, Rhodes expressed satisfaction with the progress being made.

“Our understanding of the issue is growing,” he remarked, “and so too is our ability to disrupt illegal operators. Our independent research has strengthened the evidence base and improved transparency. This progress underscores the importance of a collective effort across sectors.”

Moving forward, the UKGC plans to focus its efforts on research, data collection, and enforcement activities. The commission has committed to sharing further details about these plans in the future.

The report also considers the perspectives of industry experts who argue that while efforts to combat illegal gambling are necessary, they must be balanced with considerations of personal freedoms and the potential for innovation within the industry. Some suggest that overly stringent regulations may drive more consumers towards the black market as they seek greater flexibility and options not available within regulated sites.

Moreover, critics of the current regulatory approach point out that punitive measures alone may not be sufficient to curtail the black market’s appeal. They argue for a more nuanced approach that includes consumer education, enhanced legal offerings, and collaboration with international partners to tackle the root causes of illegal gambling.

The UKGC’s report ultimately sheds light on the multifaceted nature of the black market issue. While significant challenges remain in accurately measuring the market’s size, the commission is committed to leveraging research and collaboration to mitigate its impact. This proactive stance is seen as essential in preserving the integrity of the legal gambling industry while safeguarding consumers from the risks associated with unlicensed operators.

As the gambling landscape continues to evolve, the UKGC’s ongoing efforts to address illegal gambling serve as a reminder of the complexities involved in regulating an industry characterized by rapid technological advancements and shifting consumer behaviors. Looking ahead, the commission’s commitment to transparency and collaboration will be crucial in navigating these challenges and ensuring the continued safety and fairness of the UK’s gambling environment.