Gambling Commission Index Puts Illegal Site Use at 2.5% of Online Gamblers

The Gambling Commission's new survey index finds 2.5% of online gamblers used an illegal site in the past four weeks, a first baseline rather than a trend. It also referred 7.7 million URLs to search engines in one quarter, and about 3 million were removed.

• The Gambling Commission's Illegal Gambling Index, published on 5 November, finds 2.5% of people who gambled online in the past year used an illegal site in the past four weeks, and a further 1.5% earlier in the year
• The estimate rests on 3,569 online gamblers in the Gambling Survey for Great Britain (GSGB), and only 128 respondents were classed as illegal site users
• Between July and September the Commission referred 7,677,211 URLs to search engines, up from 147,721 the quarter before, and 3,019,291 were removed
• Gambling Compliance International (GCI) says the share of people using illegal sites is not the share of revenue they generate
• The data follows the Commission's open banking analysis of illegal payments and comes days before IAGR's first Illegal Gambling Awareness Week from 9 to 13 November

The Commission Measures Behaviour, Not Admissions

The Commission published the Phase 4 findings of its research with Yonder Consulting on 5 November, with a technical report and an updated illegal gambling dashboard. The index does not ask people whether they used an illegal site. It scores seven self-reported behaviours: using a site known not to be on GamStop, signing up because no age or identity check was needed, cancelling a withdrawal, using a VPN to reach a site unavailable in Great Britain, gambling with cryptocurrency or NFTs, and depositing by credit card.

The first three are rated "near certain", because licensed operators must join GamStop, verify customers and, since 2021, may not let customers cancel withdrawals. Older behaviour counts for less, and a recent user needs one near-certain or two strong indicators in the past four weeks. The technical report says a direct question on intentional use was dropped from the scoring, partly because many sites respondents named as illegal were licensed.

The data covers four GSGB waves from April 2025 to April 2026, online respondents only. Of 3,569 online gamblers, excluding those who played only National Lottery products, 2.5% met the four-week threshold, 1.5% the 12-month one, 14.0% showed limited indications and 82.0% none. Across all 14,257 online respondents, the figures are 0.6%, 0.4%, 4.6% and 94.4%. Of the 128 users, 58.0% had used a site known not to be on GamStop and 56.6% had cancelled a withdrawal.

Sue Young, the Commission's Executive Director for Operations, said engagement "appears low and stable from these indicators", but that research suggests the cohort using these sites is more likely to experience harm.

7.7 Million URLs Referred, 3 Million Removed

The 7.7 million URLs flagged between July and September were referred to search engines, not taken down, according to the Commission's enforcement figures. Over the quarter, 3,019,291 URLs and 1,339 websites were removed from search results. Registrars or hosts removed or suspended seven websites, and operators geo-blocked 25. Cease and desist letters to illegal operators rose to 546 from 217, and four criminal investigations began.

Acting chief executive Sarah Gardner told the Commission's CEO Briefing on 5 November that 7,824,932 URLs were reported to search engines between April and September, against 397,527 in all of 2025/26. She linked the scale-up to the £26 million the government committed over three years, a sum she had set out to regulators in October.

GCI Says Prevalence Is Not Revenue

GCI president Ismail Vali told iGB that "a relatively small audience, particularly one concentrated around vulnerable, repeat or high-value gambling behaviours, can generate substantial criminal revenue". GCI research for the Campaign for Fairer Gambling put illegal online GGR in Great Britain at about £780 million in 2025, nearly 9% of the online market, iGB reported. Vali also said the adult survey leaves out children, and that self-excluded gamblers need specific analysis.

The Stable Claim Rests on the Dashboard, Not the Index

The index has one year of data, and Gardner called it a baseline from which trends can be built. Any judgement of stability comes from the dashboard. It counted 586 accessible illegal sites in September, up from 439 in May 2024, while estimated traffic to them, modelled from Similarweb with an uplift for VPN use, fell by about a third between those months. More supply and less use is plausible, but it rests on modelled traffic.

The URL Count Measures Granularity, Not Operators

Referred URLs rose 52 times; referred websites rose five times. The Commission referred about 4,200 URLs per website in the second quarter against about 400 in the first, and removals equalled 39% of referrals, against 67% across 2025/26. That points to finer, page-level referrals rather than a surge in operators. Gardner said the focus "may evolve away from some of these numbers". No payment provision was disrupted in the quarter.

Both Sides Are Measuring Different Things

The Commission counts people; GCI counts money. A 2.5% user base concentrated among GamStop evaders could still carry the revenue GCI estimates, and nothing in the survey rules that out. The persona questions the Commission plans to add to the GSGB in 2027 should show how concentrated that cohort is.

The Commission now has a repeatable measure and a disruption effort with new money behind it. Its headline enforcement figure, though, counts search listings, and its headline prevalence figure cannot yet say whether the illegal market is shrinking.