ENGAGEMENT, NOT JUST ACCESS
Te Commission is not simply counting websites. Using traffic estimates from Similarweb, Livesley and his team analysed both the number of visits to these sites and the average time spent per visit. To deal with uncertainty in third-party estimates, they applied bootstrapping techniques to generate confidence intervals around the results. Average visit duration has remained broadly stable, at around six to seven minutes, but the number of visits has fluctuated considerably over the 15-month period.
Estimated visits rose between August and December 2024, before declining sharply in February 2025 and flattening over the summer. By July 2025, the point estimate of visits, around 20 million, was broadly in line with levels seen a year earlier. Tis volatility suggests that spikes may be linked to particular promotions or major sporting events rather than to a structural upward trend.
To reflect both volume and duration, the Commission combined these measures into a single ‘engagement metric,’ adjusted for hidden traffic likely to be missed because of Virtual Private Network (VPN) use. Based on consumer surveys, around a quarter of users who admit to visiting illegal sites say they do so via a VPN, with a 95 per cent confidence interval suggesting the real figure could be anywhere between 19 and 34 per cent. Adjusting for this, the data indicates that total time spent on illegal websites peaked at 306 million minutes in January 2025, before falling back to 152 million minutes in July, almost exactly where it had been in July 2024.
WHY THE NUMBERS MATTER
Te Commission’s findings carry important implications for the licensed industry. On the one hand, the absence of sustained growth in consumer engagement with illegal sites should temper some of the more alarmist claims that the black market is spiralling out of control. On the other, the dynamic nature of the market underscores the ongoing risks to both consumers and legitimate businesses.
Illegal operators continue to innovate. Crypto casinos are increasingly embedded within sites that also offer traditional products such as slots and sports betting, blurring the lines between old and new models of unlicensed gambling. Messaging platforms such as WhatsApp and Telegram are also being used to promote or even host gambling opportunities, though these remain outside the scope of the Commission’s current web-based methodology. For consumers, the danger lies in the fact that many illegal sites are designed to look indistinguishable from licensed operators.
For the regulator, automation is beginning to change the game. By freeing up resources, the Commission is able to take swifter action against the highest-traffic sites and prioritise disruption efforts where they are likely to have the greatest impact. Future reports will explain in more detail how this disruption activity works in practice, and how the Commission is measuring its effectiveness.
NEXT STEPS AND INDUSTRY COLLABORATION
Livesley is clear that the work is still in development. Te methodology relies on assumptions, and the Commission is keen to improve its accuracy. Tis will involve refining search terms as consumer motivations evolve, broadening data collection to capture activity within apps and social platforms, and experimenting with alternative traffic-estimation providers. Crucially, the Commission is inviting licensed operators to collaborate, comparing their first-party web analytics with estimates from platforms such as Similarweb to calibrate the model more precisely.
VPN behaviour is another area of focus. Te Commission plans to embed VPN-use questions into the Gambling Survey for Great Britain, explore open banking data for changes in VPN subscription payments, and monitor download trends from app stores. Together, these steps will help to refine the uplift applied to engagement metrics and build a clearer picture of the true scale of activity.
Looking ahead, the next two publications in the series will broaden the conversation. One will detail the enforcement interventions being undertaken to disrupt illegal gambling, while the other will tackle the more complex challenge of estimating the financial size of the market.
A MARKET IN FLUX
Te picture painted by the Commission is not one of runaway growth, but of constant churn. Illegal websites appear and disappear at pace, fuelled by affiliates, new technologies, and shifting consumer behaviours. Average engagement has fluctuated but not escalated, yet the risks remain acute: consumers are exposed to unsafe products, the state loses tax revenues, and legitimate operators are undercut. For businesses operating in the licensed sector, the lesson is clear. Te illegal market is unlikely to vanish, but the regulator’s ability to detect and disrupt it is improving rapidly. Engagement with the Commission’s data-driven approach, whether by sharing insights, refining affiliate oversight, or tightening brand protection, will be central to ensuring that legal, regulated operators remain the most attractive and trusted option for consumers in Great Britain.
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