BETTER CHANGE
Illegal Gambling – Whose Responsibility Is It?
The conversation around illegal gambling is a hot topic currently. In the UK and across other regulated markets, concern is growing that well-intentioned regulation may be creating unintended consequences - most notably, a migration of some consumers toward the unregulated, illegal space. Better Change’s Engagement Director, Rob Mabbett, reports.
T
he conversation around illegal gambling is a hot topic currently. In the UK and across other regulated markets, concern is growing that well-intentioned regulation may be creating unintended consequences - most notably, a migration of some consumers toward the unregulated, illegal space. This is not a new phenomenon, but it is becoming harder to ignore.
At the heart of the issue lies a tension. Regulation exists to keep gambling safe, fair and crime-free. Yet the illegal market operates without such constraints. It does not conduct affordability checks, source of funds verifi cation, or safer gambling interactions. It does not impose stake limits or uphold age restrictions. It offers products, such as bonus buy features, which are rightly restricted in regulated environments due to their volatility and potential for harm.
In this month’s Better Change article, we explore how the industry and other stakeholders can take the fi ght to the illegal market.
A QUESTION OF BALANCE Let’s face it, the role of a regulator is not an easy
22 MARCH 2026
one. Too little regulation risks consumer harm; too much risks pushing consumers elsewhere. Striking the right balance is critical. There is a legitimate debate to be had about where that balance sits. Some restrictions are clearly justifi ed. Highly volatile mechanics, such as bonus buys or slam stops, present real risks, and their prohibition refl ects a commitment to safer play. However, other measures, such as blanket stake limits, can feel overly restrictive to low-risk or “healthy” players, potentially diminishing the recreational experience without meaningfully reducing harm.
When regulation begins to interrupt normal, non-problematic play, friction is introduced, which, in a competitive marketplace, can drive consumer behaviour towards illegal operators who offer fewer questions and fewer barriers.
THE VULNERABILITY PARADOX It is important to acknowledge an uncomfortable truth: some vulnerable consumers will actively seek out illegal gambling environments. This may be because they wish to avoid scrutiny, or because they have self-excluded from licensed operators and are looking for a
way around those controls. This does not mean that regulation is wrong; it means that vulnerability is complex.
Well-designed regulation should not aim to eliminate risk entirely; that is neither realistic nor achievable. Instead, it should aim to manage risk proportionately, while maintaining the attractiveness of the regulated market. The regulated gambling sector is often criticised for targeting vulnerable individuals. Yet, compared to many other industries, it has made signifi cant strides in identifying and supporting at-risk consumers. From enhanced customer due diligence to proactive interventions, the sector is investing heavily in harm prevention. By contrast, the illegal market does the opposite. It actively targets vulnerability. It promotes itself as a space free from safeguards, appealing directly to those who know they are at risk. There are no interventions, only extraction.
COMPETING ON THE RIGHT BATTLEFIELD
One of the challenges facing the regulated industry is narrative. Too often, the focus is on what cannot be offered, on lost products, lost
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