UK LEGAL
N
ew research published on 18 September by the Gambling Commission sheds further light on consumers’ motivations for gambling with ‘black market’ operators. Lack of awareness of whether sites are licensed was reflected in the Commission’s survey results, with some respondents initially believing they only used licensed sites but apparently discovering they were incorrect during the course of the survey, and others believing they had gambled on an unlicensed site when it was in fact licensed. The Commission’s research involved an online survey of just over 1,000 individuals who had gambled online in the past four weeks. 9% of the respondents said that in the past year they had gambled on a website they knew or suspected was unlicensed, but of those who scored 8+ on the PGSI scale (“problem gamblers”), 51% had gambled on such sites. This highlights that it is vulnerable consumers who are most at risk from black market operators.
A lack of awareness is further demonstrated in these findings, as whilst 9% said they had gambled on a site they knew or suspected was unlicensed, 20% said they had gambled on a site that did not require ID or age verification and 18% said they had gambled on a site that didn’t offer deposit limits or self-exclusion. Alerting British consumers to the measures a licensed site must have in place therefore seems a simple way of increasing awareness of whether an operator is properly regulated. These findings all point to the potential value of a public awareness campaign to explain how consumers can check if a provider is licensed and highlight the potential risks if it is not. In fact, the BGC is one step ahead on this, having recently launched a campaign using videos featuring racing presenter Frankie Foster highlighting the risks.
Exploring the black market
Last year, the UK’s Betting and Gaming Council reported that unlicensed operators take between £2.7bn and £4.3bn of revenue away from legitimate licensed operators. Its research found that in more than half of cases, the customer was simply unaware that they were gambling with an unlicensed operator. Northridge Law’s Melanie Ellis reports.
24 OCTOBER 2025
MOTIVATIONS FOR USING THE BLACK MARKET
The key purpose of the Commission’s research was to explore consumers’ motivations for using unlicensed operators. As a result of this initial survey, it has sorted users of black market sites into four audience profiles it is calling “self-excluders”, “skilled advocates”, “social explorers” and “accidental tourists”. The “self-excluders” are the clearest at-risk group here, being those who have chosen to self-exclude from all online gambling using GAMSTOP, then find unlicensed sites typically by using search engines to find “not on GAMSTOP” websites. These sites will be those who are deliberately targeting self- excluded players by using this search term. The Commission’s enforcement activities are vital to protecting this group of consumers.
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