UK LEGAL
gathering evidence on the “emerging phenomenon” of unlicensed skins gambling websites, which allow consumers to participate in gambling games, such as roulette or a coin-flip, using in-game items. It identified over 50 such sites which were accessible from the UK and found that the largest,
clash.gg, had received more total (global) visits than well-known licensed websites including
Betfred.com and BetVictor. com. Only a quarter of the skins gambling sites assessed had a dedicated responsible gambling page and their age verification procedures tended to involve only self- declaration, although 65% of the sites reviewed did offer self-exclusion. The DCMS report concludes that legislative clarity and reform is needed. In fact, the UK’s legislation is already quite clear that, if items that can be won in a game have real-world value, gambling is taking place. The report notes that enforcement against unlicensed operators is challenging due to the “international nature of these sites” and the “ease with which operators can relocate or rebrand”. Collective regulation across jurisdiction is called for, holding skins gaming operators to the “same standards as traditional gambling platforms”.
NEXT STEPS
Although its work with search engines such as Google has resulted in over 30,000 URLs being removed from search results in a four-month period this year (according to Tim Miller in a speech in early September), illegal operators produce new URLs as fast as this disruption can take place.
Each of the other groups (“skilled advocates”, “social explorers” and “accidental tourists”) featured consumers who were tempted to use unlicensed operators (some deliberately and some by chance) due to finding better odds and offers. Overall, “getting the best odds” was a reason cited by 45% of those using illegal websites and “getting the best sign-up or bonus offers” was cited by 39%.
Although these groups didn’t necessarily include players who experienced harmful gambling, they may be at risk when playing with unlicensed sites which may lack options to set limits and self-exclude and/or meaningful play monitoring and customer interaction. For these
26 OCTOBER 2025
groups, increased gambling taxes and increased regulation in the form of restrictions on stakes, bonuses and advertising are very likely to increase the disparity between what can be offered in the licensed and unlicensed markets.
SKINS GAMBLING
Meanwhile, the Government’s Department for Culture, Media and Sports (DCMS) has been
The Commission’s research represented just the first step in its investigation of the black market. Next, it plans to further analyse the data to “determine which potential indicators can accurately signify engagement in the illegal online space”. It will then use this to “inform a larger-scale quantitative survey” and “develop a set of questions to feed into the Gambling Survey for Great Britain”. Whilst not yet finalised, its goals are expected to include tracking use of illegal sites over time and investigating the prevalence of the four different types of illegal website user. When it comes to illegal skins gambling sites, DCMS proposes further assessment of the effectiveness of existing, emerging and future regulatory frameworks, including comparative studies across jurisdictions to identity best practices, potential regulatory harmonisation and legal gaps.
Melanie has been providing UK legal and regulatory advice to betting and gaming clients since the advent of the Gambling Act 2005. She advises on all aspects of gambling law including licence applications, compliance, advertising, licence reviews and changes of control and is described in the legal directories as “a very impressive lawyer” who “demonstrates commercial pragmatism supported with a great deal of technical and operational knowledge and experience”.
Melanie has acted for a wide range of gambling operators including major online and land-based bookmakers and casinos, B2B game and software suppliers and start-ups. She also frequently advises operators of raffles, prize competitions, free draws and social gaming products. Melanie has a particular interest in the use of new technology for gambling products and
novel product ideas. She is a regular contributor to industry publications and often speaks at industry events. Melanie is listed as a ‘Leading Partner’ in the Legal 500 guide and is also ranked in Chambers.
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