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The UK Gambling Commission (GC) has admitted it remains unsure how much money British players are spending with illegal online gambling operators, stating that current research methods are insufficient to produce reliable estimates.
The comments were made in the regulator’s fourth and final chapter of its research series on illegal online gambling, which analyzed various approaches to measuring the size and scope of the unlicensed market.
Limited Accuracy in Measuring the Illegal Market
The GC explored three primary methodologies: the dwell time approach, which converts engagement data and time spent on websites into spending estimates; the channelization approach, which compares engagement with legal versus illegal platforms; and the survey-based approach, which relies on player self-reporting.
However, the Commission ultimately dismissed the survey method, citing that “consumers’ recall of past expenditure in gambling surveys is generally poor.” Only the dwell time and channelization approaches were developed in detail, but both produced inconclusive results.
Findings and Flaws in Dwell Time Data
Using dwell time analysis, the Commission tracked the behavior of 117 players on illegal websites. Sports betting was the most common activity (34%), followed by bingo (14%) and slots and instant win games (13%). However, the small, non-representative sample limited the validity of the results.
The report also referenced its ‘Patterns of Play’ study of legal market data, which found casino games generated £1.12 GGY per minute, compared to £0.32 for slots. Yet, the Commission noted the data, drawn from 2018–19, was outdated. Updated slot GGY per minute from 2020 to 2025 averaged £0.24 in March 2025.
“Dwell time approach allows us to attempt to convert objective estimates of engagement data using known data from the legal market. This requires several assumptions to be made – each introducing additional uncertainty to these estimates. Further work on these actions is required before we will reach a position where reliable estimates can be published.”
Channelization Data Still Unclear
The Commission said the channelization approach—estimating the proportion of gambling through legal versus illegal sites—shows promise but also faces major data challenges.
It noted limitations in web traffic data from SimilarWeb, particularly the lack of insight into app-based gambling. “Given the likely strong degree of app-based spend in the legal market, we also need to obtain web traffic data for both app-based and website-based engagement with legal sites. SimilarWeb provides estimates of both. Ideally, we would benefit from operators’ insights to help us verify the accuracy of these estimates.”
The GC added that even small statistical errors could have a significant impact, noting that a 0.5% variation in channelization estimates could change the GGY figure by £34.5 million.
Next Steps and Ongoing Efforts
The regulator outlined potential improvements, including integrating data from consumers who use illegal sites, updating its “Patterns of Play” research, and monitoring VPN activity and search engine trends for unlicensed operators.
“Developing this estimate is a worthwhile exercise… we urge caution over use of estimates where the methodologies are not clear and levels of uncertainty are not set out.”
John Pierce, the GC’s Director of Enforcement and Intelligence, reaffirmed the regulator’s long-term strategy:
“Illegal gambling is not a static threat. It is adaptive, opportunistic, and increasingly embedded in digital ecosystems on the international stage. Through targeted disruption, strategic partnerships, and continued investment in capability, we are building a resilient and effective framework to protect consumers and uphold the integrity of the regulated sector.”
Source: iGaming Business
