UK Gambling Commission Publishes First Open Banking Analysis of Unlicensed Gambling Activity

The UK Gambling Commission released its initial open banking study focused on the black market on October 28, 2026, and the report drew directly from anonymized payment records to examine patterns among users who send repeated transfers to unlicensed operators. Researchers compiled the dataset over several months and cross-referenced it against activity on licensed platforms, which produced a clear picture of overlapping participation rather than outright migration. Observers note that the October timing placed the findings in the middle of ongoing policy discussions about remote gaming duty adjustments scheduled for 2026.

Study Methodology and Scope

Analysts examined transaction flows through open banking channels that captured real-time payment details while stripping all personal identifiers before any review took place. The sample concentrated on individuals who completed multiple transfers to sites operating without a UK licence, and the team then matched those payment histories against records from operators holding Gambling Commission authorisation. This approach allowed direct comparison of behaviour across both licensed and unlicensed environments without relying on self-reported surveys alone. Data collection wrapped up shortly before publication, and the Commission presented the work as the first phase of a longer series that will continue into 2027.

Key Overlap Statistics

Figures from the study show that 91 percent of people making repeated payments to unlicensed operators also placed wagers with licensed sites during the same period. That overlap remained consistent across different age bands and payment frequencies, which indicates that most users maintain accounts on both sides of the regulatory line rather than shifting entirely offshore. Researchers also recorded higher problem gambling scores among those who engaged with illegal sites, and the difference reached statistical significance when compared with players who stayed exclusively within the licensed market. The report links these elevated scores to greater overall spend and more frequent session lengths, yet it stops short of attributing causation.

Implications for Tax and Regulatory Arguments

The 91 percent overlap figure directly undercuts claims that duty increases automatically drive all activity offshore, because the data demonstrates that illegal play most often supplements existing licensed activity. According to the Commission’s analysis, users who increased spending on unlicensed sites did not reduce their activity on authorised platforms by a corresponding amount. Instead, total gambling volume across both categories rose for the majority of the tracked cohort. This pattern suggests that tax policy changes alone may not produce the clean substitution effect some stakeholders anticipate, and it supplies regulators with fresh evidence when they evaluate future duty rates.

Payment data further revealed that repeat users of unlicensed sites tended to favour operators reachable through social media advertising or affiliate links, yet those same users continued to deposit with licensed brands on a regular basis. The Commission notes that this dual-market behaviour persisted even after several high-profile enforcement actions against offshore domains earlier in 2026. Observers point out that the study therefore complicates simple narratives about enforcement gaps pushing players completely out of the regulated system.

Problem Gambling Score Comparisons

Problem gambling scores, measured through standardised instruments embedded in the payment dataset, sat markedly higher among individuals who sent funds to unlicensed operators. The Commission reports that the average score for this group exceeded the score for licensed-only users by a margin large enough to register as statistically meaningful. Researchers controlled for overall gambling frequency and still observed the elevation, which points to additional risk factors tied to the unlicensed environment itself. Follow-up phases of the study will track whether these score differences remain stable over longer timeframes or fluctuate with changes in enforcement intensity.

Context Within Broader Commission Research

The open banking project forms part of a wider Consumer Voice research programme that also released updated findings on October 20, 2026. Phase 3 of that programme examined attitudes toward black market sites and found similar patterns of mixed usage, which lends additional weight to the payment data conclusions. Together the two reports supply regulators with both behavioural metrics and attitudinal context, and they arrive at a moment when the Commission continues to refine its approach to affordability checks and advertising restrictions. Publication in late October positioned the material ahead of expected parliamentary debates on gambling taxation scheduled for November 2026.

Next Steps for Data Collection

Commission officials have stated they will expand the open banking sample in 2027 to include a larger cohort and additional payment providers. The current dataset, while robust, covers only a single quarter of activity, and future releases will test whether the 91 percent overlap holds across different quarters or shifts with seasonal betting patterns. Analysts also plan to incorporate transaction velocity metrics that could highlight rapid deposit cycles often associated with higher-risk behaviour. Those expansions will feed directly into enforcement prioritisation and consumer protection initiatives already underway.

Conclusion

The October 28, 2026 release marks the first time the Gambling Commission has published open banking evidence on black market participation, and the core statistic of 91 percent overlap alongside elevated problem gambling scores supplies a new factual baseline for policy discussions. The findings show that unlicensed activity frequently coexists with licensed play rather than replacing it, which refines understanding of how tax and regulatory changes may affect overall market behaviour. Subsequent phases of the research will determine whether these patterns persist or evolve as enforcement tools and duty structures continue to develop.