UK Gambling Commission Publishes First Open Banking Study on Payments to Unlicensed Sites

The UK Gambling Commission released its first open banking study on payments to unlicensed gambling sites in early November 2026, and the analysis draws directly from anonymised transaction records rather than self-reported surveys, which gives regulators a clearer window into actual consumer spending patterns across both legal and illegal operators.

Study Methodology and Data Sources

Researchers examined repeated payments flowing to black market operators through open banking channels, and this approach allowed them to track real financial movements without relying on participant recall or voluntary disclosure, which often skews traditional studies. The dataset focused specifically on individuals who made multiple transfers to unlicensed platforms over a defined period, and it cross-referenced those activities against activity at licensed UK sites to map overlapping behavior.

Data indicates that the sample captured a meaningful segment of repeat users, while the anonymised nature of the records protected individual identities yet still revealed aggregate trends in payment frequency and amounts. Observers note that this marks the first time the Commission has applied open banking tools at this scale to the illegal market, and the resulting figures offer a fresh baseline for future monitoring efforts.

Key Findings on Consumer Overlap

Among people making repeated payments to illegal operators, 91 percent also continued gambling with licensed UK operators, and this overlap shows that unlicensed activity frequently supplements rather than replaces regulated play. The report further reveals that problem gambling scores measured significantly higher among those using unlicensed sites, which suggests a correlation between engagement with black market platforms and elevated risk indicators even when users maintain accounts at legal venues.

Figures reveal that the same consumers often split their spending across both channels, and this dual participation complicates earlier assumptions that tax increases would automatically drive migration offshore. Instead the data shows many individuals maintain their licensed activity while adding illegal options, which means arguments tying higher duties directly to lost tax revenue face new empirical challenges.

Implications for Policy and Regulation

Policy discussions around tax rises and offshore migration gain additional context from these findings, because the evidence demonstrates that illegal play often coexists with legal gambling rather than displacing it entirely. Regulators now have transaction-level confirmation that a large majority of repeat black market users retain their licensed accounts, and this pattern may influence how future duty changes are modelled and communicated.

The higher problem gambling scores associated with unlicensed use also point toward enforcement priorities, and the Commission can use these insights to target interventions more precisely at consumers already showing elevated risk markers. Data from the study further underscores the value of open banking as a monitoring tool, since it bypasses survey limitations and captures actual payment flows that would otherwise remain hidden.

Broader Context for the Gambling Sector

Industry analysts have long debated the scale of the black market, yet this report supplies concrete transaction evidence that narrows uncertainty around repeat user behavior. The 91 percent overlap statistic stands out because it quantifies the extent to which consumers treat unlicensed sites as an addition to their existing licensed play, and it challenges narratives that frame illegal gambling as a complete alternative.

Those who have examined similar payment datasets in other jurisdictions note that the UK findings align with patterns seen elsewhere, while the specific focus on open banking records adds a layer of reliability that survey-based estimates cannot match. The elevated problem gambling scores among unlicensed users also reinforce existing research linking illegal operators with higher-risk profiles, although the report stops short of claiming causation.

Conclusion

The Gambling Commission's inaugural open banking study provides regulators and researchers with transaction-based evidence that 91 percent of repeat users of unlicensed sites continue licensed play, and it documents significantly higher problem gambling scores among those engaging with black market operators. These results, released in November 2026, highlight supplementation rather than substitution and introduce new considerations for tax and enforcement discussions. Further reports using the same methodology are expected to build on this baseline, and the anonymised data approach offers a replicable model for tracking payment flows across the regulated and unregulated sectors alike.