UK Gambling Commission reviews unlicensed gambling activity using bank data

The UK Gambling Commission (UKGC) has published an analysis of anonymised banking records examining how payments linked to unlicensed gambling operators can occur alongside activity with licensed businesses. The research is based on a non-representative sample. It does not estimate the size of the illegal gambling market or establish that unlicensed gambling causes harm.

Published on 28 October 2026, the report covers open banking information from 38,000 consenting individuals between July 2018 and July 2026. YouGov gathered the records and supplied them in anonymised form. The Commission linked transaction data with other YouGov survey information, including Problem Gambling Severity Index (PGSI) scores where available.

The central finding is that detected payments involving unlicensed operators did not coincide with a sustained move away from licensed gambling. Some people in the sample made payments to both types of operator, showing that activity in the unlicensed market can occur alongside the use of licensed providers.

How the UKGC identified suspected unlicensed payments

The Commission used several steps to identify transactions potentially connected with illegal gambling operators. Its first search looked for known operator names in transaction descriptions using fuzzy matching, but did not identify any matching records.

The regulator then compared transaction descriptions with descriptions from bank statements known to involve illegal gambling operators. This identified 821 transactions. A further check matched merchant-name fields against names used in transactions strongly suspected of involving illegal operators, identifying 2,628 more records. Twenty-three transactions appeared in both exercises.

After removing the overlap, the analysis contained 3,426 unique transactions linked to 179 individuals. The wider dataset included 4.8 million transactions with licensed non-lottery gambling companies and 157.2 million transactions overall.

The method depended on descriptions and merchant names already associated with known or suspected operators. It was not designed to identify every unlicensed business or every payment made to one. The findings also do not establish the legal position of every merchant record.

Licensed and unlicensed activity appeared together

The Commission examined 122 people who had at least two detected unlicensed transactions. Within this group, 91% also had transactions with licensed gambling operators. The analysis did not show a substantial sustained fall in licensed-operator transactions after a person's first detected payment to an unlicensed operator.

The findings suggest that engagement with the two markets can overlap. The analysis does not explain why individuals used both types of service or how common this pattern is across the wider population.

This distinction is important when examining the relationship between licensed and unlicensed gambling. A detected payment involving an unlicensed operator does not necessarily indicate that an individual has stopped using regulated gambling services. Instead, the available records show that some consumers continued to interact with licensed operators during the periods examined.

The regulator's findings therefore provide a more detailed picture of overlapping gambling activity without suggesting that the behaviour is representative of all consumers.

PGSI scores and what the figures show

Of the 146 individuals in the detected unlicensed group with an available PGSI score, 45% recorded a result of eight or more. The corresponding proportion among 12,543 people with at least one licensed non-lottery gambling transaction was 6%.

These figures apply only to the sample examined. They are not national prevalence estimates and the groups are not mutually exclusive, meaning some individuals may appear in both. The comparison does not show that a particular payment caused harm.

The Problem Gambling Severity Index is used to assess gambling-related experiences and identify indicators associated with different levels of gambling-related problems. Scores provide an additional perspective on consumer behaviour when considered alongside other information.

However, the Commission said its study design cannot establish a causal relationship between transactions with unlicensed operators and gambling-related harm. The results should therefore be read as an observed association within the dataset rather than proof of cause and effect.

The difference between the two percentages is a notable feature of the research, but it should not be interpreted as evidence that all people using unlicensed gambling services experience gambling-related problems. The regulator's stated limitations remain central to understanding what the figures can demonstrate.

Credit card use and research limitations

Credit card accounts were involved in 138 of the 3,426 detected transactions or around 4%. These transactions involved 15 of the 179 individuals. This represents the payment pattern in the identified records, not necessarily the use of credit cards across the whole unlicensed market.

The sample was not nationally representative and included people who had chosen to share banking information for research. It covered only institutions supporting open banking protocols, excluding cryptocurrency payments and other activity outside the dataset.

The analysis identified payments associated with only a subset of illegal gambling operators. Some appeared in historical records but were not believed to be operating in Great Britain at the time of publication. The Commission also warned that additional payments may have gone undetected.

These limitations mean the data cannot calculate the total size of the illegal gambling market, either in absolute terms or compared with the licensed sector. The methodology also cannot proactively identify previously unknown illegal operators.

The research should consequently be treated as a focused examination of identifiable financial activity rather than a comprehensive assessment of every consumer or business operating in the market.

Implications for gambling oversight

The report adds transaction-level evidence to the UKGC's wider work on unlicensed gambling. Banking records can show how licensed and unlicensed activity appears in the same individual's transaction history.

However, merchant descriptions may not identify the underlying operator, payment channels are not comprehensively covered and the approach relies on prior information about suspected businesses. The results should therefore be considered alongside other research rather than as a complete picture of the market.

The Commission's explanation of how it tackles illegal gambling sets out the licensing context in Great Britain. Under the regulatory framework, businesses generally need an appropriate UKGC operating licence to provide gambling facilities to consumers in Great Britain unless a relevant exemption applies.

Open Banking Limited also provides background on the framework that enables consumers to share financial information securely with authorised third-party services. This is relevant to understanding the type of financial information that can be used in research, although the Commission's findings remain specific to its own dataset and methodology.

NHS guidance on gambling addiction also provides information about support for people affected by gambling-related harm. This is an important consideration when interpreting research that examines gambling behaviour and PGSI scores.

Conclusion

The UKGC's open banking analysis offers a useful but limited view of payments associated with unlicensed gambling. Its central finding is that detected activity in the unlicensed market can exist alongside continued use of licensed operators. Among people with repeated detected transactions, most also had licensed gambling activity.

The PGSI comparison identifies a higher proportion of elevated scores among people with detected unlicensed payments within this dataset. However, the regulator does not claim that the transactions caused harm or present the figures as representative of all consumers. The sample's composition, restricted payment coverage and incomplete identification of operators prevent conclusions about the overall scale of the market.

For regulators and researchers, the report demonstrates the value of anonymised financial data while showing why such evidence must be interpreted with care. Further analysis may clarify the relationship between payment patterns, consumer behaviour and gambling-related risk. For now, the findings describe the transactions the Commission was able to identify, not the full extent of unlicensed gambling in Great Britain.

The wider significance of this research lies in its contribution to the evidence available to gambling regulators. Understanding how consumers interact with different parts of the market requires more than identifying individual payments. It also involves examining financial behaviour, recognising the limitations of available information and distinguishing statistical associations from established causes.

The UKGC's findings provide another perspective on these questions. By highlighting the coexistence of licensed and unlicensed gambling activity, the study offers useful information for future research and regulatory discussions. Its most important contribution is therefore not a definitive measurement of the illegal market, but a more detailed understanding of what anonymised transaction records can reveal and where additional evidence remains necessary.

FAQs

What did the UKGC's latest open banking research examine?
The research examined anonymised banking transactions to identify payments potentially associated with unlicensed gambling operators and assess how they related to individuals' transactions with licensed gambling businesses.

When was the UKGC report published?
The Gambling Commission published its open banking analysis on 28 October 2026.

How many individuals were included in the wider dataset?
The YouGov open banking dataset covered 38,000 consenting individuals between July 2018 and July 2026.

How many unlicensed gambling transactions did the UKGC identify?
The analysis identified 3,426 unique transactions associated with known or suspected illegal gambling operators.

What does the 91% finding mean?
It means that 91% of the 122 individuals with at least two detected unlicensed gambling transactions also had transactions with licensed gambling operators.

What did the research find about PGSI scores?
Among 146 individuals with detected unlicensed transactions and available PGSI scores, 45% recorded a score of eight or more. The corresponding proportion among 12,543 licensed non-lottery gambling consumers was 6% within the same dataset.

Did the research establish that unlicensed gambling causes harm?
No. The Commission specifically stated that its research methodology does not establish a causal relationship between unlicensed gambling transactions and gambling-related harm.

How many detected transactions involved credit cards?
The analysis identified 138 transactions involving credit card accounts. These represented approximately 4% of the detected transactions and involved 15 individuals.

Can the research establish the total size of the illegal gambling market?
No. The dataset was not nationally representative and did not cover every operator or payment method. Cryptocurrency transactions and other unidentified payments were also outside its scope.

Why is the UKGC using open banking data in its research?
Open banking data allows researchers to examine anonymised financial transactions and study patterns of consumer behaviour. The approach can complement surveys and other research methods when assessing activity in the gambling market.