UK Gambling Harms Data Raises Questions on Unlicensed Market
Fresh findings from the UK Gambling Commission have reignited a fierce debate about whether Britain’s black-market gambling scene may be far larger than previously believed.
The latest Gambling Survey for Great Britain (GSGB), published this week, aims to provide the most comprehensive picture yet of gambling trends, participation, and harm across the country. But instead of providing clarity, the figures have sparked new questions about accuracy, hidden gambling activity and how many players are slipping outside the regulated system.
Gambling harm rates edge upward
According to the GSGB, the country’s problem gambling rate rose slightly from 2.5% to 2.7% a shift that could correspond to roughly 1.4 million adults.
Commission Chief Executive Andrew Rhodes said the findings give a sharper view of “risk profiles among those gambling most frequently,” urging operators to study behavioural data closely and reinforce their player protection measures.
“Studies like the GSGB help us decide where regulatory focus should lie,” Rhodes added, pointing to ongoing reforms linked to the Gambling Act Review White Paper.
But the numbers are dividing opinions. Some industry voices argue that tighter regulation is pushing players toward offshore, unlicensed websites. Others see the increase as further proof that stronger safeguards are urgently needed.
Conflicting signals muddy the waters
The GSGB results are difficult to interpret because they tell two different stories at once.
Analyst Dan Waugh of Regulus Partners noted that while problem gambling rose, moderate-risk gambling fell meaning the overall number of at-risk players remained mostly unchanged when excluding lottery participants. He also highlighted that severe gambling harms dropped by around 20% compared to 2023.
However, Waugh expressed doubts about the reliability of the survey, saying the participation rates recorded seem inconsistent with operator-reported regulatory data. “Without resolving these gaps, it’s unclear what these figures should mean for policymaking,” he cautioned.
A hidden market in plain sight?
If the GSGB is accurate, it may be exposing an unregulated gambling ecosystem much larger than anyone anticipated.
The participation rates appear significantly higher than previous national studies, including those from the NHS, raising suspicions that many gamblers may be using unlicensed platforms. A 2024 independent review by Professor Patrick Sturgis had already warned that the GSGB carried a “non-negligible risk” of overestimating activity and harm.
Waugh added that the Commission’s skepticism toward NHS figures suggests two possibilities: either NHS studies have underestimated gambling’s impact, or the GSGB is inflating the scale of the issue.
Survey methods under scrutiny
One factor shaping the outcome may be how the GSGB gathers its data. Unlike traditional face-to-face research, the survey relies on online and postal submissions.
Critics argue this can create bias especially if more gambling-engaged individuals are the ones most likely to respond. Additionally, since participants know the topic in advance, self-selection could skew the sample further.
This may help explain why the GSGB’s numbers don’t always line up with operator data or official participation statistics.
If the figures hold true…
Should the GSGB be correct, it would point to an underground market of unprecedented scale.
Waugh observed that participation levels for certain gambling categories don’t align with “hard data,” leaving two explanations: respondents may have misunderstood the survey, or vast amounts of gambling are happening outside the regulated environment. “Not every unlicensed site operates illegally, but some do and these gaps could be shining a light on previously unseen illicit networks,” he said.
Policy implications and regulatory tension
Whether the GSGB is overstating the problem or revealing a blind spot, its findings carry significant regulatory weight. If participation has been overestimated, the risk is an inflated sense of urgency that drives disproportionate policy responses. But if the numbers are right, the UK may be facing a serious oversight gap one that allows players to access offshore operators despite strict laws.
While the GSGB does not provide definitive answers, it has reignited one of the most critical debates in British gambling policy: Are millions gambling beyond the regulators’ line of sight, or are we chasing ghosts in flawed data?
