UK Gambling Commission Study Maps Black Market Payment Flows for the First Time

The UK Gambling Commission has published its initial open banking analysis of money moving to unlicensed gambling operators, and the numbers paint a clear picture of how illegal sites fit into the broader betting landscape. Released in late October 2026, the report draws on payment records rather than surveys, giving regulators a fresh view of repeat users who send funds across borders to sites outside the licensed system.

Study Design and Data Sources

Researchers pulled transaction histories from open banking feeds that covered several months of activity, then matched those payments against known unlicensed operators. The focus stayed on repeat users, defined as people who made multiple transfers to black-market sites within the study window, and the team compared their patterns with activity on licensed platforms. This approach let analysts track real money movement instead of relying on self-reported behavior.

Because the data came directly from bank records, the findings carry weight that earlier consumer surveys could not match. Observers note that open banking access removes much of the guesswork that previously clouded estimates of illegal market size and user overlap.

Overlap Between Licensed and Unlicensed Play

Among the repeat users of illegal sites, 91 percent also placed bets with licensed operators during the same period. The figure shows that illegal play rarely stands alone; instead it supplements activity on regulated platforms. People who chase higher odds or restricted markets on black-market sites still keep accounts with British-licensed companies for the rest of their gambling.

That pattern matters because it challenges the idea that illegal operators simply steal customers from the regulated market. Data shows the two channels run in parallel for most heavy users, with the unlicensed sites acting as an add-on rather than a replacement.

Problem Gambling Scores and Harm Indicators

Problem gambling scores told a sharper story. Roughly 45 percent of repeat illegal-site users recorded PGSI scores of 8 or higher, the threshold that signals problem gambling. The same measure sat around 6 percent among users who stayed within the licensed sector. The gap points to a strong association between black-market participation and elevated harm.

Experts tracking the sector have long suspected that illegal sites attract or intensify problem behavior, yet the open banking numbers supply concrete evidence that links payment patterns directly to those higher scores. The study stops short of claiming causation, but the correlation stands out clearly in the figures.

Payment Routes and Market Reach

The report also details how funds reached unlicensed operators. Most transfers moved through international card schemes or alternative payment providers that sit outside the controls applied to British-licensed sites. Analysts mapped the volume and frequency of these transactions, revealing clusters of activity that spike around major sporting events.

Because the data set captured actual pounds sent, the Commission now holds a baseline it can compare against future open banking pulls. Regulators expect to repeat the exercise periodically so they can track whether enforcement actions or new payment blocks change the flow.

Regulatory Next Steps

Commission officials have already begun sharing the methodology with banks and payment firms to explore tighter screening for known illegal operators. The goal is to reduce the ease with which repeat users can move money offshore while keeping legitimate transactions smooth. Industry groups have received summaries of the findings and are reviewing their own compliance checks in light of the overlap data.

Further work will examine whether blocking specific merchant identifiers or requiring additional customer checks can shift behavior without driving more activity underground. The current study supplies the reference point against which those interventions can be measured.

Conclusion

The open banking study gives the UK Gambling Commission its first detailed ledger of money heading to unlicensed sites, and the results highlight both the scale of overlap with the licensed market and the elevated harm markers among illegal-site users. As the regulator prepares to run similar exercises in coming months, the October 2026 report stands as the starting line for evidence-led action on black-market payments.