Gambling Commission Banking Data Study Finds Illegal Gambling Sits Alongside Licensed Play

^{The Gambling Commission, based at Victoria Square House in Birmingham, published its open banking report on 28 October 2026. (Photo: Bs0u10e01 / Wikimedia Commons)}

The Gambling Commission has published its first study that tracks illegal gambling through British consumers' bank transactions. The research, released on 28 October 2026, found no notable fall in licensed gambling after people first transacted with an illegal operator.

It also found that 45% of people with a detected illegal transaction scored 8 or more on the Problem Gambling Severity Index (PGSI), against 6% of licensed gamblers in the same dataset.

How the Commission Found the Transactions

The regulator used an anonymised open banking dataset bought from a panel of consenting individuals. In the full report, it says searching for the names of known illegal operators failed, which may mean they rarely put their name in the information passed to payment providers.

Two other methods worked. Exact matches to descriptions on bank statements known to involve illegal operators found 821 transactions, and matching merchant names found a further 2,628, of which 23 overlapped. In all, 3,426 unique transactions were made by 179 people, who had an average age of 44. Of them, 115 were male.

For context, the dataset holds 157.2 million transactions, including 4.8 million with licensed non-lottery gambling companies. Steven Murphy, the Commission's postdoctoral data scientist, said in a blog post that the data lets the regulator observe behaviour directly, rather than rely on web-traffic estimates or surveys.

Illegal Play Appears as an Add-On

The central finding is about overlap. Among people with repeated detected illegal transactions, 91% also used licensed operators. Licensed transactions averaged between about 23 and 29 a month in the six months before the first illegal one, and stood at 23.7 in the month after.

That matches earlier Commission work, which has treated the unlicensed market as a threat whose growth is not proven, and it adds a new data source to that debate. Murphy wrote that the result 'challenges the notion that engagement in illegal gambling is a direct substitution of legal activity'.

'The relative sizes of the low risk, moderate risk and problem gambling categories are reversed compared to the population of gamblers with licensed companies.' – Steven Murphy, Gambling Commission

The PGSI comparison covers 146 people with detected illegal transactions and 12,543 licensed gamblers, excluding lottery-only players. Among the illegal group, 26% scored 0, 12% scored 1 to 2, 17% scored 3 to 7 and 45% scored 8 or more. Among licensed gamblers the split was 68%, 16%, 9% and 6%.

The Commission also reported that 4% of detected illegal transactions were made with credit card accounts. It said this may be the first analysis of its kind by any regulator or research team in the world.

Limits and Next Steps

The Commission lists clear caveats. The dataset is not nationally representative, only cash transactions from institutions that support open banking are included, and there may be illegal transactions it cannot detect. The report therefore does not size the illegal market or compare it with licensed gambling.

The regulator calls the work a 'powerful proof of concept' and says it will expand its use of financial transaction data, with banks and payment providers among the partners it wants to work with. It follows the Commission's earlier look at self-excluded Britons targeted by illegal networks.

For licensed operators, the finding that illegal play tends to sit alongside licensed activity suggests the two markets are not simple substitutes, a point likely to feature in the industry's wider enforcement debate.