Gambling Commission Releases First Open Banking Study on Unlicensed Gambling Payments

The UK Gambling Commission has published its initial open banking study examining transaction patterns to unlicensed gambling operators, with the report dated October 28, 2026, providing fresh data for ongoing discussions around the black market and its overlap with regulated platforms. Analysts at the regulator examined payment records from individuals who sent repeated transfers to sites operating outside UK licensing rules, and the figures show that 91 percent of those users also placed bets with licensed operators during the same period. This dual activity highlights how transaction data can reveal consumer behavior that surveys alone might miss, since people often underreport their engagement with illegal sites when responding to questionnaires.

Study Methodology and Data Sources

Researchers relied on aggregated open banking records rather than self-reported responses, which allowed them to track actual payment flows to both licensed and unlicensed domains over multiple months. The approach marks the first time the Gambling Commission has applied this method to black market analysis, and it yields clearer visibility into frequency, amounts, and timing of transfers that reach operators without UK authorization. Observers note that this transaction-based lens reduces reliance on recall bias, while it simultaneously raises new questions about how tax revenue calculations might shift once regulators better understand the scale of cross-border flows. Data indicates problem gambling scores ran notably higher among those who used unlicensed sites compared with users who stayed within the licensed sector, although the study stops short of establishing direct causation between site type and harm levels.

Participants who sent multiple payments to illegal operators showed elevated scores on standardized problem gambling measures, and the difference reached statistical significance when compared against control groups who only used licensed platforms. The report frames these findings as input for policy conversations about enforcement priorities and potential tax adjustments, because accurate estimates of black market volume depend on reliable payment intelligence. Those who reviewed the raw datasets pointed out that repeat transfers often clustered around specific high-risk operators, yet many of the same accounts later routed funds to compliant UK-licensed brands within days or weeks.

Key Findings on Overlap and Problem Gambling

Among the cohort making repeated payments to unlicensed sites, the 91 percent overlap with licensed operators suggests that a substantial share of black market users do not operate entirely outside the regulated system. Instead, they appear to maintain parallel accounts, which regulators can now trace through banking data. The study further reveals that problem gambling indicators climbed in tandem with the number of unlicensed transactions recorded, although researchers emphasize that additional variables such as overall gambling volume and session length require further examination. Figures reveal that the average monthly transfer amount to illegal operators exceeded amounts sent to licensed sites for a subset of users, yet the majority still directed the bulk of their activity toward compliant platforms.

Because the study draws from open banking feeds rather than voluntary surveys, it captures behavior that might otherwise remain hidden from policy makers. The Gambling Commission study therefore supplies a new baseline for estimating the revenue lost to unlicensed operators, which in turn informs debates on whether tax changes could alter market dynamics. Experts who examined the methodology praised the shift toward objective payment records, while they also cautioned that open banking coverage does not extend to every payment method, leaving some cash or cryptocurrency flows outside the dataset. The report nevertheless supplies the most granular view yet of how UK residents interact with both licensed and unlicensed gambling environments simultaneously.

Implications for Black Market Debates

Policy discussions around the black market often hinge on estimates of its size and the degree to which it draws customers away from licensed operators. This first open banking analysis supplies concrete transaction evidence that many repeat users of illegal sites continue to gamble with regulated companies, which complicates simple narratives about total market displacement. The elevated problem gambling scores observed among unlicensed users add another layer, because they suggest that harm reduction strategies may need to address both licensed and unlicensed channels. Data shows that the overlap occurs across different age groups and payment frequencies, indicating the pattern is not limited to a narrow demographic slice.

Regulators can now reference these transaction patterns when evaluating enforcement tools such as payment blocking or advertising restrictions. The study also supplies a template for future open banking projects that could track changes after new rules take effect, allowing comparison of pre- and post-intervention flows. Observers note that the November 2026 release timing coincides with broader conversations about gambling taxation, so the data arrives at a moment when lawmakers are weighing options for closing revenue gaps. The Gambling Commission has indicated it will publish additional open banking analyses in coming quarters to build on this initial dataset.

Conclusion

The October 28, 2026 report marks a shift toward transaction-driven research on unlicensed gambling, and its core findings on the 91 percent overlap plus higher problem gambling scores provide measurable inputs for future policy work. By focusing on actual payment records, the Gambling Commission has created a foundation that future studies can expand, while current debates on tax impacts and enforcement gain access to previously unavailable detail. The study therefore stands as the starting point for a more data-informed approach to understanding how UK residents engage with the full spectrum of online gambling operators.