UK Gambling Commission Releases Initial Open Banking Study on Illegal Gambling Engagement

The UK Gambling Commission published its first open banking study in November 2026, and the analysis draws on anonymized banking transaction data to track how consumers interact with illegal unlicensed gambling sites. Researchers examined patterns among individuals who made repeated payments to these operators, and the findings indicate that 91 percent of such users also placed bets with licensed operators during the same period. Licensed gambling activity showed no substantial decline after the first detected illegal transactions, which suggests that illegal play often supplements rather than replaces activity on regulated platforms. Data from the study further connects users of illegal sites to elevated problem gambling indicators. Forty-five percent of those engaging with unlicensed operators scored eight or higher on the Problem Gambling Severity Index, whereas the corresponding figure stood at six percent among licensed gamblers within the same dataset. Observers note that these figures come from transaction records rather than self-reported surveys, and this approach provides a direct view of actual payment flows between consumers and both licensed and unlicensed entities.

Scope and Data Sources Behind the Analysis

The study marks the first time the Commission has applied open banking methods to monitor illegal gambling at scale. Transaction data arrived in anonymized form from participating banks, and analysts filtered records for payments directed to known unlicensed operators. This method allowed identification of repeat users without accessing personal identifiers, and it produced a sample focused on individuals who showed consistent engagement with illegal sites over time. Those who've studied payment patterns in gambling markets often discover that transaction data reveals behaviors that surveys alone might miss, and this report follows that pattern by linking illegal site usage directly to licensed activity levels. The absence of any meaningful drop in licensed gambling after illegal transactions began stands out as a central observation, because it challenges assumptions that illegal sites simply divert spend away from regulated markets.

Patterns Among Repeat Users of Unlicensed Sites

Among the cohort with repeated detected payments to illegal operators, the overlap with licensed gambling reached 91 percent. Licensed activity continued at similar volumes after the initial illegal transaction appeared in the records, and this continuity held across multiple measurement periods. Researchers tracked sequences of payments to see whether users shifted spending entirely or maintained parallel accounts, and the results point to concurrent rather than sequential behavior. The same dataset revealed stark differences in problem gambling scores. Forty-five percent of repeat illegal site users reached the eight-plus threshold on the PGSI, compared with six percent of those whose transactions stayed within licensed channels. These percentages derive from the transaction-linked sample, and they highlight a measurable association between unlicensed engagement and higher severity indicators.

Implications for Regulatory Monitoring

The UK Gambling Commission report positions open banking data as a new tool for identifying unlicensed operators and understanding consumer pathways. Because the data capture actual transfers rather than declared intentions, regulators gain visibility into the scale of illegal activity and its relationship to the licensed sector. No evidence emerged that illegal gambling displaces licensed play in any significant way, and the continued parallel use of both channels appears consistent across the examined population. Analysts also examined timing of payments to see whether illegal activity preceded or followed licensed sessions, and the records show both sequences occurring without a dominant order. This mixed pattern reinforces the supplementary nature of illegal play for most repeat users in the sample. The elevated PGSI scores among illegal site users remain a separate but related finding that the Commission can now cross-reference with other datasets for further verification.

Conclusion

The November 2026 open banking study supplies the first large-scale transaction-based view of consumer movement between licensed and unlicensed gambling in the UK. With 91 percent of repeat illegal users also active on licensed sites and no notable reduction in regulated activity, the data indicate that illegal gambling functions as an addition to rather than a replacement for legal options. The 45 percent versus six percent contrast in high PGSI scores adds a further dimension that future monitoring efforts can track. Regulators now hold transaction-level evidence that can inform enforcement priorities and consumer protection measures, while the methodological approach itself sets a template for subsequent analyses.