Intrusive Data Checks Push Gamblers To Black Market UKGC Research Finds

Research published by the UK Gambling Commission has found that requests for personal data are among the leading factors pushing British gamblers towards unlicensed, offshore operators – a conclusion that places the regulator’s own evidence base at odds with criticism from the racing and betting industries over the introduction of affordability checks.

The findings come from “Illegal online gambling: consumer awareness, drivers and motivations”, the first in a planned series of reports examining the black market, published by the Commission in September 2025. Among its findings was that using gambling websites that consumers knew “would not ask for much personal data” ranked as a key push factor towards illegal operators, second only to other considerations such as product and pricing.

The Wider Context: Financial Risk Checks

The research lands at a sensitive moment for the industry. The Commission has been rolling out financial risk checks, which require licensed operators to assess customers’ gambling activity against indicators of financial harm. Online customers who lose more than £1,000 net within a 90-day period – or deposit more than £1,000 in a 24-hour window – can be subject to enhanced assessments.

The regulator has consistently maintained that the vast majority of checks are non-intrusive. It reported that 97 per cent of the 1.7 million financial risk checks conducted during stage two of its pilot were deemed “frictionless”, meaning they required no action from the customer. The Commission has also stated that only around 3 per cent of betting accounts are expected to be subject to so-called frictionless affordability checks.

Despite those assurances, sections of the racing and betting industry have warned that even limited intervention risks pushing customers towards unlicensed operators, which offer no consumer protections, no contribution to racing’s funding streams, and no tax revenues to the Exchequer. Estimates put the potential cost to British racing’s revenues at approximately £250 million over five years if significant customer migration occurs.

What the Research Says About Motivations

The Commission’s mixed-methods study identified a range of motivations for using illegal gambling websites. In addition to the desire to avoid submitting personal data, key drivers included:

• Better odds and offers
• Access to games and products unavailable in Great Britain
• The ability to use alternative or digital payment methods
• For some, the desire to circumvent protection measures such as self-exclusion

The report represents the regulator’s most substantial effort to date to build an evidence base around the unlicensed market, complementing earlier work using operator data to identify and estimate the scale of illegal activity.

A Balanced Picture

The findings complicate the debate in both directions. For critics of the checks, the research appears to validate long-standing warnings that friction – particularly around data collection – is a meaningful driver of consumer migration. Industry figures have argued that the checks’ impact on harmful gambling is unproven while imposing real costs on operators, customers, and tax receipts.

At the same time, the report should be read in full. The Commission has previously argued that the size of the black market risk is overstated, and the research indicates that many consumers who use illegal sites are motivated by factors unrelated to regulatory friction, such as product availability and pricing. Nor does the research suggest a direct causal link between financial risk checks and black market participation; rather, it identifies data demands as one of several influences on consumer behaviour.