UK Gambling Commission Publishes First Open Banking Study on Unlicensed Gambling Payments

The UK Gambling Commission released its initial open banking analysis of payment data tied to the unlicensed gambling market on 28 October 2026, marking the first time regulators have examined transaction records in this way. The study focused on repeated payments to illegal operators and revealed patterns among users who engage with both licensed and unlicensed sites. Observers note that the timing coincided with Budget week, when tax policy discussions around gambling were already underway.

Core Findings from Payment Data

Among individuals who made repeated detected payments to unlicensed operators, 91 percent also placed bets with licensed gambling sites. Licensed activity showed no substantial decline after the first recorded illegal transaction. Researchers tracked these patterns through open banking records and found that illegal play often supplements rather than replaces activity on regulated platforms. Problem gambling scores stood significantly higher among those using illegal sites. Forty-five percent of illegal-site users scored 8 or above on the Problem Gambling Severity Index, compared with 6 percent among licensed gamblers. The data set drew from open banking transactions involving certain operators, which allowed regulators to identify repeated movements of funds to unlicensed entities.

Scope and Limitations of the Analysis

The report acknowledges constraints in its data collection methods. Open banking records cover only a portion of payment activity, and the study examined transactions from specific operators rather than the full market. Despite these boundaries, the analysis provides the first direct look at how users move money between licensed and unlicensed channels. Figures show that many individuals maintain accounts across both sectors without shifting their entire activity away from regulated sites after beginning to use illegal ones.

Release Context During Budget Discussions

Publication occurred during the same week as government budget announcements, when debates about gambling taxation continued in Parliament. The study does not draw direct connections to tax policy, yet its release supplied new data points for those examining the scale of unlicensed gambling. Regulators presented the findings as an early step in using payment data to understand market behavior, while noting that future work could expand the data sources beyond open banking records.

Patterns Identified in User Behavior

The analysis tracked users who made multiple payments to unlicensed operators and compared their activity before and after those transactions. Licensed gambling volumes remained consistent in most cases, indicating that illegal sites did not simply draw players away from regulated platforms. Instead, the data suggests overlapping participation where individuals continue using licensed services alongside illegal ones. Researchers highlighted that problem gambling indicators appeared more frequently in the illegal-user group. The 45 percent figure for high PGSI scores contrasts sharply with the 6 percent rate among those using only licensed sites. This difference emerged across the sampled transactions and points to a correlation between unlicensed play and elevated risk markers, although the report stops short of claiming causation.

Next Steps for Regulatory Monitoring

The Gambling Commission described the study as the first in a series that will apply payment data to track unlicensed activity. Future reports may incorporate additional data streams once technical and legal arrangements allow broader access. Officials emphasized that the current findings rest on a narrow base of open banking records and certain operators, which limits how far the results can be generalized to the entire market. Those who have reviewed the document note that the 91 percent overlap figure offers a concrete measurement of dual participation. The absence of a drop in licensed activity after the first illegal transaction further illustrates how some users integrate both types of sites into their routines. Regulators plan to refine their methods as more payment data becomes available through open banking channels and other sources.

Conclusion

The October 2026 report supplies the first transaction-based evidence on how UK users interact with unlicensed gambling operators alongside licensed ones. Key statistics on dual participation, stable licensed volumes, and elevated PGSI scores among illegal-site users form the central results. Limitations tied to open banking coverage and operator selection remain clearly stated in the document. The findings arrive at a moment when taxation and market oversight discussions continue, giving policymakers and researchers a new set of figures to consider.