UKGC’s own research ties KYC friction to illegal gambling

• Gambling Commission research ties low-data and non-GamStop sites most closely to illegal use.
• Skilled Advocates read licensed-market friction as injustice; other groups see an inconvenience.
• Sarah Gardner says operators’ commercial practices could be part of the solution.

Seeking out sites that ask for little personal data is one of the two factors most strongly linked to illegal gambling, the UK Gambling Commission’s own research has found.

The third phase of its illegal online gambling study, published on 20 October 2026, also shows that “not on GamStop” has become a search shortcut into the illegal market.

Data over odds

Yonder Consulting ran the research for the Commission, surveying more than 4,000 people who had gambled in the previous four weeks, excluding lottery-only players. Digital intelligence and in-depth interviews fed into the findings.

A key drivers analysis measured how strongly each factor ties to illegal site use. Better odds did not lead. The top two were looking for sites not blocked by GamStop, and using sites that customers knew would not ask for much personal data.

Both behaviours are rare across the full sample but climb among Self-Excluders and Skilled Advocates. Accidental Tourists break the pattern. For them, self-reported withdrawal problems carry more weight than hunting for non-GamStop sites.

Leaving does not remove the friction. ID and KYC checks and finance-related checks are reportedly present on illegal sites too. The report describes a cycle “where users, frustrated by certain push factors in the licensed market, move to illegal gambling websites only to face the same issues in a less protected environment”.

Injustice or inconvenience

Players do not all react to friction the same way. Skilled Advocates often hold an anti-authority mindset and are significantly less likely to trust operators, government or the regulator.

For this group, ID checks, KYC and slow payouts stack up into “a broader sense of injustice”. That sense of injustice reinforces their choice to play outside the licensed system.

Social Explorers and Accidental Tourists treat the same friction as an inconvenience. They move for convenience and a smoother experience, often on tips from friends and family.

Self-Excluders, defined by getting around GamStop through illegal sites, are community-influenced. They also tend to try new game types, sites and products.

The GamStop shortcut

“Not on GamStop” no longer belongs only to self-excluded players. The research found it now signals fewer identity checks, less friction, faster payouts and credit card or cryptocurrency betting.

Rupam Jagota, Research and Impact Manager at the Gambling Commission, wrote in a blog post:

“This has created a normalised and established pathway into illegal online gambling for some consumers, further evidenced by consistently high estimated search volumes of terms relating to ‘not on Gamstop’, with many search results directing consumers to affiliate pages promoting illegal operators using ‘not on Gamstop’ branding.”

The same blog rejects a one-line explanation. It says illegal use cannot be explained by isolated factors such as policy changes or market conditions alone. It describes the picture as more complex than a simple trade-off between regulation and illegal market growth.

Industry pushes back

In comments reported by Racing Post, a spokesperson for the Betting and Gaming Council (BGC) said:

“The BGC has been clear throughout that excessive friction and demands for personal information risk pushing customers towards illegal gambling sites. The Gambling Commission’s own research now underlines that concern. Illegal operators offer none of the protections found in the regulated sector, pay no UK tax and put consumers at greater risk. The priority must be keeping customers safe within the regulated market.”

Dan Waugh, analyst at Regulus Partners, said:

“Where regulation and fiscal policy is antagonistic to the licensed market, you get rampant criminal activity. So the idea that the Gambling Commission can constrain the black market through enforcement, and not through a consideration of regulatory balance, is absurd.”

No single fix

The Commission says a one-size-fits-all response is unlikely to work. Education should land better with Social Explorers and Accidental Tourists. Skilled Advocates are more likely to respond to enforcement and fixes to core friction points.

Sarah Gardner, Acting Chief Executive at the Gambling Commission, said in her IAGR keynote in Lima, Peru:

“Some, like those who self-exclude, we want to help stay safe. Whilst they are self-excluded, we don’t want them gambling at all. For others, there is the potential that commercial practices in industry could be part of the solution. And for others, such as the ‘accidental tourists’ for example, education and awareness may help protect them.”

In 2025/26, the Commission issued 741 cease and desist notices and reported 397,527 URLs to search engines, with 266,667 removed. It disrupted 1,134 websites through takedowns or geo-blocking.

The first £7 million of a £26 million government package arrived in April, and powers to seek IP and domain name suspension orders are coming.

November data drop

The full consultation response on financial risk assessments is due this autumn. Gardner told delegates the process is frictionless for all but 0.1% of accounts.

Phase 4, scheduled for November 2026, will publish the first four waves of GSGB illegal gambling data and a technical report on the Illegal Incidence Index.

The Commission will use it to track how regulatory interventions and operator practices change who plays on illegal sites. A separate release will examine spending and vulnerability among illegal-market gamblers using financial transaction data.