UK Gambling Commission Open Banking Study Examines Payments to Unlicensed Operators

The UK Gambling Commission published its first open banking study on 28 October 2026, examining transaction data from payments made to unlicensed gambling operators, and the timing coincided with Budget week discussions on tax policy and market regulation. Researchers analyzed actual payment records rather than relying on self-reported surveys, which allowed for a clearer view of user behavior patterns across both licensed and illegal platforms. Data showed that among individuals making repeated payments to illegal sites, 91 percent continued to place bets with licensed operators, and licensed activity showed no substantial decline following the initial illegal payment.

Transaction Data Provides New Perspective on User Behavior

Payment records revealed that problem gambling scores stood significantly higher among those using illegal sites compared to users who stayed exclusively with licensed operators, and this distinction emerged directly from the transaction patterns rather than from questionnaires. Observers note that the study marks a shift because it draws on bank data to track real movements of funds, giving regulators and analysts a more precise picture of how people interact with the black market while maintaining activity on regulated platforms. The findings arrived at a moment when policymakers considered tax adjustments and their potential effects on the size of unlicensed gambling operations.

What's interesting is the way the study separates payment flows to highlight continuity rather than substitution, and this approach avoids assumptions that illegal betting automatically reduces activity on licensed sites. Researchers tracked the timing of payments to see whether the first illegal transaction triggered any measurable drop in licensed betting, and the records showed stability instead. Such stability carries implications for debates about tax rises, because arguments about the black market often assume that higher duties on licensed operators would push more users toward illegal alternatives.

Context Within Broader Regulatory Discussions

The publication occurred during Budget week, when questions about gambling taxation and enforcement against illegal operators occupied attention in policy circles, and the timing placed the open banking findings into ongoing conversations about market balance. The Gambling Commission used anonymized transaction data to avoid identifying individuals while still capturing aggregate trends across thousands of payment sequences. Those who have examined similar data sets elsewhere point out that open banking records offer advantages over survey methods because they reduce recall bias and capture actual amounts and frequencies of transfers.

Evidence from the study shows that illegal site users maintained their licensed betting volumes after beginning payments to unlicensed operators, which challenges narratives that assume a zero-sum relationship between the two sectors. At the same time, the elevated problem gambling scores among illegal-site users provide a separate data point that regulators can consider when evaluating enforcement priorities. The report does not prescribe policy responses, yet it supplies transaction-based evidence that can inform assessments of how tax changes might interact with black market activity.

Implications for Future Monitoring and Analysis

Future studies could build on this initial open banking analysis by expanding the sample size or incorporating additional data sources, and the Commission has indicated that transaction monitoring will continue as part of its regulatory toolkit. The current findings establish a baseline against which later payment patterns can be compared, particularly if tax rates on licensed operators change. Observers note that the methodology itself represents progress because it moves beyond estimates derived from surveys and instead uses direct financial records to quantify the scale and behavior of black market payments.

Those tracking the industry note that the 91 percent overlap figure, combined with unchanged licensed activity levels, adds a layer of detail to discussions about whether tax increases would drive substantial migration to illegal sites. The higher problem gambling scores among illegal users remain a distinct observation that stands apart from the continuity in licensed spending. The study therefore supplies two separate strands of evidence that policymakers can weigh when considering adjustments to the regulatory framework.

Conclusion

The UK Gambling Commission's open banking study delivers transaction-level insights into payments flowing to unlicensed gambling operators, and the data shows that most repeat users of illegal sites continue betting with licensed platforms without measurable reduction. Problem gambling scores appear higher among those making illegal payments, and the report's timing during Budget week places these findings within wider debates on taxation and enforcement. The use of actual payment records rather than survey responses marks a methodological step forward that future analyses can reference when evaluating the relationship between licensed and black market gambling activity.