In a new data update published on 21 April 2026, the UK Gambling Commission (UKGC) has admitted that tracking consumer engagement with illegal gambling sites is becoming increasingly complex. While the regulator’s 21-month trend analysis shows fluctuating rather than sustained growth in black market activity, the rise of anonymising technologies is forcing a significant recalibration of how the UK measures its illegal sector.
The Online Safety Act and the VPN Surge
The most striking revelation from the report is the impact of the Online Safety Act, which came into full effect in July 2025. Following its rollout, the UKGC observed a massive spike in Virtual Private Network (VPN) usage as consumers sought to circumvent new online restrictions.
- The 40% Baseline: According to data from Ofcom and Similarweb, VPN usage initially skyrocketed in mid-2025 and has since stabilised at a level approximately 40% higher than pre-July 2025 levels.
- Hidden Traffic: The UKGC previously applied a 30% uplift to its traffic estimates to account for VPNs. However, the regulator now acknowledges that a much larger proportion of illegal gambling activity may be completely invisible to traditional web traffic monitoring.
- Data Confidence: Because of this VPN blind spot, the Commission has introduced wider confidence intervals in its latest data through February 2026, signalling that absolute volumes of illegal traffic are harder to pin down than ever.
Volatility Over Growth: What the February 2026 Data Shows
Despite the data challenges, Tim Livesley, Head of the UKGC’s Data Innovation Hub, noted that engagement with illegal sites does not appear to follow a clear seasonal or structural upward pattern.
- Fluctuating Minutes: The data shows periodic spikes, most notably in early 2025 and again in August, where estimated time spent on illegal sites exceeded 200 million minutes per month.
- No Seasonal Mirror: Interestingly, a peak seen in Autumn 2024 was not mirrored in Autumn 2025, suggesting that the black market is driven more by specific events or external friction rather than steady organic growth.
The Friction Factor: Affordability and Financial Scrutiny
The regulator’s update comes at a time of intense industry debate regarding the friction caused by new domestic safeguards. While the UKGC maintains that there is no sustained structural rise in the black market, industry bodies have raised concerns that consumer opposition to affordability checks could drive more users toward unlicensed alternatives that offer no oversight.
This tension is currently being tested through the UKGC financial risk assessment pilot, which aims to find a data-driven balance between protection and player retention. The UKGC’s latest report suggests that if friction were a primary driver, the data would likely show a more consistent upward trend than the currently observed volatility.
Strategic Evolution for 2026
The UKGC is moving away from treating any single data source as definitive. To combat the invisibility of VPN-shrouded traffic, the regulator is:
- Expanding Datasets: Integrating Consumer Voice research and the Gambling Survey for Great Britain (GSGB) to capture self-reported behaviour that web traffic misses.
- International Collaboration: Working with other regulators (including the Dutch Ksa) to verify data sources and identify shared patterns in illegal access.
- Disruption Investment: Using Treasury-backed funding to move beyond monitoring and into active disruption, such as payment blocking and domain takedowns.
As the UK transitions into a new regulatory era, supported by the UK gambling levy transition fund, the focus is shifting from “how big is the black market?” to “how can we effectively disrupt it?”
For operators, the takeaway is clear: the regulator is prioritising the quality of data over the quantity, and while VPNs may hide some players today, the UKGC is building a multi-layered detection net that looks far beyond simple IP addresses.