UK Gambling Commission Publishes First Open Banking Study on Black Market Activity

The UK Gambling Commission released its initial open banking study of the black market on October 28, 2026, and the report examines payment data flowing to unlicensed gambling operators while drawing on related Phase 3 Consumer Voice research issued eight days earlier. Observers note that the analysis focuses specifically on users who made repeated transactions to illegal sites, and the findings provide a clearer picture of how these individuals interact with both regulated and unregulated platforms.

Study Methodology and Scope

Payment tracking through open banking allowed researchers to identify patterns among consumers who sent funds to operators without UK licences, and the approach marked the first time the Commission applied this data source to black market monitoring. The study captured repeated payments rather than one-off transactions, which helped isolate habitual users of unlicensed sites, while cross-referencing activity against licensed operators showed no major drop in regulated play among the same group.

Key Findings on Licensed and Unlicensed Overlap

Data indicates that 91 percent of users making repeated payments to illegal operators continued gambling with licensed sites, and their activity on those regulated platforms showed no substantial reduction. This overlap suggests that many consumers maintain accounts across both markets rather than shifting entirely offshore when tax changes occur. Figures reveal that the Remote Gaming Duty increase to 40 percent took effect in April 2026, yet the payment patterns captured later in the year do not demonstrate a wholesale migration away from licensed operators.

Problem gambling scores appear significantly higher among those who transact with unlicensed sites compared with users who stay within the regulated market. The study highlights this concentration of elevated risk in the unregulated sector, and researchers tracked these scores through established screening tools included in the Consumer Voice research component.

Implications for Tax Policy Debates

Arguments that recent duty increases simply drive players offshore face new data points from the October 28 release, because the 91 percent overlap figure shows sustained engagement with licensed sites even after the April 2026 tax adjustment. The Commission’s analysis does not claim causation between the duty rise and black market growth, but it does illustrate that users already active in the illegal market do not abandon regulated operators in large numbers. Those who reviewed the payment records observed that harm indicators cluster more sharply around unlicensed activity, which complicates direct links between tax policy and offshore migration.

Broader Context in November 2026

By early November 2026 the study had entered discussions among regulators and industry participants, and the findings on repeated black market payments offered a baseline for future open banking work. The Commission referenced Phase 3 Consumer Voice data released on October 20 to strengthen its assessment of problem gambling scores, and the combined evidence set points to concentrated risk rather than uniform displacement across the entire player base. Payment data continues to serve as one monitoring tool among several, yet this first dedicated black market application demonstrates its utility for tracking flows that traditional surveys may miss.

Conclusion

The October 28, 2026 open banking study supplies concrete figures on user overlap and harm concentration without asserting broader policy outcomes, and the 91 percent continuation rate on licensed sites stands as the central statistic emerging from the payment analysis. Further rounds of similar research may build on these initial observations as open banking capabilities expand.