Sustainable Gambling Conference — The Rise of the Black Market: Insights Into Player Behaviour and Regulatory Risk

Johnson emphasised that regulators and licensed operators share the same long-term goal: keeping gambling safe, visible, and well-regulated. Yet unregulated markets continue to grow across online and in-person channels, operating outside the Gambling Commission’s oversight. Understanding how and why players engage with these operators is essential for reducing harm and protecting the integrity of the licensed market.

To build that understanding, Frontier worked with operators and the Betting and Gaming Council to develop and conduct a large-scale behavioural survey to look at the what, who, how and why of black market awareness and usage. Frontier Economics defined the black market as any gambling activity not regulated by the UK Gambling Commission, including both online and land-based activity.

Frontier Economics’ findings show that whilst black market usage is limited to relatively few players, together their spend means black market stakes in the UK could exceed £4.3 billion annually, including roughly £2.7 billion staked through online and messaging-based platforms and £1.6 billion in unlicensed premises.

The data further indicates that 93.8% of gamblers use regulated operators exclusively, 5.4% were ‘multi-homers’ who use both regulated and unregulated operators, and 0.8% rely solely on black markets. Frontier went on to highlight that £14.8 billion staked in licensed markets by customers that already ‘multi-home’ are potentially “at risk.” The survey also revealed that 8.1% of respondents reported using VPNs to gambling websites in the past 12 months, with VPN usage more common for those accessing black market sites.

Players cited several reasons for turning to unregulated operators, including better bonuses, easier account creation, the ability to play anonymously, and avoiding limits, documentation checks, or self-exclusion restrictions.

Awareness and usage were notably higher among younger cohorts, especially 18-24 year-olds, and higher-spending customers appeared more likely to engage with black market channels.

Johnson closed by underscoring that reducing harm requires lowering exposure to unregulated operators and limiting their appeal, ensuring that gambling stays within environments where consumer protections, standards, and visibility can be maintained.