Tracking illegal gambling is harder with rising VPN use, UKGC says

The Gambling Commission released an analysis of consumer engagement with illegal online gambling sites on Tuesday. The analysis highlights fluctuating activity patterns and emerging challenges to data accuracy due to the increased use of anonymising technologies, such as virtual private networks (VPNs).

The update followed a panel discussion on illegal gambling at the Commission’s Spring Evidence Conference held in Birmingham in March. Industry representatives, the Dutch gambling regulator and HMRC convened to discuss enforcement and data issues.

No structural rise after 21 months

Tuesday’s update builds on findings in November 2025, when the UKGC acknowledged it could not reliably estimate how much players were spending with unlicensed operators. The authority did not deem any of the three approaches of time, channelisation and survey-based fit for purpose. 

The Commission admitted then that the methodology still needed more work. Six months on, the Commission has offered an update, though the picture remains far from definitive.

The Commission’s latest 21-month data series was updated through February 2026. It used estimated minutes spent on illegal gambling sites as a proxy for consumer engagement. The data indicates volatile user activity without clear seasonal patterns or sustained growth. 

An observed spike in consumer engagement during autumn 2024 did not recur in the following year. This suggests volatility rather than sustained growth in the illegal market.

Online Safety Act fuels VPN use, clouding market data

Consumers’ growing VPN use, especially after the rollout of the Online Safety Act in July 2025, has complicated the enforcement landscape. While a 30% uplift had been applied to account for VPN-hidden traffic, recent data suggest an even larger proportion of illegal gambling activity may be hidden. 

Data from Ofcom and app analytics provider Similarweb shows an increase in VPN use starting July 2025. It stabilised at roughly 40% higher than pre-July levels, according to Ofcom’s data. 

This prompted the Gambling Commission to incorporate two VPN usage scenarios into its trend analyses, resulting in larger confidence intervals from mid-2025 onwards.

Trends visible, volumes are not

The Commission emphasised that its figures are derived from web traffic estimates, which carry margins of error. Furthermore, web traffic analysis does not capture all avenues of illegal gambling access, such as apps or direct connections. As a result, these estimates are more effective in indicating trends than in predicting precise engagement volumes. 

“We continue to work on improvements to our methodology and are seeking input from other international regulators and licensed operators to help verify and improve existing data sources and to identify additional datasets which can be used to improve understanding of the illegal market,” said Tim Livesley, head of the UKGC’s Data Innovation Hub.

Furthermore, the regulator is also enhancing data collection through its Gambling Survey for Great Britain and the Consumer Voice research programme. 

Enforcement effectiveness hinges on data gaps

Accurate measurement of the illegal market is critical to targeting enforcement efforts and evaluating the success of interventions such as payment blocking, domain takedowns and collaborations with financial institutions and advertising platforms.

“The Commission continues to treat illegal gambling as a priority and we will also be providing further updates on how we are expanding our disruption and enforcement activity,” Livesley added.

The Commission’s recognition of VPN-related measurement challenges reflects broader difficulties faced by regulators worldwide. VPNs designed to protect consumer privacy are proving an equal headache for regulators and payment processors trying to detect illegal activity.