UK Gambling Commission Publishes Initial Open Banking Study on Payments to Unlicensed Operators

The UK Gambling Commission released its first open banking study in late October 2026, and the analysis examined payment data linked to suspected illegal gambling operators operating without a licence. Researchers reviewed transactions involving 179 individuals who had sent funds to unlicensed sites, and 122 of those people showed repeated activity to the same platforms. The study focused on patterns that emerged once people began using illegal operators, and it tracked whether those individuals reduced their spending with licensed UK sites afterward.

Study Methodology and Scope

Commission staff pulled anonymised banking data through open banking channels to identify payments that matched known unlicensed gambling domains, and the approach allowed them to observe real transaction flows without relying on self-reported surveys. The sample covered consumers who had completed at least one payment to an illegal site during the monitoring period, and the dataset captured both single and multiple transactions. Observers note that the methodology marked the first time the regulator applied open banking records at this scale to illegal gambling activity.

Among the 179 individuals, 122 recorded repeated transfers to unlicensed operators, and the repeated group formed the core of the deeper analysis. Data shows that 91 percent of those repeat users also maintained accounts and placed bets with licensed operators throughout the same period. Licensed activity did not show a substantial drop after the first recorded payment to an illegal site, and spending levels with regulated platforms remained broadly consistent.

Problem Gambling Indicators

Problem gambling rates stood out as the clearest difference between teh groups. Forty-five percent of individuals who used illegal sites recorded a PGSI score of eight or higher, and that figure compared with six percent among the broader population of licensed gamblers. The commission cross-referenced the banking data with existing problem gambling screens, and the elevated scores appeared consistently within the illegal-site cohort. Researchers flagged the disparity as statistically significant, and the finding prompted further questions about how illegal operators interact with consumers who already show signs of harm.

Those who studied the results point out that the overlap in usage complicates enforcement efforts, and the same consumers often move between licensed and unlicensed platforms. The commission noted that the data does not establish causation between illegal site use and higher PGSI scores, yet the correlation remains strong enough to warrant continued monitoring. Figures reveal that problem gambling screens were applied to the same 179 individuals, and the 45 percent rate held across both single and repeat users.

Regulatory Context in November 2026

The release arrived as the commission continued its broader work on consumer protection and illegal market disruption, and the open banking approach added a new tool to existing enforcement methods. Staff at the regulator have already begun exploring how to expand the dataset in future phases, and they expect additional rounds of analysis to cover larger samples. The study remains the first public output from the open banking workstream, and it sets a baseline for tracking payment flows to unlicensed operators over time.

People familiar with the commission's data collection practices observe that open banking records provide a more direct view of actual spending than survey responses alone, and the method reduces reliance on self-reporting. The regulator linked the findings to its ongoing consumer voice research programme, and the results feed into wider discussions about how to limit access to illegal sites. No immediate policy changes were announced alongside the study, yet the commission stated it would share the insights with licensed operators and payment service providers.

Next Steps for the Commission

Commission teams plan to refine the detection criteria used in the open banking analysis, and they intend to test the approach against additional suspected illegal domains. The current sample focused on payments that had already been flagged, and future iterations may incorporate predictive modelling to identify emerging sites earlier. Researchers continue to examine whether the patterns observed in the 179-person cohort appear in larger populations, and they expect to publish follow-up findings in 2027.

Conclusion

The first open banking study from the UK Gambling Commission provides a detailed snapshot of payment behaviour among a specific group of consumers who used unlicensed gambling operators. The data shows that most of those individuals continued activity with licensed sites, and problem gambling rates measured substantially higher within the illegal-site group. The commission will use the findings to inform future enforcement work, and the methodology opens a new avenue for tracking transactions outside the regulated market.