The UK Gambling Commission (UKGC) has warned that increasing use of anonymising tools such as virtual private networks (VPNs) is undermining its ability to accurately track consumer engagement. This affects the UKGC’s ability to monitor illegal online gambling sites.
In a new analysis released Tuesday, the regulator highlighted that while it can observe engagement trends through web traffic estimates, the growing scale of VPN usage is creating major blind spots. As a result, those blind spots reduce confidence in illegal market measurements.
The update follows discussions held at the UKGC’s Spring Evidence Conference in Birmingham in March. At the event, industry stakeholders, HMRC, and international regulators including the Dutch gambling authority examined enforcement challenges. They also reviewed the difficulty of obtaining reliable illegal gambling data.
No Clear Long-Term Growth in Illegal Gambling Engagement
The Commission said its latest dataset, covering a 21-month period through February 2026, does not indicate a sustained structural increase in illegal gambling activity. Instead, the figures show fluctuating patterns. Notably, there are volatile engagement levels with no consistent seasonal trends.
The UKGC used estimated minutes spent on illegal gambling sites as a proxy for consumer engagement. While a spike was recorded during autumn 2024, the same pattern did not repeat the following year. This suggests instability rather than sustained growth in the illegal market.
The findings build on the UKGC’s November 2025 admission that it could not reliably estimate how much UK consumers were spending with unlicensed operators. At that time, they noted that existing approaches based on channelisation, time-based tracking, and surveys were not fit for purpose.
Online Safety Act Linked to VPN Uptake, Increasing Data Uncertainty
The regulator said VPN usage rose significantly following the rollout of the UK Online Safety Act in July 2025. Consequently, this complicates both enforcement and measurement.
Previously, the Commission applied a 30% uplift to account for traffic hidden by VPNs. However, updated data suggests the scale of concealed activity may be higher than previously assumed.
Ofcom and Similarweb data showed VPN usage began rising from July 2025 and stabilised at roughly 40% above pre-July levels. In response, the UKGC incorporated two separate VPN usage scenarios into its trend modelling. This resulted in wider confidence intervals from mid-2025 onward.
UKGC: Trends Are Visible, But Accurate Volumes Remain Unclear
The Commission stressed that its findings rely on web traffic estimates, which naturally include margins of error and do not capture all illegal gambling channels. For example, app-based access, direct connections, and other non-web pathways are not fully reflected. This means the dataset is better suited for identifying directional trends rather than precise market size.
Tim Livesley, Head of the UKGC’s Data Innovation Hub, said the regulator is continuing to refine its methodology. Additionally, it is working with international regulators and licensed operators to improve data reliability.
“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,” Livesley said.
Better Data Seen as Key to Enforcement Impact
The UKGC emphasised that measuring the illegal market more accurately is essential for targeting disruption strategies such as payment blocking, domain takedowns, and collaboration with advertising and financial services providers.
Livesley added that illegal gambling remains a priority area for the regulator. Further updates will be provided as enforcement activity expands.
The Commission also confirmed it is strengthening data collection through the Gambling Survey for Great Britain and the Consumer Voice research programme.
VPN Growth Reflects a Global Enforcement Challenge
The UKGC noted that VPN-related measurement issues are not unique to the UK. Regulators worldwide face similar challenges as privacy tools make it harder to identify consumer location and monitor unlicensed gambling activity.
While VPN technology is widely used for legitimate privacy reasons, it is increasingly complicating efforts by regulators, payment processors, and compliance teams. These teams are attempting to detect and disrupt illegal online gambling networks.
