(AsiaGameHub) –   On Tuesday, the Gambling Commission published an analysis examining consumer interaction with unlicensed online gambling platforms. The report draws attention to shifting activity patterns and new risks to data accuracy, driven by growing uptake of anonymity tools such as virtual private networks (VPNs).

This update came after a panel discussion focused on illegal gambling took place at the Commission’s Spring Evidence Conference hosted in Birmingham in March. Industry representatives, the Dutch gambling regulator, and HMRC gathered to discuss enforcement practices and data-related challenges.

No sustained structural increase recorded over 21 months

Tuesday’s update expands on findings released in November 2025, when the UKGC acknowledged it could not produce reliable estimates of how much players were spending with unlicensed operators. The regulator found none of the three available approaches — time-based, channelisation, and survey-focused methods — suitable for the task.

The Commission admitted at that time that its measurement methodology still required further refinement. Six months later, the regulator has released a new update, though the full picture of the market remains far from clear.

The Commission’s latest 21-month data series has been updated to include figures through February 2026. It uses estimated total minutes users spent on illegal gambling sites as an indicator of consumer engagement. The data shows highly unstable user activity, with no distinct seasonal patterns or consistent long-term growth.

A notable spike in consumer engagement recorded in autumn 2024 did not repeat in the following year. This indicates fluctuating activity rather than sustained growth of the illegal gambling market.

Online Safety Act drives higher VPN adoption, obscuring market data

Rising VPN use among consumers, particularly after the rollout of the Online Safety Act in July 2025, has made the enforcement landscape more complex. While a 30% adjustment factor was previously applied to account for traffic hidden by VPNs, recent data suggests an even larger share of illegal gambling activity may be going uncounted.

Data from Ofcom and app analytics provider Similarweb shows VPN uptake began increasing in July 2025. It levelled off at roughly 40% higher than pre-July 2025 levels, according to Ofcom’s figures.

This led the Gambling Commission to integrate two separate VPN usage scenarios into its trend analyses, resulting in wider confidence intervals for all data from mid-2025 onward.

Trends can be identified, but exact volume figures remain out of reach

The Commission stressed that its figures are derived from web traffic estimates, which carry inherent margins of error. What is more, web traffic analysis does not capture all channels used to access illegal gambling, such as dedicated apps or direct connections. As a result, these estimates are better suited to indicating broad trends than calculating precise engagement volumes.

“We are continuing to refine our methodology, and are seeking input from other international regulators and licensed operators to help validate and improve existing data sources, as well as to identify additional datasets that can enhance our understanding of the illegal market,” said Tim Livesley, head of the UKGC’s Data Innovation Hub.

Additionally, the regulator is also strengthening its data collection work via its Gambling Survey for Great Britain and the Consumer Voice research programme.

Enforcement success depends on closing existing data gaps

Accurate measurement of the illegal market is critical to targeting enforcement resources effectively and evaluating the success of interventions including payment blocking, domain takedowns, and partnerships with financial institutions and advertising platforms.

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

The Commission’s recognition of VPN-related measurement challenges reflects wider difficulties faced by regulators across the world. VPNs designed to protect consumer privacy are proving to be a similarly significant challenge for regulators and payment processors working to detect illegal activity.