The Betting and Gaming Council (BGC) has updated its warning on the matter The illegal gambling market in the UK represents a significant and growing riskrejects the argument that this problem is exaggerated based on market share estimates.
BGC chief executive Grainne Hurst said the market was black "is not a marginal problem,” responding to recent analysis showing that illegal operators account for less than 10% of online gambling activity in the UK. While he did not dispute the figures, he rejected the notion that they detract from the urgency of the issue.
“Even if these figures are accepted, it will worry everyone involved in this debate.” he wrote, arguing that even relatively small activities represent meaningful consumer exposure to unregulated operators.
The research cited in the debate, conducted for the Campaign for Fairer Gambling and published through Gaming Compliance International, estimates the illegal sector generates around £800 million in gross gambling proceeds by 2025, compared with around £8 billion from regulated operators.
Disputes regarding market size and future growth projections
The differences of opinion in this sector lie not in basic estimates, but rather in their impact on policy. Campaigners argue that the regulated market has a high level of distribution, indicating that the illegal sector in the UK is relatively limited when compared globally.
However, Hurst and BGC think so any level of illegal activity represents a structural riskespecially considering future growth projections. According to NEXT.io, data from H2 Gambling Capital estimates the UK’s illegal gambling market to reach £17 billion worth of bets by 2025, generating around £685 million in gross gambling proceeds.
The same modeling suggests this could rise sharply to more than £33 billion by 2028. In that scenario, almost a fifth of all online betting activity could take place outside regulated channels.
Hurst warned that this trend could significantly increase exposure to unsafe operators, and stressed that policy decisions taken now will affect the long-term structure of the market.
Consumer protection and regulatory pressure are at the center of the debate
BGC has formulated these issues primarily around consumer safety and economic impact. Hurst emphasized that regulated operators contribute through taxation, employment and funding to the sport, while illegal operators operate without oversight.
"One contributes to society through jobs, tax revenue and support for sport. The other simply takes money from British consumers while avoiding responsibility.” he wrote.
The organization also shows evidence of gambling-related harm while emphasizing that such harm is still limited to a small percentage of users. NHS data in 2016 estimated the prevalence of problem gambling at 0.7% in adults, a figure the BGC continues to refer to in its assessments.
At the same time, more recent Gambling Commission data from 2024 shows a higher rate of 2.7% based on the Problem Gambling Severity Index, illustrating ongoing disagreement over measurement approaches.
Regulatory bodies and policy makers continue to assess how to respond to the changing balance between licensed and unlicensed gambling activities. The Gambling Commission acknowledged that accurately measuring the size of the black market remains difficult due to inconsistent data and overlapping market factors.
Industry representatives argue that tighter regulations, higher taxation and stricter affordability measures risk driving consumers away from licensed operators. The BGC specifically raised concerns that intrusive financial risk assessments and additional compliance measures could accelerate migration to unregulated locations.
The Gambling Commission recently postponed its review of the financial risk assessment following an inconclusive evaluation of the evidence, which indicated this Further analysis is still needed before a decision is made.
The BGC and other industry bodies argue that overly restricting regulated markets can inadvertently empower illegal operators by reducing visibility and driving demand overseas.
“Banning prop bets does not eliminate the harm,” one noted industry proposal in a related context, reflects broader concerns that demand will remain despite reduced regulated supply.
However, the Gambling Commission and government officials continue to emphasize consumer protection and the need to balance market growth with harm reduction.
