In the fourth and final part of the Gambling Commission’s study of illegal gambling in the UK, published this week, the regulator has stated it is unable to provide a “robust and reliable” measure of the size of the market, with potential discrepancies of £34.5m.
The Gambling Commission has published the fourth and final part of its study of illegal gambling in the UK, which focuses on the challenges the regulator has encountered in estimating the size of the market.
The report assess the effectiveness of estimates based on survey, dwell-time and channelisation, and found that in some cases a financial appraisal of the black market could be incorrect by a margin of £34.5m.
“We have focused on methodologies based on objective data,” read the study’s executive summary. “This provides the opportunity to clearly explain levels of uncertainty associated with estimates and creates options to access new data to refine assumptions and improve them.”
“We note concern over reliability of estimates based on surveys which require consumers to recall previous illegal gambling expenditure with any accuracy. Having examined different methodologies, we are not yet in a position to make a robust and reliable estimate of the size of this market.”
As one branch of its investigation, the Commission used dwell-time to estimate black market engagement, however issues with sample size and relevancy of data meant any conclusion “required several assumptions to be made – each introducing additional uncertainty to these estimates.”
The regulator said channelisation yielded more potential for accuracy, however a lack of access to web and app traffic undermined the figures, adding “we would benefit from operators’ insights to help us verify the accuracy of these estimates.”
Channelisation estimates of GGY were also noted as being unreliable, often including a margin of error of 0.5 percent. Providing the example of April 2023 to March 2024, when GGY reached £6.9bn, the Commission observed that a 0.5 percent error amounted to £34.5m.
“While we welcome the focus on this issue, and recognise the concern stakeholders have about illegal gambling, we urge caution over use of estimates where the methodologies are not clear and levels of uncertainty are not set out.”
Unfortunately, the exact same can now be said of the Commission’s assessment of the UK black market; by its own admission, the Commission’s estimates are neither “robust” nor “reliable”.
Neither robust nor reliable
Gambling Commission said… “We note concern over reliability of estimates based on surveys which require consumers to recall previous illegal gambling expenditure with any accuracy. Having examined different methodologies, we are not yet in a position to make a robust and reliable estimate of the size of this market…