UK lagging behind Europe in terms of black gambling market control

The findings come from industry research and a PWC report for the BGC as the Government finalises its work on the upcoming Gambling Review and against a backdrop of increased use of black market sites in the UK.

British punters using unlicensed sites has more than doubled in just two years, from 220,000 users to 460,000 and the amount staked is now in the billions of pounds.

Looking at other markets, Norway introduced a state monopoly for all gaming coupled with restrictions on stakes, affordability checks and advertising, which resulted in a black market that now accounts for over 66 per cent of all money staked. In France, where online casino games are also a state monopoly, black market gaming accounts for 57 per cent of all money staked. In Italy, where betting and gaming advertising is completely banned, the black market accounts for 23 per cent of money staked. A 2020 Royal Decree in Spain put a near total ban on gambling advertising – leaving Spanish players unaware of where to bet safely – the black market there now accounts for 20 per cent of all money staked.
In the same year, Denmark placed tight restrictions on legally licensed operators offering customer loyalty rewards such as bonuses – that lead the Danish Tax Authority to warn of a possible 9 per cent increase in the black market share. And in Sweden a national survey found 38 per cent of consumers who had chosen to self-exclude from legally licensed operators reported still being able to bet online with unlicensed operators – circumventing any player protection measures.

The report by PWC said: “This analysis suggests that the UK has a more ‘open’ online gambling market and currently has a smaller unlicensed market share than our European benchmarks.

“Whilst it is not possible to isolate the impact of individual regulatory characteristics, the above assessment suggests that jurisdictions with a higher unlicensed market share tend to exhibit one or more restrictive regulatory or licensing characteristics.”

As the growth of these sites has rocketed, black market sites’ revenues in Norway have more than tripled since 2010 and French black market revenues have almost doubled since 2015.

BGC Chief Executive, Michael Dugher said: “We support the Gambling Review but there is a real danger that it leads to the regulated industry being smaller and the illegal black market growing substantially. This research is stark about the dangers of the black market, we have to learn lessons from abroad, and make the right choice at this dangerous crossroads.

“BGC members alone employ nearly 120,000 people and pay £4.5bn in tax in the UK. The black market, of course, pays no tax and employs no one in our country,” he added. “Any shift to the unsafe black market would also jeopardise the £350m a year which our members currently give to horseracing in sponsorship, media rights and the betting levy – financial support which has proved crucial during the pandemic.”

Former General Counsel at the French gambling regulator Rhadamès Killy said: “When we introduced our regulations in France in 2010, we analysed that the black market was the most extensive in the European states where the statutory regime was the most restrictive.

“A balance is required to effectively regulate without promoting the black market – I believe that balance is best struck when targeted restrictions focus on support for those at risk, but not excessively hinder or punish the wider public.”

According to a recent report from the Gambling Commission, rates of problem gambling have dropped from 0.6 per cent to 0.3 per cent of the adult population suggesting that safer gambling measures introduced recently in the regulated sector have helped the decline in the rate of problem gambling.

By comparison, Norway has a problem gambling rate of 1.4 per cent, while a survey by Public Health France last year estimated that the rate in that country was 1.6 per cent – up from 0.8 per cent in 2014.

This latest research by the BGC backs similar studies across Europe that consistently show a link between stricter regulations – and a surge in black market activity.

A 2015 report comparing online betting in France between licensed and unlicensed (black market) sites concluded: “Gambling on unlicensed sites is associated with more intense gambling patterns and more gambling-related problems compared to licensed sites. Findings demonstrate that gambling activities carried out on state licensed sites are associated with less overall harm to gamblers.”

As a strict condition of their license, UK operators in the regulated industry adhere to high standards including strict ID and age verification checks, no betting on your credit card – except for National Lottery gambling products – and participation in self-exclusion schemes. Regulated operators also offer important safer gambling tools like setting deposit limits and time-outs.

The BGC is calling on Government to consider targeted measures which protect vulnerable gamblers – not a blanket approach which could force the vast majority who bet safely onto the black market.