The UK Gambling Commission (UKGC) has highlighted the impact of the Online Safety Bill on pushing black market activity further away from detection.
In July 2025, the UK government began to enforce the Online Safety Bill, which enhanced requirements for consumers to verify their age to access certain types of content online.
As a result, the Head of the UKGC’s Data Innovation Hub, Tim Livesley, noted in a blog post that the increased use of virtual private networks (VPNs) to evade these controls means that there are greater challenges in identifying black market usage by players.
Both Ofcom and Similarweb found a sharp increase in VP usage in July 2025, followed by a settling at levels around 40% above those observed before July.
This has led to the UKGC increasing its estimations of black market engagement.
Before accounting for the change in consumer activity, the UKGC estimated that consumer engagement with the black market sat at approximately 150 million minutes in January 2026.
However, adjusting for VPN usage, the UKGC believes that this figure could be closer to around 175 million minutes.
“We have noted that consumer behaviour around VPN use is undergoing a period of change related to the implementation of the Online Safety Act,” said the UKGC after publishing data related to black market trends in November 2025. “It will be important to monitor what impact this has over future months of data collection.”
Livesley was providing an update after the UKGC hosted a Spring Evidence Conference in March, attended by the Dutch gambling regulator and HMRC.
Overall, the UKGC has found no clear pattern in terms of black market engagement throughout the 21 months analysed, with the most recent spike being observed in August 2025.
Livesley emphasised that the regulator is consistently working to improve its methodology to further its understanding of the illegal market.