UK Regulator Faces VPN Challenge in Tracking Illegal Gambling

UK Gambling Commission Flags Rising VPN Use – Measurement of Illegal Gambling Becomes More Uncertain

Key Takeaways

• The UK Gambling Commission says increased VPN use is making it harder to measure illegal online gambling activity.
• The regulator has already built a 30 percent VPN adjustment into its methodology and revised assumptions using data from Ofcom and Similarweb.
• Experts disagree on whether VPNs significantly undermine enforcement or are overstated in the black market debate.
• The UK Online Safety Act has contributed to a broader rise in VPN adoption, affecting traffic analysis beyond gambling.

UK Gambling Commission Revises Methodology as VPN Use Grows

The UK Gambling Commission has acknowledged that rising use of virtual private networks is complicating its efforts to assess the scale of illegal online gambling. In its latest update on illegal gambling trends, published in April, the regulator pointed to increased VPN adoption as a factor that reduces visibility of online traffic.

VPNs allow users to mask their location and encrypt internet traffic. While widely used for privacy and cybersecurity, they can also be used to bypass digital restrictions, including gambling-related geo-blocking and age-verification requirements.

The Commission does not directly measure illegal gambling volumes. Instead, it relies on traffic estimates and trend analysis. It has already incorporated a 30 percent adjustment for VPN usage into its methodology. However, following the implementation of the UK Online Safety Act, the regulator noted that a larger share of web traffic may be concealed. It therefore revised its assumptions using VPN usage data from Ofcom and Similarweb.

The result, according to the Commission, is greater uncertainty rather than a clearer picture of black market activity.

Reduced Visibility Does Not Automatically Indicate Market Growth

Legal and technology experts differ in their assessment of how VPN growth affects enforcement and market integrity.

Melanie Ellis, partner at Northbridge Law, stated that significant VPN use makes web traffic data an unreliable tool for assessing the size of the black market. She said the Commission will need to rely more heavily on consumer research and information from licensed operators.

James Baker, programme manager at the Open Rights Group, cautioned against interpreting reduced visibility as proof of increased illegal gambling. He said policymakers should improve measurement methodologies and use multiple evidence sources, rather than assume activity has grown simply because it has become harder to track.

This distinction matters for regulatory policy. If measurement challenges are misinterpreted as market expansion, authorities could respond with stricter controls without clear evidence of increased illegal participation.

Technology Providers Highlight Enforcement and Detection Tools

From a compliance technology perspective, GeoComply vice president Elizabeth Cronan argued that VPNs do not inherently undermine regulated markets. She said modern geolocation systems are designed to detect VPNs, proxies, remote desktop tools, and other forms of location manipulation. In regulated markets such as the United States, licensed operators are required to verify a customer’s true location before accepting a wager, and regulators audit those controls.

Mike Venner, director at Advanced Compliance Technology, took a more critical view of existing enforcement frameworks. He said basic geolocation checks are no longer sufficient in an environment where location spoofing tools are widely available. Venner called for real-time, multi-layered systems combining location, network, device, identity, and behavioural intelligence to uphold compliance standards.

Bethan Lloyd, partner at Wiggin, also noted that VPN providers continuously adapt their technology, including rotating IP addresses and obfuscating traffic to resemble standard encrypted connections. She said detection methods often struggle to keep pace. At the same time, she argued that it is not the responsibility of licensed operators to police the wider black market.

Some Industry Figures Question the Central Role of VPNs

Not all observers consider VPNs a primary driver of illegal gambling access.

Ismail Vali, president of Gaming Compliance International, described VPN use as overstated in the context of black market gambling. He pointed to latency issues that can degrade user experience in live sports betting, live dealer games, slots with community features, and poker. According to Vali, delays can lead to closed betting windows, lagging streams, and additional friction from compliance checks.

He also argued that in many countries, users can access unlicensed gambling websites without needing a VPN. In his assessment, offshore availability rather than circumvention tools represents the core enforcement gap.

Online Safety Act Drives Broader VPN Adoption

The debate extends beyond gambling regulation. The UK Online Safety Act introduced stricter age-verification requirements, which, according to several stakeholders, increased demand for VPN services.

Cronan said the implementation of the Act led both minors and adults to use VPNs to bypass mandatory age checks. She added that this broader adoption may also have increased VPN use for accessing offshore gambling platforms.

Venner linked this trend to wider enforcement challenges across digital regulation, including adult content controls. In his view, the same weaknesses exposed by VPN growth apply across multiple regulatory frameworks.

At the policy level, a proposed consultation from the Department for Science, Innovation and Technology would require VPN providers to age-verify users. Cronan argued that such a requirement could drive users toward less regulated tools such as Tor and unregulated proxy services, potentially raising data security and privacy concerns.

Ofcom has clarified that VPNs are lawful services in the UK and that decisions on restrictions fall to the government rather than to the Online Safety Act framework itself.

Our Assessment

The UK Gambling Commission’s latest update shows that increased VPN adoption has made measurement of illegal online gambling more complex and uncertain. While the regulator has adjusted its methodology, it acknowledges limitations in traffic-based analysis. Stakeholders remain divided on whether VPNs represent a significant enforcement gap or a secondary factor in black market access. For licensed operators and users, the discussion highlights ongoing tension between privacy tools, regulatory compliance, and the practical challenges of enforcing geo-restricted gambling markets.