The Gambling Commission's work to tackle illegal online gambling

Request

This request relates to the Gambling Commission's work to tackle illegal online gambling through engagement with third parties, as referenced in the Commission's most recent annual report, which states that it has made" significant progress" through upstream work with third parties in finance, payment services and internet service providers.

For the period 1 January 2023 to 31 December 2025, please provide:

1. A list of the categories of third-party organisations the Commission engaged with for the purpose of disrupting illegal online gambling (for example: payment service providers, financial institutions, internet service providers, domain registrars, social media platforms).
2. The number of recorded engagements with each category of third party during this period (for example meetings, referrals, notices, or other formal interventions).
3. Any internal guidance, framework, or policy documents that set out how the Commission works with third parties to disrupt illegal online gambling.
4. Any metrics, indicators, or measures used internally to assess the effectiveness of this work.

Response

Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).

In your email you have requested information relating to the Gambling Commission's work to tackle illegal online gambling through engagement with third parties, as referenced in the Commission's most recent annual report, which states that it has made "significant progress" through upstream work with third parties in finance, payment services and internet service providers.

For the period 1 January 2023 to 31 December 2025, provide:

1. A list of the categories of third-party organisations the Commission engaged with for the purpose of disrupting illegal online gambling (for example: payment service providers, financial institutions, internet service providers, domain registrars, social media platforms).
2. The number of recorded engagements with each category of third party during this period (for example meetings, referrals, notices, or other formal interventions).
3. Any internal guidance, framework, or policy documents that set out how the Commission works with third parties to disrupt illegal online gambling.
4. Any metrics, indicators, or measures used internally to assess the effectiveness of this work.

The Gambling Commission have published a four-part series on illegal online gambling. The series, launched in 2025, set out to improve understanding of consumer engagement with illegal online gambling, the risks it poses, and the actions being taken to disrupt it. The third chapter focuses on the disruption of the market, including the categories of third-party organisations the Commission engaged with and some of the metrics used to assess the effectiveness of this work. Section 21 of the FOIA provides that information is exempt from disclosure where it is reasonably accessible elsewhere. In order to be of assistance, please see the following information available on the Gambling Commission website:

• Summary of disruption activity
• Case studies
• New tactics coming into use
• Conclusion and looking ahead

The Commission is a regulatory body with licensing, compliance and enforcement functions. Through our regulatory enforcement activity, the Commission aims to protect consumers and the wider public, and to raise standards in the gambling industry. Part of our statutory remit and a key licensing objective is to keep crime out of gambling. When consumers access potentially illegal gambling sites, they expose themselves to many risks and are not afforded the protections in place that are expected in the regulated sector.

I can confirm that the Commission does hold further information falling within the scope of your request. However, releasing this level of detail would reveal the methods and techniques the Commission uses as part of regulatory work. We are of the view that the disclosure of this information would prejudice the regulatory functions of the commission. As such, this information is exempt under section 31 of the FOIA.

Section 31

Section 31(1)(g) exempts information whose disclosure would, or would be likely to, prejudice the exercise by any public authority of its functions for any of the purposes specified in subsection (2).

The Commission considers the subsections below apply and therefore the information is exempt from disclosure:

i. Subsection 31(2)(a) refers to the purpose of ascertaining whether any person has failed to comply with the law,

ii. Subsection 31(2)(b) refers to the purpose of ascertaining whether any person is responsible for any conduct which is improper,

iii. Subsection 31(2)(c) refers to the purpose of ascertaining whether circumstances which would justify regulatory action in pursuance of any enactment exist or may arise, Public interest test

The factors the Commission has considered when applying the public interest test have been detailed below.

Arguments in favour of disclosure:

• The Commission is a public body which is required to regulate the gambling industry in the public interest. There is therefore a public interest in members of the public having confidence the Commission is being open and honest with the information it holds so that it can be held to account.
• Furthermore, this disclosure may encourage stakeholders to work with us and contribute to our programme of work, increasing confidence in the Commission as a regulator and its ability to uphold the law.

Arguments in favour of maintaining the exemption:

• There is an expectation of confidence in much of the Commission’s work, particularly when discussing potential areas of non-compliance with the LCCP. It is the impact on this work of the Commission which is more likely to be affected by disclosure.
• The Gambling Commission’s statutory obligations as set out in section 22 of the Gambling Act 2005 are:

i. preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime,

ii. ensuring that gambling is conducted in a fair and open way, and

iii. protecting children and other vulnerable persons from being harmed or exploited by gambling.

• The Commission will not disclose information if it might jeopardise these important functions. Disclosure of this information would also undermine the Commission's ability to uphold these objectives, which would impact on the trust and confidence of the public in it as a regulator.
• The Commission has robust and effective processes and procedures in place which are utilised as part of our strategy to tackling illegal markets. These procedures and processes have been put in place to minimise the risk of a product being offered without an appropriate licence.
• It could seriously impact the Commission’s investigation process, if details of what information it uses to inform its regulatory activities became known; this is strongly not in the public interest as it would impair the Commission’s ability to regulate effectively
• The Commission routinely provides updates to the public about its regulatory actions. It considers that the public interest in transparency, accountability, and public awareness of how the Commission handles regulatory concerns is therefore met by this level of disclosure.

Weighing the balance

The Commission acknowledges that there is a public interest in promoting the accountability and transparency of public authorities and the importance of having sufficient information in the public domain to support consumers with their choice of operator. However, disclosure of the information would be damaging to the Commission as a regulatory body which ultimately serves to protect the wider public interest. We consider that the public interest is better served by withholding this information.

Further information on how the Commission tackles illegal gambling can be found on our website, here: How we tackle illegal gambling.

Review of the decision

If you are unhappy with the service you have received in relation to your Freedom of Information request you are entitled to an internal review of our decision. You should write to FOI Team, Gambling Commission, 4th floor, Victoria Square House, Victoria Square, Birmingham, B2 4BP or by reply to this email. 

Please note, internal review requests should be made within 40 working days of the initial response. Requests made outside this timeframe will not be processed.

If you are not content with the outcome of our review, you may then apply directly to the Information Commissioner (ICO) for a decision. Generally, the ICO cannot make a decision unless you have already exhausted the review procedure provided by the Gambling Commission. 

It should be noted that if you wish to raise a complaint with the ICO about the Commission’s handling of your request for information, then you are required to do so within six weeks of receiving your final response or last substantive contact with us.

The ICO can be contacted at: The Information Commissioner’s Office (opens in new tab), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Information Management Team
Gambling Commission

Internal Review Request

I would like to request an internal review of the decision to withhold information under section 31.

While I understand the sensitivity of operational methods, I would ask that the Commission reconsider disclosure of high-level aggregated information, including:

The number of recorded engagements with each category of third party during the period specified Any aggregated metrics or indicators used to assess effectiveness (e.g. counts of referrals, takedowns, payment blocks)

It is not clear how disclosure of statistical summaries, without case-specific or tactical detail, would prejudice the Commission's regulatory functions.

I would also be grateful for clarification as to whether the published blog materials cited under section 21 fully satisfy each element of my request.

Internal Review Response

I am writing to you further to your Freedom of Information request dated 20/01/2026 which we responded to on 17/02/2026, and your subsequent request for an internal review received on 17/03/2026.

We have now concluded our review and our findings are detailed below.

This internal review was conducted by someone who was not involved in the processing of your original request.

In your initial email you requested information relating to the Gambling Commission's work to tackle illegal online gambling through engagement with third parties, as referenced in the Commission's most recent annual report, which states that it has made "significant progress" through upstream work with third parties in finance, payment services and internet service providers. Specifically, for the period 1 January 2023 to 31 December 2025:

1. A list of the categories of third-party organisations the Commission engaged with for the purpose of disrupting illegal online gambling (for example: payment service providers, financial institutions, internet service providers, domain registrars, social media platforms).
2. The number of recorded engagements with each category of third party during this period (for example meetings, referrals, notices, or other formal interventions).
3. Any internal guidance, framework, or policy documents that set out how the Commission works with third parties to disrupt illegal online gambling.
4. Any metrics, indicators, or measures used internally to assess the effectiveness of this work.

In our initial response we confirmed that information falling within the scope of your request was held by the Commission. However, the Commission was of the view that releasing this level of detail would reveal the methods and techniques the Commission uses as part of its regulatory work. As such, our view was that the information is exempt from disclosure under section 31(1)g of the FOIA (‘law enforcement’) and therefore will not be released.

Within your request for an internal review, you have asked us to reconsider the following:

• The number of recorded engagements with each category of third party during the period specified
• Any aggregated metrics or indicators used to assess effectiveness (e.g. counts of referrals, takedowns, payment blocks)
• Disclosure of statistical summaries, without case-specific or tactical detail
• Clarification as to whether the published blog materials cited under section 21 fully satisfy each element of your initial request.

Internal Review

After reviewing your request and our response, I uphold our original decision to engage the section 31(1)g exemption. My considerations for this decision are detailed below. Section 31(1)(g) exempts information whose disclosure would, or would be likely to, prejudice the exercise by any public authority of its functions for any of the purposes specified in subsection (2).

In our initial response, we considered that the following subsections are engaged:

i. Subsection 31(2)(a) refers to the purpose of ascertaining whether any person has failed to comply with the law,

ii. Subsection 31(2)(b) refers to the purpose of ascertaining whether any person is responsible for any conduct which is improper,

iii. Subsection 31(2)(c) refers to the purpose of ascertaining whether circumstances which would justify regulatory action in pursuance of any enactment exist or may arise.

As this is a qualified exemption, we considered the following public interest arguments for and against disclosure.

Arguments for disclosure

There is a legitimate public interest in promoting accountability and transparency of public authorities and disclosure of the requested information could demonstrate to stakeholders and relevant parties that the Commission was active in its regulatory functions. Furthermore, increasing confidence in the Commission as a regulator and its ability to uphold the law.

Arguments against disclosure

Discussing within the public domain specific information relating to regulatory practices may deter key stakeholders from sharing important material with us, as such prejudicing our regulatory functions. Disclosure of the requested information may prejudice the outcome of any future work by the Commission, or another body, by exposing techniques and practices to the detriment of the public interest.

The Commission has robust and effective processes and procedures in place which are utilised as part of our strategy to tackling illegal markets. These procedures and processes have been put in place to minimise the risk of a product being offered without an appropriate licence.

It could seriously impact the Commission’s investigation process, if details of what information it uses to inform its regulatory activities became known; this is strongly not in the public interest as it would impair the Commission’s ability to regulate effectively.

The Commission also routinely provides updates to the public about its regulatory actions. It considers that the public interest in transparency, accountability, and public awareness of how the Commission handles regulatory concerns is therefore met by this level of disclosure. Within your initial request, you were provided with the following website links:

• Summary of disruption activity
• Case studies
• New tactics coming into use
• Conclusion and looking ahead

These links were provided to you in order to be of additional assistance in directing you to any published relevant information relating to your request.

The Commission considered that on balance, the disclosure of this information ‘would prejudice’ its regulatory functions and, therefore, considered the information to be exempt under S31(2)(a), (b) and (c).

We concluded that, having considered the arguments for and against disclosure of the requested information, the Commission’s view is that the public interest is best served through maintaining this exemption.

In reviewing the information we hold, we have reconsidered the arguments detailed above and agree with the application of S31(2)(a), (b) and (c). Providing this information could seriously impact on the Commission’s ability to fulfil its statutory functions.

The Commission values transparency and will always publish information where able. Further information on how the Commission tackles illegal gambling can be found on our website, here: How we tackle illegal gambling. In particular, please see the following published information in relation to our impact metrics related to unlicensed gambling, here: Activity to tackle unlicensed gambling and outcomes.

If you are not content with the outcome of your review, you may apply directly to the Information Commissioner (ICO) for a decision. Generally, the ICO cannot make a decision unless you have exhausted the complaints procedure provided by the Gambling Commission. The ICO can be contacted at www.ico.gov.uk or at: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF.

Yours sincerely,

Information Management Team
Gambling Commission