A new analysis has questioned the accuracy of the UK Gambling Commission’s flagship gambling survey, arguing that participation estimates are significantly higher than figures recorded by licensed operators.
The Gambling Survey for Great Britain (GSGB), launched in 2023, surveys around 20,000 respondents annually and serves as the Commission’s main source for measuring gambling participation and related harms.
Research presented by Regulus Partners analyst Dan Waugh at the UNLV Eadington Conference 2026 compared GSGB estimates with operator data. According to Waugh, the findings suggest the survey may not accurately reflect activity in the regulated market.
“The data reveals substantial over-reporting of gambling participation in the GSGB compared to what is actually happening in the regulated market,” Waugh said.
He added: “There are only two possible explanations for this. Either the survey sample is skewed or there are massive – and hitherto undetected – black markets for land-based casinos, betting exchanges and the football pools.”
Large Gaps Between Survey And Operator Figures
One area examined in the research involved casino visits. Using figures from the Betting and Gaming Council, which covers the entire licensed casino sector, Waugh compared actual attendance records with GSGB estimates.
The survey suggested between approximately 1.75 million and 2.25 million visits occurred for casino table games between July 2023 and February 2024. Recorded visits to casinos for all activities during the same period exceeded one million. Based on those figures, Waugh estimated that survey results were between 69% and 176% higher than observed attendance.
He also noted that operators estimate a significant share of casino visits do not involve table games, which would widen the gap between survey estimates and administrative data. His analysis indicated casino participation figures may have been overstated by between 408% and 628% during 2023 and 2024.
Football pools showed an even wider difference. The GSGB estimated about 863,000 players during a period in 2023, while operator records showed 109,000 customers, implying an overstatement of 694%.
For betting exchanges, Waugh estimated around 172,000 participants based on market data, compared with a GSGB estimate of roughly 612,000 users.
Concerns Over Methodology
Waugh said the results are consistent with known survey issues, including “topic salience bias,” where gamblers may be more likely to participate in gambling-related surveys. He also pointed to low response rates and selection bias.
His paper raised the possibility that some activity measured by the GSGB could occur outside the regulated market. He concluded that the evidence points to “systemic bias” affecting participation and frequency estimates and urged policymakers to consider multiple data sources, including operator records.
The Gambling Commission has defended the survey. A spokesperson previously said: “The GSGB is the largest survey of its kind in the world and has been subject to significant external scrutiny by those with recognised expertise in survey design.”
According to Next.io, the survey has also faced criticism from the Office for Statistics Regulation, which recommended that the Commission warn users that the data may overestimate gambling behaviours.
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