Tighter regulations and rising taxes continue to play a crucial part in fuelling the black market, driving players away from the regulated sector to seek bigger returns and less obstructions elsewhere. So why should the legitimate industry pay to police it? It’s a question that has vexed Peter Hannibal, Chief Executive of the Gambling Business Group. He argues that the global spread of illegal gambling and the criminal engagement through dens and online sites is a world away from the UK’s regulated high street operators. The enforcement must come from government funds.
The ‘polluter pays’ principle, suggested by the Gambling Commission and approved by the government for the industry’s statutory levy, puts the burden of costs on those most to blame – so who should pay to police the growing black market?
The DCMS’s ‘preferred option’ as it consults the industry on proposals to raise Commission fees, is that 10 percent of a 30 percent increase should be ringfenced to combat unlicensed operators. Other options include a straight 20 percent or 30 percent increase, the latter of which is preferred by the regulator. However, under every option – ringfencing or not – the industry is being called upon to foot the black market bill.
That is not the way forward, argues Gambling Business Group Chief Executive Peter Hannibal.
The Gambling Commission fee increase, he argues, will arrive on top of higher regulatory demands and upcoming tax rises. And it’s these changes, implemented by the government and the Commission, that many commentators in the industry are pointing to as the cause for driving significant black market expansion in recent years, with unlicensed operators popping up faster than the regulator can take them down.
In his commentary in Coinslot this week, Hannibal asks the fundamental question: why should compliant operators pay for a problem that is run by illegal organisations who are neither part of the industry nor observe the legislation and regulatory rules. And, worse, many of whom run their activities from across the world.
“Licensed operators are not the cause of the black market. They are regulated, compliant businesses operating legitimately within the law,” Hannibal notes. “Yet they are being asked to fund enforcement action against illegal and unlicensed activity.The statutory gambling levy was introduced on the principle of ‘polluter pays’. But in this case, licensed operators are not the polluter. It cannot be right that those who follow the rules are required to fund action against those who ignore those same rules.”
The DCMS consultation on GamCom fees runs until 29 March 2026, with changes expected to take effect from October if approved.
“I would encourage all stakeholders to consider the wider implications carefully and respond to the consultation accordingly,” advised Hannibal. “In most sectors, legitimate businesses are not required to pay for the policing of criminal competitors. Why should gambling be different?”
And equally important is the inconsistency of the DCMS and Commission arguments for increased funding to fight an illegal black market which, in the main, is being played out on a global stage.
The question will obviously be raised as to why the UK Gambling Commission is looking to engage on a campaign to tackle a global black market – using funds raised from, amongst others, small to medium sized high street operators.
It’s a model that certainly requires convincing explanation – not much of which, in fairness, emerged during this week’s BGC AGM when the matter was raised.
But it will continue to dominate the discourse throughout the Commission licence fee consultation process. The argument that the legitimate industry should pay for the battle against the illegal market, much of which operates overseas, has little traction at present, particularly in the absence of a coherent strategy from either the regulator or the government.
Who’s the real polluter?
Peter Hannibal said……. “Why are the UK’s legitimate, regulated land-based operators on our high streets being asked to pay for the war against an online black market which is being run out of countries all over the world?
Originally published on Coinslot on March 2, 2026. Republished with permission.