The 522% number nobody wants to explain
Traffic to websites accepting bets on British horse racing from unregulated sources rose 522% between August 2021 and September 2024. That figure, from an IFHA study published via the British Horseracing Authority in February 2025, is the single most telling statistic in the current UK racing regulatory debate. It describes the growth of a market that does not contribute to the Levy, does not respect self-exclusion tools, and does not protect the punters who use it.
Most punters I speak to have an instinctive position on the black market: they either refuse to engage with it because they understand the risks, or they drift toward it because the friction of the regulated system has become too much. The middle ground is shrinking. This piece is about what the black market actually is, how the recent growth is measured and what it means for punters trying to stay inside the regulated system.
How the black market is measured
The 522% figure comes from specific methodology. IFHA (International Federation of Horseracing Authorities) commissioned an analysis of traffic patterns to websites accepting UK racing bets that were not licensed by the UK Gambling Commission. The study tracked traffic growth over a three-year window, applying filters to identify UK-originating visits and to distinguish betting activity from casual browsing.
The figure is a traffic multiplier, not a direct GGY measurement. It tells you that unregulated platforms received 6.2 times as many UK visits in September 2024 as they did in August 2021. It does not tell you exactly how much money was wagered, because unregulated operators do not file the same disclosure returns as UKGC-licensed firms.
The Betting and Gaming Council has attempted to put a figure on the turnover implication. For the 2025 Cheltenham Festival alone, the BGC estimated £60 million was wagered through unregulated operators. Extrapolated across the full year, that kind of flow implies substantially more than £1 billion of unregulated turnover on British racing annually – money that is not captured by the Levy (£108.9 million yield in 2024-25) nor by the £766.7 million horse racing remote betting GGY recorded by UKGC-licensed operators.
Who moves there and why
The BHA’s Right to Bet Survey, conducted jointly with the Racing Post, Racing TV and At The Races across more than 14,000 respondents, produced some of the clearest data on who is moving and why. 9% of respondents reported having already used unregulated bookmakers; 12% said they had been approached by unregulated operators. Both figures had risen sharply over the preceding two years.
The driver most commonly cited is the affordability-check regime. 52% of bettors surveyed said they would significantly reduce or stop betting if affordability checks were implemented in the form proposed; 61% reported they would refuse to provide financial documents if asked (down from 66% in 2023, but still a clear majority). The affordability-check threshold itself moved sharply: £500 monthly deposits in August 2024, tightened to £150 by February 2025.
For the punter who previously deposited £300 a month without friction, the current £150 threshold means that almost every month of normal activity triggers a potential check. Some respond by reducing activity. Others respond by splitting activity across multiple licensed operators. A growing minority respond by moving to unregulated platforms that do not conduct the checks.
The Racing Post Big Punting Survey 2025 added further numbers. 23.7% of respondents had been subject to affordability checks, up from 16.6% in 2023. The checked population is disproportionately the higher-stakes, higher-engagement segment that historically generated the majority of racing betting turnover. When they reduce activity or move offshore, the proportional impact on the regulated market is larger than the headcount suggests.
Festival level exposure
The £60 million BGC figure for the 2025 Cheltenham Festival represents a specific concentration of unregulated activity around major events. Festivals produce betting turnover spikes; they also produce unregulated activity spikes, because the marketing environment around big events drives searches for better prices or fewer restrictions, and unregulated operators target that traffic.
William Hill’s spokesperson Lee Phelps, previewing the 2026 Cheltenham Festival, said: “We expect around £450 million to be wagered across the four days of the 2026 Festival. The contest between bookmakers and punters at Cheltenham is unrivalled in jump racing.” If £60 million-plus of that £450 million flows through unregulated channels, the proportion is over 13% – a substantial leak that directly costs the regulated market, the Levy and racing’s prize money.
The Grand National produces similar concentrations. Approximately £250 million is wagered on the race annually, roughly seven times the Cheltenham Gold Cup’s total. The single-race focus attracts both casual money and unregulated targeting. With the 2026 Grand National field capped at 34 runners and prize fund of £1 million (£500,000 to the winner), the race’s commercial significance makes it a particular target for black-market operators offering “enhanced” terms without the regulatory constraints.
Risk to the punter
The practical risks of betting with an unlicensed operator fall into four categories: financial, behavioural, legal and integrity-related.
Financial risk is the most immediate. Unregulated operators are not required to segregate customer funds, and there is no IBAS or equivalent dispute resolution. A punter who deposits £500 with an unregulated site and wins £3,000 has no regulated pathway to collect if the operator refuses to pay. Stories of non-payment on significant winnings from unregulated operators are common and frequently documented in racing publications.
Behavioural risk is the self-exclusion problem. A punter who has self-excluded via GAMSTOP is automatically blocked from every UKGC-licensed operator, but unregulated sites are outside that framework. Self-exclusion’s effectiveness as a harm-reduction tool depends on the unregulated sector remaining small; as it grows, the tool becomes less effective for the very population it is designed to protect.
Grainne Hurst, CEO of the Betting and Gaming Council, has made the same point across multiple 2025 statements: “The only winner from this Budget is the black market – they’ve hit the jackpot. The losers are customers who will now be exposed to greater risk, communities that rely on jobs and investment, and sectors like racing that depend on a strong regulated industry.”
Legal risk is modest but real. Betting with an unlicensed operator is not a criminal offence for the individual punter, but using unregulated platforms to bet on fixed or corrupted races carries exposure under the Gambling Act’s integrity provisions. Integrity risk – the possibility that the operator is running corrupted markets or laundering funds through the bet flow – is the hardest risk for an individual punter to assess.
Policy response so far
The Autumn Budget 2025 set out the government’s first formal response to the black-market growth. HM Treasury allocated £26 million to counter-black-market activity, alongside the increase in Remote Gaming Duty to 40% from April 2026. The Treasury’s own forecast projected an additional £500 million of unlicensed activity as a consequence of the duty changes.
The BHA and the BGC have both criticised the response as insufficient. The £26 million allocation is a fraction of the estimated £1 billion-plus annual unregulated turnover; enforcement against offshore-based operators targeting UK customers is structurally difficult, and the Commission’s enforcement actions against named unregulated platforms have been limited.
BHA Chief Executive Brant Dunshea has framed the policy trajectory bluntly: “Adding more red tape to an already highly regulated sector will only fuel a significant rise in illegal betting, deprive horseracing of funding and prevent the Government collecting millions of pounds in much-needed taxation.” The argument is that the regulated market’s competitiveness has to be preserved if the black market is not to grow further; conversely, continued tightening of affordability and tax measures on the regulated sector will accelerate the migration that is already well underway.
For the individual punter, the policy debate matters less than the practical question of where to bet. Staying with UKGC-licensed operators despite the friction is the only way to retain the protections the regulated market provides. The pillar on betting at horse racing covers the wider market context.
Articles
Written by the editors at bettingathorseracing.com.
