This article is an opinion piece by Lee Hills, CEO of leading iGaming regulatory advisory service SolutionsHub.
On 19 January 2026, the UK Gambling Commission‘s ban on mixed-product incentives came into force. The regulator’s intention is explicit. Simplify promotions, reduce player confusion, and limit potentially harmful cross-product play. A typical mixed-product incentive might offer players £20 in free football bets in exchange for spending £10 on casino slots, or vice versa.
It is difficult to challenge those objectives, yet good intentions don’t guarantee fair outcomes.
The restriction applies only to licensed UK operators. Those very businesses operate under some of the strictest regulatory, technical, and financial controls in the industry. The ones already subject to identity checks, affordability controls, safer-gambling monitoring, marketing oversight, and escalating compliance costs.
On the other hand, unlicensed operators face no such limitations. They can offer whatever bonuses they want, with no identity checks, no affordability limits, and no restrictions on how players move between products. That asymmetry matters.
One of the biggest mistakes in gambling policy is assuming that restricting regulated products reduces demand. History, economics, and recent regulatory experience suggest otherwise.
If the rules stop offering workable choices, people look elsewhere. Demand doesn’t suddenly stop. It finds another way through. It sinks to unregulated black-market websites that operate beyond UK law. It migrates to where there are no consumer protection standards or safer-gambling controls.
This pattern has happened before with stake limits and bonus restrictions.
Why does the ban create uneven pressure
Take online slots. The UK introduced statutory limits of £5 for over-25’s and £2 for younger adults in 2025. Those limits only reach the operators working under UK licences. The regulator will need more time before setting out clear causal lines, though you can already see how the situation is beginning to take shape. The UK’s unlicensed market is real, powerful, continuing business as usual, and heading in the wrong direction.
Independent estimates put the amount staked annually on illegal sites at billions of pounds, involving well over a million UK players. However, we don’t yet have a neat percentage figure for traffic flowing directly to the black market due to stake limits. What we do see is a steady pattern. When the regulated offer tightens or loses its edge, the demand doesn’t fade. It goes elsewhere, usually towards the sites with no stake limits, no checks on spending and no safety measures. That’s the part policymakers still struggle to grasp.
The mixed-product incentive ban risks becoming another incremental step in the same direction.
Regulated friction, unregulated freedom
Mixed-product incentives had a deeper role behind the scenes. They helped operators follow how people moved across different games and spot when someone’s play started to shift in a worrying direction. If a player took up a small sports offer and then moved quickly into heavier casino play, that change showed up in the data.
It sat alongside time on device, loss-chasing and spend patterns, giving safer-gambling teams a better picture of when support might be needed. Operators could intervene sooner with cooling-off messages, stake limits or direct contact before losses escalated. Removing it does remove a marketing tool, but it also removes a source of behavioural intelligence that safer-gambling teams relied on to act promptly. When the same behaviour happens on an unlicensed site, nothing is flagged, and nothing interrupts it.
Removing those tools from the regulated market does not eliminate cross-product play. It simply ensures that such play is more likely to occur where monitoring, intervention and consumer safeguards do not exist.
The result? More restrictions for licensed operators, while unlicensed sites face none.
Outcomes over intentions
The UKGC’s goals are reasonable in promoting safer gambling and better protection for vulnerable players. But good intentions mean nothing if the policy backfires. What matters is whether this actually works.
Restricting legal operators while ignoring illegal ones doesn’t reduce harm. It drives players to unregulated sites where there’s no protection at all. This has played out before when governments restrict legal products too much.
US alcohol prohibition still offers the clearest lesson. It was built on good intentions, but it handed momentum to the black market, dragged honest businesses down and pushed harm into the shadows. Say the word “prohibition”, and people tend to recognise the shape of what happens next. Close off the regulated route, leave the illegal one wide open, and the flow moves in the only direction left to it. You can feel that same pull in modern gambling arguments.
Looking at the mixed-product incentive ban, there is a noticeable absence of anything to actually tackle the black-market threat. Have we seen sudden crackdowns on illegal sites, or payment blocking, or domain disruption at scale?
Legal operators face tighter restrictions while illegal sites do whatever they want, making the black market much more appealing. Over time, the UK licence stops being valuable. It becomes a handicap. High-spending players will just gamble offshore instead.
There’s evidence that higher-value players are drifting offshore. Research from Entain and Regulus Partners says the UK’s black-market spend is roughly £2.7 billion each year. Analysis by Yield Sec suggests that close to nine percent of online gambling already happens on unlicensed sites. And the Betting and Gaming Council believes as many as two million people use illegal sites, with the bigger spenders the ones most likely to make that jump.
Principles must compete as well as control
Effective gambling regulation does not rely solely on restriction. It relies on making the regulated environment the most attractive place to play, and on a combination of safety, competitiveness, clarity, and commercial viability.
If all the UKGC does is restrict legal operators while ignoring illegal sites, the outcome is obvious. Less oversight, weaker protection for players, and a bigger illegal market.
The ban on mixed-product incentives may simplify promotions within the regulated sector, but it will not stop cross-product gambling. It will not eliminate complex promotions. It will not remove consumer appetite.
Unless policy considers the whole market players actually face, it will result in a narrower, less flexible, and less competitive regulated offer. Meanwhile, the black market offers everything that regulations have just banned. Therefore, the biggest winner will be the one over whom the regulator has the least influence.
In that sense, the outcome is predictable.
Another incremental tightening. Another competitive concession. Another win for the black market.
The views expressed are those of the author and do not necessarily reflect the views of the SiGMA News editorial team.
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