Landman Economics researcher Howard Reed has challenged the credibility of a World Advertising Research Centre report predicting illegal gambling advertising will surpass the licensed sector.
The WARC report, titled “The ad spend disconnect,” forecast that UK black market gambling advertising expenditure would outstrip the licensed industry by 2028.
Reed’s critique was commissioned by Derek Webb’s Campaign for Fairer Gambling, and it targets the report’s lack of methodological transparency in its forecasting.
Reed, the former chief economist for the Institute for Public Policy Research, argues the research is “flawed” because the methodology behind its predictions is never properly explained.
His response also highlights that the WARC report “fails to distinguish between the gambling regulatory regime for Great Britain and Northern Ireland, which is separately regulated.”
WARC defended its work, stating that its data “has been trusted by the world’s largest brands, media owners, advertising agencies, government organisations and academic institutions for over forty years.”
The company added that “the study was commissioned to measure the UK as a whole and not Great Britain exclusively,” pushing back against Reed’s jurisdictional criticism.
WARC’s methodology draws on Nielsen Ad Intel, the Interactive Advertising Bureau, Radiocentre, Thinkbox, and data sourced directly from gambling companies themselves.
The report forecasts that total sector advertising investment will grow to £2.2bn, including sponsorship and affiliate marketing, for the period between October 2025 and September 2026.
Of that figure, WARC predicts roughly £1bn will come from the unregulated market, representing 27.7% year-on-year growth against a 9.4% decrease from regulated operators.
Since unlicensed operators do not report expenditure to regulators or tracking bodies, measuring the growth of illegal market ad spend presents an obvious and significant challenge.
Reed notes: “Therefore, accurate estimation of the size of the gambling advertising spend by unregulated operators relies on other empirical techniques (such as ‘web-scraping’ – the automated extraction of data from gambling websites); these are mentioned in the report, but not explained at all.”
The forecasting figures are also difficult to interpret, with predicted unregulated expenditure growth slowing sharply from 28% between 2024/25 and 2025/26 to just 8% the following year.
WARC states its forecasting approach “leverages machine learning capabilities aside the expertise of its in-house analytic team to produce two-year advertising spend forecasts across all 100 markets, updating on a rolling basis each quarter.”
Without further disclosure of methods and underlying data, understanding the reason for that projected slowdown remains impossible.
The Betting and Gaming Council published the WARC report and referenced the decline in regulated operator ad spend as a consequence of tax pressures facing the industry.
Reed claims the implicit argument of the study is that unregulated market growth “is proof that the regulated gambling sector is over-regulated,” though that conclusion does not appear explicitly in the report.
The report itself only references a “widening structural divide within the market,” stopping short of drawing the regulatory conclusions Reed attributes to it.
The BGC has nonetheless cited the study while lobbying government and the Gambling Commission to redirect regulatory focus toward the illegal gambling market.
Reed counters that the correct interpretation is simply that the “unregulated gambling sector is under-regulated,” a position that many regulated industry stakeholders broadly share.
WARC claims that “unregulated firms are set to account for all growth in sponsorship spend this year and next and will account for more than half of spend by October 2027.”
Reed argues that action on sponsorship deals involving unlicensed operators is overdue, stating: “This is another case where more stringent regulation is needed. It would be relatively simple for the UK government to ban sponsorship of sports teams by unlicensed betting firms.”
Despite the Premier League’s voluntary front-of-shirt gambling sponsorship ban, many English football clubs continue partnerships with unlicensed operators in other capacities, including sleeve deals.
Stake, for example, will move from the front of Everton’s shirts to the sleeves next season, illustrating how clubs are navigating around rather than away from such arrangements.
