Behind the numbers: New report fuels Europe’s black market enforcement debate
Europe’s online gambling market is increasingly being shaped by a contest taking place largely outside the boundaries of national gambling licences.
The scale of that contest is the subject of a new report from the Campaign for Fairer Gambling – an organisation that campaigns for reform to reduce harm and inequity across online gambling marketplaces.
The analysis estimates that, in 2025, unregulated operators accounted for €91.6 billion of gross gambling revenue in the EU’s 27 member states, compared with €36.5 billion for regulated operators.
That would put the unregulated sector at 72% of the total €128 billion online gambling marketplace. It is a striking figure, and one that is attracting scrutiny from the industry – something the Campaign fully expects.
Ismail Vali, president of Gaming Compliance International (GCI), which carried out the analysis, welcomes the scrutiny.
“For years, the unregulated sector has often been discussed using broad estimates, partial datasets or individual operator and traffic measures. We are putting a quantified value on the total marketplace, using the same methodology across regulated and unregulated activity.”
The team behind the report has combined specialist human analysis, machine learning and AI with marketplace monitoring, benchmarking and increasingly extensive third-party data.
“And we deliberately publish the lower end of our modelled range rather than the upper end. What we are looking to do is to get to this point: you are all being stolen from,” says Vali.
The report argues that the scale of the market is evidence not simply of offshore operators evading national regulators, but of a systemic failure to police the digital gambling marketplace.
How big is Europe’s gambling black market?
GCI’s claim that €91.6 billion, or 72% of EU online gambling revenue, goes to unlicensed operators exceeds other estimates.
A Regulus Partners/Helios study for Euromat, published this month, puts Europe’s illegal online market at €12 billion, or 25%, while H2 Gambling Capital estimates the number to be about €18 billion (27%).
National figures point the same way: PwC puts France’s illegal market at €2 billion, Germany’s regulator puts unlicensed revenue at €547m for 2024 and the Dutch regulator puts it at €617m for the first half of 2025.
The European Gaming and Betting Association (EGBA), which represents online gambling operators in the EU, says the report sits at the top of a wide range.
“Illegal gambling is hard to measure by its nature, which is why there have been so many studies about it, with widely varying results,” an EGBA spokesperson says. “Other studies put the illegal market at around a quarter of Europe’s online gambling revenue.”
Unpacking the methodology
Much of the gap comes down to methodology. GCI converts web traffic and audience activity into revenue using a “value per visit” benchmark. In its own reporting, the UK Gambling Commission, reviewing traffic-based approaches in general, found key limitations, including no insight into app use by illegal sites.
The scale of GCI’s total market also stands out: it puts EU online gambling at €128 billion in 2025, while EGBA/H2 data put online at 39% of Europe’s €123.4 billion gambling market in 2024 – about €48 billion. That figure includes the UK, which GCI’s data does not.
“The work should be judged on the methodology and the evidence, not on the identity of the messenger,” says a GCI spokesperson. “Anyone who believes €91.6 billion is wrong should test the methodology, produce a competing total-marketplace analysis, and show where the difference comes from.”
The numbers may be contested, but there is broad agreement on the direction of travel.
“Illegal activity is substantial and growing, and for us it is the biggest challenge facing the sector today,” the EGBA spokesperson adds.
Carl Brincat, senior director of legal and regulatory affairs at LeoVegas, strikes a similar note. “Putting a definitive figure on an activity that is by nature undisclosed and hard to trace is genuinely difficult, so we’d treat any single number with some caution – although the underlying trend it describes is real.”
A failure of enforcement
Derek Webb, gambling industry veteran and founder of the Campaign for Fairer Gambling, believes the problem with illegal gambling in Europe is a lack of coordinated enforcement across the digital ecosystem in which gambling now operates.
“We should have the philosophy that governments need to be capable of reacting to change at precisely the moment when the need to do things is accelerating because of innovations in social media, AI and crypto.”
The report argues that illegal gambling depends on a much broader commercial infrastructure: affiliates, advertising platforms, payment providers, app stores, search engines, social media, streaming services and technology suppliers.
“We need to attack the companies that are enabling this and making money from it,” he says. “The online advertisers, cloud companies, payment processors and other parts of this ecosystem are all laid out in the report,” says Kieran O’Keefe, an adviser to the Campaign for Fairer Gambling.
In the Netherlands, gambling trade body VNLOK has initiated legal proceedings against Meta, for it allowing illegal gambling site ads to be shared across its social media platforms, even after being flagged.
Borut Petek, chief global affairs officer at Super Technologies and a member of the EGBA board, describes the report as “a wake-up call for Europe”.
“Chasing individual websites is not enough,” he says. “The illegal market operates across borders, so enforcement must increasingly focus on the infrastructure that enables it: payments, affiliates and digital distribution, advertising platforms, technology and game suppliers, as well as on stronger cooperation between national authorities.”
Should governments tax the sector more?
Where the Campaign and the licensed industry part company is on what should happen next.
The Campaign for Fairer Gambling is not simply arguing that governments should do more to protect licensed operators from offshore competition. It is also arguing that, if enforcement reduces the unregulated market, governments could have greater scope to raise revenue from the legal sector.
“The beauty of fiscal policy is that if you’re not taxing the sector much, you don’t worry about losing much of it,” Derek Webb says. “If you actually tax the sector adequately, all of a sudden the affiliates might get more interested in saying, ‘We’ve got to stop losing this revenue.'”
That argument meets scepticism in an industry already facing higher gambling taxes in several European markets. Operators have long warned that increasing the cost of regulated gambling can weaken licensed businesses and potentially make unlicensed alternatives more attractive.
Petek puts that case bluntly.
‘Let’s not make the problem worse’
“Higher taxation of licensed operators will only make the problem worse,” he says. “If governments continue to increase the cost of operating legally while illegal operators pay no taxes and carry none of the regulatory burden, they make the illegal offer more competitive.”
The priority, he argues, should be keeping as much play as possible inside the regulated system, “where customers are identified, consumer protections apply and taxes are paid”. Any further fiscal or regulatory measures, he says, should be assessed against their impact on channelisation and the competitiveness of the legal market.
According to EGBA, the legal market is already under significant pressure from illegal operators, who undermine consumer protection, pay no tax and carry no compliance costs. “Every tax increase on legal operators widens that competitive gap, showing up as weaker odds and bonuses for players and making illegal sites – which are increasingly visible – more attractive,” its spokesperson says.
Enforcement over taxation
The association’s answer is enforcement rather than taxation.
“Tackling illegal online gambling requires effective enforcement, greater cooperation and action on the platforms, payment providers and other intermediaries that allow illegal operators to reach European players. The goal must be stable, proportionate rules that keep players in the safer, regulated market.”
A spokesperson for the Betting and Gaming Council, the UK gambling trade body, makes a similar case.
The report, it says, demonstrates the need for enforcement to look beyond individual illegal operators, but the BGC also appeals for caution when it comes to tighter fiscal measures.
“Illegal operators rely on affiliates, advertising, social media, payments and technology platforms to reach customers, so action must target the wider ecosystem that supports them. At the same time, government must keep the regulated market competitive through proportionate regulation and stable taxation.”
Operators make the same case. “We support clear and strong regulation, but reading these findings as a case for tighter fiscal measures on licensed operators would be a mistake,” says Brincat.
UK tax increase is funding black market enforcement
A spokesperson for Betsson Group also passes comment: “Any proposal to increase their costs should therefore be assessed against clear evidence of how players actually behave and whether it improves channelisation and player protection. The briefing does not establish that higher taxes would pass that test.”
O’Keefe acknowledges how provocative the Campaign’s position can seem. “I’m sure the online industry probably tears its hair out every time we open our mouth on this subject,” he says.
Webb acknowledges that a tougher fiscal policy “is the complete opposite of the way the trade wants to handle it”, but he rejects the logic of the operators.
He points to Britain as an example, arguing that when the tax rate increased from 21% to 40%, the Treasury subsequently provided £26 million to the Gambling Commission and the Department for Culture, Media and Sport to address the illegal market.
He advocates for an EU-wide tax on remote gambling combined with stronger enforcement.
Who is using the black market?
For Ismail Vali, the problem is more concentrated than the headline numbers suggest. He argues that illegal gambling is increasingly reaching audiences that cannot be served by conventional licensed operators, particularly children and self-excluded players.
“We found that in the UK 94% of unregulated gambling activity was concentrated among children and self-excluded players.”
According to Vali, these groups provide illegal operators with an unusually attractive acquisition opportunity precisely because they are excluded from the regulated market.
The mechanism, he says, is increasingly sophisticated. Illegal gambling brands can use affiliates, social media, streaming and other digital channels to find consumers without competing directly with the enormous advertising budgets of mainstream operators.
Illegal streaming creates another route into the market. Exclusive sports rights can leave consumers looking for alternatives, while streaming platforms can become acquisition channels for gambling brands.
The broader point is that the Campaign sees illegal gambling as an ecosystem rather than a collection of websites. Cut off one route and, it argues, another can emerge.
That is why Webb believes enforcement needs to move beyond gambling regulators. Affiliates, he argues, should themselves be licensed.
“How do we know that an affiliate isn’t financing terrorism or an organised crime entity?” he asks.
A European response
Vali and O’Keefe both point to evidence of Russian-linked gambling operations and their proximity to other forms of illicit online activity.
“This is an enforcement failure in Europe,” he says. “That’s what this is.”
The proposed remedy is expansive: monitor the whole marketplace, enforce against the infrastructure supporting illegal operators and then measure whether interventions actually shift consumers back towards regulated services.
The political question is whether Europe is willing to do that collectively.
That is ambitious in a sector where gambling remains largely a national competence. Yet the underlying infrastructure is plainly transnational. Advertising, payments, social platforms, affiliates, cloud services and streaming do not stop at national borders, as Webb points out.
Petek, whose company has taken a more active role in EU affairs through its EGBA board seat, makes a similar point, although he stops short of calling for EU-level gambling regulation.
“Gambling regulation remains primarily the responsibility of member states, but the illegal online market does not respect national borders,” he says. “Stronger European cooperation is therefore needed to tackle the cross-border infrastructure that sustains illegal operators.”
Black market should be treated as an ‘internet-harms issue’
The Campaign for Fairer Gambling sees an opportunity in the EU’s existing digital regulatory machinery. O’Keefe argues that illegal gambling should be treated as an internet-harms issue rather than as a narrow gambling-regulation problem.
“The EU sees itself as a trailblazer of internet regulation,” he says. “This particular aspect isn’t being controlled enough.”
Webb warns that if the legal industry cannot demonstrate that it can coexist with effective enforcement and meaningful consumer protection, the political backlash may eventually turn against regulated gambling itself.
“I think that if the global illicit market is not controlled and eradicated, eventually everybody will say we need to eradicate the totality – the legal market as well,” he says.
Petek frames the stakes as a question of the rule of law. “Governments should enforce the rules against those who break them with at least the same determination as they apply when regulating those who follow them,” he says.
For now, the report puts three questions on the European agenda: how much online gambling is actually taking place outside national regulatory systems; how effectively can government police the infrastructure that supports it; and would stronger enforcement give governments more room to tax the regulated sector without undermining channelisation.