Europe's online gambling landscape is currently influenced by a significant challenge that occurs largely beyond national gambling regulations. A recent report from the Campaign for Fairer Gambling highlights the extent of this issue, as the organization advocates for reforms aimed at minimizing harm and inequities in online gambling markets.
The analysis projects that by 2025, unregulated operators will generate €91.6 billion in gross gambling revenue across the European Union's 27 member states, in stark contrast to €36.5 billion from regulated operators. This places the unregulated segment at a staggering 72% of the estimated total €128 billion online gambling market in the EU, a figure that has drawn considerable attention from the industry.
Ismail Vali, president of Gaming Compliance International (GCI), which produced the report, appreciates the increased scrutiny this analysis will invite. "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," he stated.
The report utilized a mix of human analysis, machine learning, and AI to evaluate marketplace monitoring and benchmark data, ultimately opting to present the lower end of their models to elicit a stronger response. "What we are looking to do is to get to this point: you are all being stolen from," Vali added.
This significant market size is cited by the report as not merely evidence of offshore operators bypassing national regulators, but indicative of a systemic failure to enforce regulations in the digital gambling space.
According to GCI's assertion that unlicensed operators will account for €91.6 billion, this number surpasses other estimates. A recent Regulus Partners/Helios study for Euromat estimates Europe's illegal online gambling market at €12 billion, about 25% of the total, while H2 Gambling Capital approximates it to be around €18 billion, or 27%.
Similar national studies back this trend, with PwC estimating France's illegal market at €2 billion, Germany's regulator placing unlicensed revenue at €547 million for 2024, and the Dutch regulator noting €617 million in the first half of 2025. The European Gaming and Betting Association (EGBA), which advocates for online operators in the EU, remarked that GCI's report sits at one extreme of computed ranges.
"Illegal gambling is hard to measure by its nature, which is why there have been so many studies about it, with widely varying results," stated an EGBA spokesperson, highlighting that other studies suggest the illegal market constitutes around a quarter of Europe’s online gambling revenue.
Differences in methodology significantly contribute to these divergent figures. GCI employs a "value per visit" benchmark to translate web traffic and audience activity into revenues. In its own assessments, the UK Gambling Commission discovered limitations in traffic-based approaches, including a lack of insight into illegal app usage.
GCI's total market estimate also diverges notably from EGBA/H2 data, which forecast that online gambling will represent 39% of Europe's total €123.4 billion gambling market in 2024, approximately €48 billion, including the UK—excluded from GCI's calculations.
The report's numbers, while contested, reflect a broader consensus about the trend. "Illegal activity is substantial and growing, and for us it is the biggest challenge facing the sector today,” said an EGBA spokesperson.
Concerns about illegal gambling in Europe have been underscored by Derek Webb, founder of the Campaign for Fairer Gambling, who contends the issue stems from insufficient coordination in enforcement across the digital gambling ecosystem.
"Governments need to be capable of responding promptly as changes arise due to innovations in social media, AI, and cryptocurrencies," he remarked.
The report claims that illegal gambling relies on an expansive commercial network involving affiliates, advertising platforms, payment processors, app stores, search engines, social media, streaming services, and technology suppliers. Kieran O'Keefe, an adviser to the Campaign, argued for targeting these companies profiting from illegal activities.
For instance, in the Netherlands, the gambling association VNLOK has initiated legal action against Meta for permitting ads for illegal gambling sites on its platforms, even after reporting them.
Borut Petek, chief global affairs officer at Super Technologies and an EGBA board member, characterizes the report as "a wake-up call for Europe."
"Chasing individual websites is not enough," he emphasized. "The illegal market operates across borders, so enforcement must increasingly focus on the infrastructure that enables it, including payments, affiliates, and advertising platforms. Stronger cooperation among national authorities is also crucial."
While the Campaign for Fairer Gambling advocates increased government action to protect licensed operators from unregulated competition, it also argues that effective enforcement could enable governments to raise revenue from the legal sector.
Derek Webb commented, "If you’re not taxing the sector much, you don’t worry about losing much of it. But if you tax it adequately, affiliates might be more incentivized to stop letting this revenue slip away."
This argument is met with skepticism in an industry already facing higher taxes in several European countries. Operators have warned that increasing the cost of regulated gambling risks pushing customers toward illegal alternatives. Petek bluntly stated, "Higher taxation of licensed operators will only make the problem worse, as unregulated competitors that bear no tax burden become more appealing."
The EGBA maintains that robust enforcement should take precedence over taxation.
"Effective enforcement requires collaboration and action on intermediaries that facilitate illegal operations," said an EGBA spokesperson. "We must establish stable, proportionate rules to retain players in the safer, regulated market."
This sentiment is echoed by the Betting and Gaming Council, which asserts that while the report calls for greater enforcement against illegal operators, caution is necessary regarding attempts to tighten fiscal measures on licensed businesses.
"Illegal operators depend heavily on a network of affiliates and other platforms to reach customers, so strategy must target the entire ecosystem supporting them. At the same time, proportionate regulations must keep the legal market competitive," the BGC spokesperson noted.
Operators reinforce this viewpoint, suggesting that while supporting strong regulations, interpreting these findings as a call for tighter financial regulations on licensed operators would be misguided.
A spokesperson from Betsson Group also remarked that proposals to increase operators' costs should hinge on clear evidence of player behavior improvements and their effects on legal market participation.
O'Keefe acknowledged that the Campaign’s stance can provoke strong reactions within the online industry, stating, "I’m sure the online industry probably tears its hair out every time we open our mouth on this subject."
Webb admitted that the idea of increased fiscal policies contradicts industry desires, yet he firmly opposes operator arguments.
He highlighted Britain as an illustrative case, noting that when the tax rate surged from 21% to 40%, it subsequently provided £26 million to the Gambling Commission and related departments to combat illegal gambling. Webb advocates for a unified EU tax on remote gambling coupled with enhanced enforcement measures.
Ismail Vali argues that the underlying issues of illegal gambling may be concentrated more narrowly than suggested by broad statistics. He asserts that illegal gambling increasingly attracts demographics not served by conventional licensed operators, particularly vulnerable groups like children and self-excluded individuals.
"We found that in the UK, 94% of unregulated gambling activity occurred among children and self-excluded players," Vali stated.
He emphasizes that these specific groups prove particularly enticing for illegal operators due to their exclusion from regulated markets, allowing these brands to leverage sophisticated digital marketing tactics without competing directly with mainstream operators' robust advertising budgets.
The use of illegal streaming further complicates the landscape; exclusive sports broadcasting rights prompt consumers to seek alternatives, creating pathways for gambling brands to capture these segments.
The Campaign views illegal gambling as an interconnected ecosystem, rather than a simple aggregation of websites. Disrupting one avenue of access often leads to the emergence of new channels, necessitating a comprehensive approach to enforcement that extends beyond traditional gambling regulators.
Webb argues that even affiliates should require licensing to prevent potential ties to illicit activities.
Gambling operations linked to Russian networks and various illicit online activities underscore this sentiment, with Vali proclaiming this situation as an "enforcement failure in Europe."
The proposed solution necessitates a holistic approach: monitoring the entire gambling landscape, enforcing regulations against infrastructure supporting illegal operators, and evaluating whether measures successfully shift consumers back toward licensed services.
The political challenge lies in achieving a collective European response, especially in a sector where gambling regulation predominantly falls under national jurisdiction. However, the interconnected nature of the pertinent infrastructure highlights the necessity for cross-border collaboration.
Petek suggests that although member states currently manage most gambling regulations, the transnational characteristics of the illegal online market demand stronger European cooperation to address the underlying mechanisms at play.
The Campaign for Fairer Gambling proposes viewing illegal gambling through the lens of broader internet regulation, making it a matter of digital harms rather than a narrow gambling-specific issue.
O'Keefe believes that the EU should accelerate its regulatory efforts to manage this dimension more effectively.
Webb cautions that failing to demonstrate success in harmonizing the legal sector with effective enforcement and consumer protections might provoke a backlash against legally recognized gambling.
"If the global illicit market is not addressed, there’s a real risk that the conversation will shift towards eliminating the entire legal market as well," he warned.
Petek frames the issue as one of upholding the rule of law, stating that governments must enforce rules against violators with the same rigor applied to regulated operators.
In the meantime, the report raises three critical points for Europe to consider: the extent of online gambling occurring beyond national regulations, the effectiveness of government enforcement on supporting infrastructure, and whether increased enforcement could allow for higher taxation of regulated operators without undermining the established market.
