The online gambling sector in Europe is increasingly influenced by a contest occurring beyond the reach of national gambling licenses. A new report from the Campaign for Fairer Gambling, an organization advocating for reforms to address harm and inequities in online gambling, sheds light on the size of the unregulated market.
The analysis estimates that unregulated operators will generate €91.6 billion in gross gambling revenue by 2025 across the EU’s 27 member states, starkly outpacing the €36.5 billion expected from regulated operators. This means that unregulated operators would represent a staggering 72% of the total €128 billion online gambling market. These findings are drawing attention from industry stakeholders, which the Campaign anticipates.
Ismail Vali, the president of Gaming Compliance International (GCI), which conducted the analysis, is open to scrutiny of the figures. He stated, "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 report combines human analysis, machine learning, AI, market monitoring, and extensive third-party data. Vali emphasized that GCI publishes the lower end of their model range to drive home the point: "You are all being stolen from."
The report argues that the expansive size of the market indicates a failure to adequately regulate and police the digital gambling landscape, rather than merely reflecting offshore operators avoiding national regulations.
GCI’s assertion that €91.6 billion, or 72% of EU online gambling revenue, is managed by unlicensed operators stands in stark contrast to other estimates. A Regulus Partners/Helios study for Euromat recently indicated that Europe’s illegal online market is around €12 billion, or 25%, while H2 Gambling Capital numbers suggest it’s approximately €18 billion (27%). National data corroborate GCI's findings: PwC assessed France's illegal market at €2 billion, Germany’s regulator estimated unlicensed revenue at €547 million for 2024, and the Dutch regulator projected it at €617 million for the first half of 2025.
The European Gaming and Betting Association (EGBA), which represents online gambling operators within the EU, observed that the report’s estimates are at the high end of a broad range of results. A spokesperson remarked, "Illegal gambling is hard to measure by its nature, which is why there have been so many studies about it, with widely varying results. Other studies put the illegal market at around a quarter of Europe’s online gambling revenue."
A substantial disparity in estimation stems from methodology. GCI assesses web traffic to derive revenue using a "value per visit" benchmark. The UK Gambling Commission, which evaluates traffic-based approaches, previously noted significant limitations, including the inability to account for app usage by illegal sites.
GCI’s total market figure of €128 billion for EU online gambling in 2025 vastly differs from the EGBA/H2 assessment of €48 billion, which includes the UK—a region excluded from GCI’s data.
"The work should be judged on the methodology and the evidence, not on the identity of the messenger," a GCI representative stated, challenging skeptics to create their own comprehensive marketplace analysis.
While the numbers may be debated, the trend of increasing illegal activity is widely acknowledged. The EGBA representative noted, "Illegal activity is substantial and growing, and for us it is the biggest challenge facing the sector today."
Carl Brincat, senior director of legal and regulatory affairs at LeoVegas, conveyed a similar sentiment, acknowledging the complexity of accurately quantifying such clandestine activities but affirming the underlying trends are tangible.
Derek Webb, a veteran in the gambling industry and founder of the Campaign for Fairer Gambling, attributes the growing illegal gambling issue to insufficient coordinated enforcement across the digital ecosystem. He asserts that governments need to adapt promptly to dynamic changes driven by innovations in technology and media.
The report suggests that illegal gambling thrives due to a far-reaching commercial backdrop, involving affiliates, advertising platforms, payment providers, and more. Webb argues for attacking these enabling companies, stating, "We need to focus on the online advertisers, cloud companies, payment processors, and other sectors profiting from this ecosystem."
In the Netherlands, legal proceedings have been launched by the gambling trade organization VNLOK against Meta for permitting advertisements promoting illegal gambling sites on its social media platforms despite alerts about these posts.
Borut Petek, chief global affairs officer at Super Technologies and EGBA board member, described the report as "a wake-up call for Europe," arguing that simply targeting individual websites is inadequate as the illegal market spans borders. Enforcement must increasingly concentrate on the supporting infrastructure such as payments, affiliates, and digital distribution.
Looking ahead, the Campaign for Fairer Gambling argues that beyond merely advocating for stronger protections for licensed operators, governments could improve fiscal policies as enforcement tightens the unregulated domain. Derek Webb stated, "The beauty of fiscal policy is that if you’re not taxing the sector much, you don’t worry about losing much of it. If you actually tax the sector adequately, affiliates might become more interested in keeping this revenue."
However, this stance faces pushback from an industry already grappling with rising taxes in various European markets. Many operators warn that increasing the costs associated with licensed gambling could inadvertently drive consumers to illegal alternatives.
Petek bluntly stated, "Higher taxation of licensed operators will only make the problem worse. If governments increase the operational costs for legal gambling while illegal operators bear none of these expenses, they make the illegal offer more appealing."
The consensus among many stakeholders leans towards prioritizing enforcement over taxation. Both the EGBA and the Betting and Gaming Council emphasize the need for effective measures against illegal online gambling, urging action against the intermediaries that facilitate these operations.
"Tackling illegal online gambling requires effective enforcement, greater cooperation, and action against the platforms that allow illegal operators to reach European players," stated an EGBA representative.
Operators echo this sentiment, stressing that any calls for increased fiscal measures must consider the risk to the competitive landscape. Brincat noted, “We support clear and strong regulation, but interpreting these findings as a justification for tightening fiscal measures on licensed operators would be misguided.”
As debate continues, the report raises critical questions about the scale of online gambling occurring outside regulatory frameworks and the efficacy of government efforts to police the systems that sustain unlicensed operators. The political landscape complicates matters, with gambling regulation largely remaining a national jurisdiction in a sector that increasingly requires a collaborative European response.
Vali cautioned that illegal gambling is not just a numerical issue but also one involving vulnerable populations. He claimed, "In the UK, 94% of unregulated gambling activity was concentrated among children and self-excluded players."
The Campaign sees this illegal gambling ecosystem as a web, underscoring the need for comprehensive enforcement efforts against affiliates and digital channels that allow operators to target consumers outside the regulated market.
As the European landscape continues to grapple with these challenges, there emerges a plea for coordinated efforts to address the far-reaching impact of illegal gambling across borders. O’Keefe suggested reframing illegal gambling as an internet-harms issue, arguing for its control within the broader context of digital regulation. Webb warned that if the market fails to establish a balance between enforcement and protecting consumers, it could jeopardize the legitimacy of regulated gambling altogether.
