The dynamics of Europe’s online gambling sector are increasingly influenced by activities that occur outside the framework of national gambling licenses. This issue is explored in a report released by the Campaign for Fairer Gambling, an organization advocating for reforms to mitigate harm and inequality in online gambling markets.
The report projects that by 2025, unregulated gambling operators will generate €91.6 billion in gross gambling revenue across the 27 EU member states, in stark contrast to the €36.5 billion attributed to regulated operators. This would mean that unregulated gambling would comprise 72% of the total €128 billion online gambling market in Europe. Such figures have drawn significant scrutiny from industry stakeholders, a reaction the Campaign anticipates.
Ismail Vali, president of Gaming Compliance International (GCI), which conducted the analysis, finds this scrutiny welcome. "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," Vali stated.
The report combines expert analysis with advanced technologies such as machine learning and AI, integrating detailed marketplace monitoring and extensive third-party data. Vali emphasized, "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."
GCI’s assertion that €91.6 billion, or 72% of EU online gambling revenue, goes to unlicensed operators stands in contrast to other estimates. A recent study by Regulus Partners and Helios for Euromat estimated the illegal online market in Europe at €12 billion (25%), while H2 Gambling Capital placed it at about €18 billion (27%).
Country-specific figures reinforce this narrative: PwC estimates France's illegal market at €2 billion, while Germany's regulatory body anticipates unlicensed revenue to reach €547 million in 2024, and the Dutch regulator estimates it at €617 million for the first half of 2025.
The European Gaming and Betting Association (EGBA), representing legal online gambling operators in the EU, recognizes that the report reflects a wide spectrum of estimates. An EGBA spokesperson noted, "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."
The discrepancies largely stem from differences in methodology. GCI converts web traffic and audience activity into revenue using a "value per visit" benchmark. While the UK Gambling Commission has recognized limitations in traffic-based approaches, GCI's overall market figure of €128 billion for EU online gambling in 2025 contrasts sharply with EGBA and H2’s estimate of €48 billion for online gambling in 2024, which includes the UK, not accounted for in GCI’s data.
"The work should be judged on the methodology and the evidence, not on the identity of the messenger," a GCI representative asserted. "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."
While the figures may be debated, there is consensus on the increasing trend of illegal operations. An EGBA spokesperson lamented, "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, added a note of caution regarding defined figures in relation to inherently secretive and ambiguous activities. He stated, "Putting a definitive figure on an activity that is by nature undisclosed and hard to trace is genuinely difficult… although the underlying trend it describes is real."
Derek Webb, founder of the Campaign for Fairer Gambling and a veteran in the industry, emphasized that the core issue of illegal gambling in Europe lies in insufficient coordinated enforcement across the diverse digital landscape.
"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," Webb commented.
The report contends that illegal gambling operates within a wider commercial ecosystem. This includes affiliates, advertising platforms, payment providers, app stores, search engines, social media, streaming services, and technology suppliers. Webb noted, "We need to attack the companies that are enabling this and making money from it."
Kieran O’Keefe, an adviser to the Campaign for Fairer Gambling, pointed out ongoing legal actions against companies like Meta, following complaints about illegal gambling ads circulating on their platforms despite being flagged.
Borut Petek, chief global affairs officer at Super Technologies and a board member of EGBA, described the report as a necessary wake-up call for Europe. He added, "Chasing individual websites is not enough… enforcement must increasingly focus on the infrastructure that enables it."
Discussions diverge significantly when it comes to potential government actions moving forward. The Campaign for Fairer Gambling advocates not only for stronger protection of licensed operators from unregulated competition but also suggests that improved enforcement could allow governments to increase revenue from the legal sector without negative repercussions.
"The beauty of fiscal policy is that if you’re not taxing the sector much, you don’t worry about losing much of it," Webb argued. He contended that if taxes on the sector rise, affiliates would be incentivized to preserve revenue.
However, skepticism surrounds this proposal within an industry facing heightened gambling taxes in various European markets. Operators warn that increasing the regulatory cost may weaken licensed businesses and inadvertently favor unlicensed options. Petek expressed this concern succinctly: "Higher taxation of licensed operators will only make the problem worse."
According to Petek, government efforts should focus on retaining as much gambling activity within the regulated sector, which ensures customer identification and consumer protections. He argued that any fiscal or regulatory measures should be assessed against their potential impacts on both channelization and the competitive standing of the legal market.
EGBA remarked on the pressure the legal market faces from illegal operations that neglect consumer protection, pay no taxes, and bear no compliance costs. The organization highlighted, "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."
EGBA proposes that enforcement should take precedence over 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 sentiment was echoed by the Betting and Gaming Council (BGC) in the UK, which emphasized the need for enforcement that looks beyond individual illegal operators. The BGC also urged caution regarding stricter fiscal measures, stating, "Illegal operators rely on affiliates, advertising, social media, payments and technology platforms to reach customers."
Representatives from legal operators agree about the necessity of robust regulation, but they caution against interpreting the findings as a justification for tighter fiscal measures against licensed operators. Brincat cautioned against hasty conclusions.
A Betsson Group representative underscored that any proposed cost increases should be evaluated against actual consumer behavior and whether such increases would effectively enhance player protection.
O’Keefe acknowledged the provocative nature of the Campaign’s stance. "I’m sure the online industry probably tears its hair out every time we open our mouth on this subject," he remarked.
Webb recognized that tougher fiscal policies run counter to industry preferences, yet he dismissed the operators’ logic. He cited Britain as an example where tax increases led to financial support for combating the illegal market. Webb proposed an EU-wide tax on remote gambling coupled with enhanced enforcement efforts.
Vali believes that the illegal gambling issue is more concentrated than the overarching revenue figures might imply. He pointed out, "We found that in the UK 94% of unregulated gambling activity was concentrated among children and self-excluded players," suggesting these demographics present a lucrative target for illegal operators.
He noted that illegal brands increasingly utilize sophisticated digital marketing strategies, including affiliates and social media, to connect with consumers without engaging the heavily funded advertising campaigns of conventional operators. Illegal streaming leverages exclusive sports rights to attract consumers, creating avenues for gambling brands to reach them.
The Campaign for Fairer Gambling regards illegal gambling as an ecosystem rather than merely a collection of websites. O’Keefe asserted that disrupting one access point often leads to the emergence of another.
Webb advocates for enforcing licensing requirements for affiliates, arguing, "How do we know that an affiliate isn’t financing terrorism or an organized crime entity?"
Both Vali and O’Keefe cited links between Russian-related gambling operations and other illegal online activities. "This is an enforcement failure in Europe," Vali concluded, calling for a comprehensive strategy to monitor the online gambling landscape.
The urgency of this campaign raises the question of whether Europe can achieve a coordinated response. While gambling regulation falls primarily within national jurisdiction, the digital infrastructure supporting gambling is transnational. Petek, positioning his company more actively within EU dialogues, emphasized that illegal online markets do not respect borders and require collaborative European efforts to tackle the systems supporting these illegal operators.
The Campaign for Fairer Gambling proposes that illegal gambling should be treated as a digital regulatory issue rather than confined to traditional gambling regulations. O’Keefe pointed out that the EU prides itself on being a pioneer in internet regulation, yet this aspect remains insufficiently managed.
Webb warns that if the regulated industry cannot validate its ability to coexist with substantial enforcement and consumer protection, regulated gambling itself may face repercussions. "If the global illicit market is not controlled, eventually everybody will say we need to eradicate the totality – the legal market as well," he cautioned.
Petek framed the discussion as centered on 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 stated.
In summary, the report raises key questions for Europe: how much online gambling is occurring outside regulatory systems? How effectively can governments monitor the infrastucture that supports illegal operations? Would enhanced enforcement provide governments more latitude to regulate and tax the legal sector without hindering the competitive balance?
