The online gambling landscape in Europe is increasingly influenced by activities that fall outside the jurisdiction of national gambling licenses. A new report from the Campaign for Fairer Gambling highlights the scale of this issue, estimating that by 2025, unregulated operators will generate €91.6 billion in gross gambling revenue across the EU’s 27 member states, compared to €36.5 billion for regulated operators. This suggests that a staggering 72% of the total €128 billion online gambling market will be unregulated, a figure that has drawn the attention of various industry stakeholders.
Ismail Vali, president of Gaming Compliance International (GCI), which conducted the analysis, welcomes this scrutiny, stating, "For years, the unregulated sector has often been discussed using broad estimates and incomplete datasets. We are providing a clear and quantified value for the entire marketplace."
The report's creators employed a mix of human analysis, machine learning, and artificial intelligence alongside extensive third-party data to arrive at their conclusions. Vali further added, "We intentionally publish conservative estimates to emphasize the seriousness of the issue. You are all being stolen from."
The report contends that the vast size of the unregulated market signifies not only the evasion of national regulators by offshore operators but also a fundamental failure in policing the online gambling environment. GCI’s claim significantly contrasts with other studies; for instance, a Regulus Partners/Helios study estimates Europe's illegal online gambling at €12 billion, or 25% of the market, while H2 Gambling Capital’s figure is about €18 billion (27%). Other national estimates further reflect this divergence, including PwC’s estimate of a €2 billion illegal market in France and €547 million in Germany.
The European Gaming and Betting Association (EGBA), which represents licensed online gambling operators, acknowledges the variability in such estimates, stating, "Illegal gambling is inherently difficult to measure, which is why multiple studies yield different results. Most estimate the illegal market at around a quarter of Europe’s online gambling revenue."
The discrepancy in figures primarily arises from differing methodologies. GCI associates web traffic and audience activity with revenue using a "value per visit" benchmark. However, the UK Gambling Commission has noted limitations to traffic-based approaches, citing a lack of insight into the use of apps by illegal sites.
GCI’s calculation of a total EU online gambling figure of €128 billion in 2025 contrasts sharply with the EGBA/H2 assessment, which estimates online gambling at €48 billion for 2024, including the UK—an area not covered by GCI's data. “The methodology and evidence are critical for evaluating our findings, not the sources,” a GCI spokesperson remarked, challenging skeptics to present alternative analyses.
While the figures may vary, there is consensus on the troubling trend of illegal gambling growth. An EGBA spokesperson stated, "Illegal activity is substantial and continues to increase, presenting the biggest challenge for our sector."
This concern is echoed by Carl Brincat, senior director of legal and regulatory affairs at LeoVegas, who cautioned against placing too much emphasis on any singular number, despite acknowledging the reality of the trend.
Derek Webb, founder of the Campaign for Fairer Gambling, highlighted the absence of coordinated enforcement as a key problem. He stated, "Governments need to adapt swiftly as social media, AI, and cryptocurrencies evolve the gambling landscape."
The report suggests that illegal gambling benefits from a broad commercial infrastructure that includes affiliates, advertising platforms, payment processors, app stores, search engines, and more. Kieran O’Keefe, an adviser for the Campaign, remarked, "We must target those companies profiting from this illegal activity."
In the Netherlands, for instance, the gambling trade body VNLOK has initiated legal actions against Meta for allowing the promotion of illegal gambling advertisements on its social media platforms despite warnings.
Borut Petek, chief global affairs officer at Super Technologies and a member of the EGBA board, described the findings as a wake-up call. He asserted that focusing solely on individual websites is inadequate, recommending that regulatory efforts also target the infrastructure behind illegal operations.
The Campaign for Fairer Gambling suggests that governments should not only enhance protection for legal operators but could also increase revenue from the sector if enforcement curbs the unregulated market. Webb stated, "If governments adequately tax the sector, it could prevent affiliates from losing revenue."
However, operators express skepticism, warning higher taxes might undermine the licensed market in favor of illegal competition. Petek bluntly stated, "Increasing taxes on licensed operators will only exacerbate the problem."
EGBA highlights that illegal operators, who do not pay taxes or comply with regulations, weaken the legal market’s competitiveness. The association advocates for stricter enforcement rather than increased taxation, calling for cooperative efforts to address the platforms and intermediaries that facilitate illegal gambling.
A representative from the Betting and Gaming Council echoed this sentiment, emphasizing that enforcement measures must concentrate on the broader ecosystem supporting illegal operators while keeping the regulated market competitive.
The report indicates a growing concern about who is participating in the black market, with Vali noting that unregulated gambling primarily attracts children and self-excluded players. He added, "94% of unregulated gambling in the UK is among these vulnerable groups."
This landscape creates a fertile ground for illegal operators, who employ sophisticated strategies via digital channels to reach consumers without competing with well-funded, mainstream advertising from licensed providers. The issue is compounded by exclusive sports rights and streaming platforms that inadvertently enable illegal brand acquisition.
The Campaign urges that illegal gambling be viewed as an interconnected ecosystem rather than isolated websites, suggesting that cutting off one avenue does not eliminate the problem. Webb insists that affiliates should be licensed to prevent associations with organized crime.
Evidence of Russian-linked gambling operations has prompted calls for more comprehensive enforcement measures across Europe. Vali stated, "This is an enforcement failure in Europe."
As discussions advance, it remains to be seen whether Europe can muster collective action to combat this issue, given that gambling regulation primarily falls under national jurisdictions. Petek acknowledged this while underscoring the necessity for enhanced European collaboration to address cross-border issues.
The Campaign for Fairer Gambling advocates that illegal gambling should be treated as an internet-related harm, suggesting the EU leverage its prominence in digital regulation. Webb warns that if the regulated industry cannot coexist with effective enforcement, it risks suffering a political backlash.
Petek emphasized the rule of law, advocating for governments to enforce rules against illegal operators with equal vigor as those who comply with regulations. As the report raises significant questions about the magnitude of online gambling beyond national controls, the effectiveness of governmental policing in that sphere, and the implications for taxation, the stakes for the European gambling industry continue to escalate.
