Behind the Numbers: A Comprehensive Guide to Europe’s Online Gambling Black Market Debate

Behind the Numbers: A Comprehensive Guide to Europe’s Online Gambling Black Market Debate

Introduction: A New Report Shakes Up the Discussion

Europe’s online gambling landscape is increasingly defined by a shadow battle — one fought outside the boundaries of national licensing regimes. The scale of that battle has been thrust into the spotlight by a provocative new analysis from the Campaign for Fairer Gambling, an organization dedicated to reforming online gambling markets to reduce harm and inequity. The report, produced by Gaming Compliance International (GCI), claims that unlicensed operators accounted for a staggering €91.6 billion of gross gambling revenue (GGR) across the EU’s 27 member states in 2025, compared with just €36.5 billion for licensed operators. That would place the unregulated sector at 72% of a total €128 billion online gambling marketplace.

These figures are far higher than any previously published estimates, and they have ignited a fierce debate about how Europe should measure, police, and ultimately tax its digital gambling ecosystem. This guide unpacks the report’s methodology, contrasts it with other studies, explores the enforcement challenges it highlights, and examines the widening rift between those who advocate for heavier taxation of licensed operators and those who argue that enforcement — not fiscal policy — is the priority.

The Report’s Core Findings: A Staggering 72% Unregulated?

How the Numbers Break Down

The GCI analysis estimates the total EU online gambling market at €128 billion for 2025. Within that:

• Licensed operators: €36.5 billion (28%)
• Unlicensed operators: €91.6 billion (72%)

Ismail Vali, president of GCI, stresses that the report deliberately publishes the lower end of its modelled range. “We are putting a quantified value on the total marketplace, using the same methodology across regulated and unregulated activity,” he says. The team combined specialist human analysis, machine learning, AI, marketplace monitoring, benchmarking, and extensive third-party data. Vali’s blunt message to the industry: “You are all being stolen from.”

Contrast with Other Estimates

The GCI figures sit at the top of a very wide range of estimates. Other recent studies paint a far less dramatic picture:

The European Gaming and Betting Association (EGBA), which represents licensed online gambling operators in the EU, notes that “illegal gambling is hard to measure by its nature, which is why there have been so many studies about it, with widely varying results.” The EGBA’s own preferred baseline — using H2 data — puts the illegal market at around a quarter of Europe’s online revenue.

Methodology: The Art and Science of Measuring the Invisible

Traffic-Based Revenue Estimation

GCI’s approach relies on converting web traffic and audience activity into revenue figures using a “value per visit” benchmark. In essence, they estimate how much money the average visitor to an unlicensed gambling site generates per session, then multiply that across the total number of visits identified through monitoring tools. This method is common in digital market sizing, but it comes with inherent challenges.

Criticisms and Limitations

The UK Gambling Commission, in a review of traffic-based approaches, highlighted key limitations:

• No insight into app usage: Many illegal sites operate primarily through mobile apps, which are far harder to track than web traffic.
• Difficulty distinguishing bots from real users: Automated traffic can inflate visit counts.
• Variable user behavior: The “value per visit” can differ dramatically between markets, game types, and player segments.

Beyond these methodological concerns, the sheer size of GCI’s total market estimate (€128 billion) stands out. For comparison, EGBA / H2 data put online gambling at 39% of Europe’s total €123.4 billion gambling market in 2024 — roughly €48 billion for online only. That figure includes the UK, which GCI’s EU‑only data does not. The gap between €128 billion and €48 billion is enormous, and it drives much of the difference in the unlicensed share.

The Call for Competing Analyses

A GCI spokesperson responds: “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.” So far, no rival study has attempted to produce a similarly comprehensive total‑market estimate. Until that happens, the debate will remain partly a battle of assumptions.

National Snapshots: How Do Individual Countries Compare?

France, Germany, Netherlands

National regulators and consultancies have provided their own figures, which generally fall far below GCI’s pan‑EU numbers but still confirm a significant and growing problem:

• France: PwC estimated the illegal online market at €2 billion in 2024.
• Germany: The federal gambling regulator (GGL) put unlicensed revenue at €547 million for 2024.
• Netherlands: The Dutch regulator (Kansspelautoriteit) reported €617 million in the first half of 2025 alone.

These national data points are not directly comparable because they use different methodologies, scopes, and time periods. But they all point in the same direction: unlicensed gambling is a material and expanding challenge.

The UK’s Separate Picture

GCI’s analysis excludes the UK, which operates under its own regulatory regime. The UK Gambling Commission has its own estimates and enforcement mechanisms, and the Betting and Gaming Council (BGC) — the UK trade body — responded to the report by emphasizing the need for enforcement against the ecosystem supporting illegal operators.

Enforcement: The Real Battle Beyond Individual Operators

The Role of Digital Infrastructure

The report argues that illegal gambling does not exist in a vacuum — it depends on a broad commercial infrastructure. Derek Webb, founder of the Campaign for Fairer Gambling and a gambling industry veteran, explains: “We need to attack the companies that are enabling this and making money from it.” The infrastructure includes:

• Affiliates who direct players to unlicensed sites
• Advertising platforms (e.g., Google, social media)
• Payment providers that process deposits and withdrawals
• App stores that host gambling apps
• Search engines that index illegal operators
• Streaming services and social media that run ads
• Technology suppliers and game developers who provide the software

Kieran O’Keefe, an adviser to the Campaign, notes that “the online advertisers, cloud companies, payment processors and other parts of this ecosystem are all laid out in the report.”

Case Study: Netherlands v. Meta

A concrete example of infrastructure‑level enforcement comes from the Netherlands. The Dutch gambling trade body VNLOK has initiated legal proceedings against Meta (owner of Facebook and Instagram) for allowing illegal gambling advertisements to be shared on its platforms, even after being flagged by authorities. This case illustrates the growing frustration among licensed operators and regulators who feel that tech giants are profiting from illegal activity without accountability.

Industry Calls for Coordinated Action

Borut Petek, chief global affairs officer at Super Technologies and an EGBA board member, calls the report “a wake‑up call for Europe.” He argues that “chasing individual websites is not enough. The illegal market operates across borders, so enforcement must increasingly focus on the infrastructure that enables it: payments, affiliates, digital distribution, advertising platforms, technology and game suppliers, as well as on stronger cooperation between national authorities.”

The EGBA echoes this sentiment: “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.”

Taxation vs. Enforcement: A Deepening Divide

The Campaign for Fairer Gambling’s Fiscal Argument

Where the Campaign and the licensed industry part company is on what should happen next. Derek Webb argues that if enforcement successfully reduces the unregulated market, governments would have greater scope to raise revenue from the legal sector without driving players away. “The beauty of fiscal policy is that if you’re not taxing the sector much, you don’t worry about losing much of it,” he 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.’”

In other words, once the unlicensed market is squeezed, higher taxes on licensed operators become more viable — and may even create a virtuous cycle where affiliates and intermediaries have a stronger incentive to push players toward the regulated channel.

Licensed Operators’ Fear of a Competitive Gap

That argument meets deep scepticism from the licensed industry, which already faces rising gambling taxes in several European markets. Operators have long warned that increasing the cost of doing business legally makes unlicensed alternatives more attractive. Borut Petek, chief global affairs officer at Super Technologies and an EGBA board member, puts it bluntly: “Let’s not make the problem worse.”

“Higher taxation of licensed operators will only make the problem worse. 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, must be assessed against their impact on channelisation (the share of gambling that flows through licensed channels) and the competitiveness of the legal market.

Where EGBA and BGC Stand

The EGBA’s spokesperson is clear: enforcement 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 goal must be stable, proportionate rules that keep players in the safer, regulated market.”

The BGC makes a similar case, appealing for caution on 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.”

Conclusion: The Debate Is Just Beginning

The GCI report has accomplished what its authors intended: it has forced a reckoning with the scale of Europe’s unlicensed online gambling market. Whether one accepts the €91.6 billion figure or prefers the more conservative estimates of the EGBA or H2, there is broad agreement on the direction of travel.

• Illegal activity is substantial and growing. Even EGBA acknowledges it as “the biggest challenge facing the sector today.”
• Enforcement alone is unlikely to be sufficient unless it targets the entire digital ecosystem — payment providers, ad platforms, affiliates, and technology enablers.
• The taxation debate is deeply polarised. The Campaign for Fairer Gambling sees higher taxes as a potential benefit of successful enforcement; the licensed industry sees them as a threat to channelisation.

What is missing — and what the GCI report explicitly challenges others to provide — is a competing total‑marketplace analysis that would allow policymakers to compare methodologies and draw evidence‑based conclusions. Until that happens, the 72% figure will remain a lightning rod for controversy, but it will also keep the issue of Europe’s gambling black market firmly in the public and regulatory spotlight.

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