Key Moments:
- Industry analysis finds EU governments missed out on €22.9bn in tax revenue due to illegal online gambling in 2025
- Estimates of the black market’s size remain highly disputed among industry groups
- Multiple regulatory strategies have been proposed to counter illegal operators across Europe
Major Findings from Latest Study
A recent impact study commissioned by the European Casino Association (ECA) and conducted by Gambling Compliance International (GCI) reports that illegal online gambling targeting EU consumers reached €91.6bn in 2025, an increase of approximately 14 percent from the prior year. Based on an assumed EU-wide tax rate of 25 percent of gross gaming revenue (GGR), the ECA estimates that EU member states forfeited €22.9bn in tax revenue due to unlicensed online gambling activity. According to the ECA, over 6,200 illegal operators targeted EU consumers during this period.
ECA chair Erwin van Lambaart stated, “The 2025 data from the GCI report leaves no room for doubt: illegal online gambling is a fast-growing, cross-border problem that puts players, especially young adults, at high risk, deprives societies of much-needed tax revenues, and undermines trust in the regulated market.”
It is important to note that these figures are industry estimates. The €22.9bn cited for lost tax revenue is not a definitive sum of unpaid tax bills, but an assessment grounded in market size and assumed tax rates.
| Estimate Provider | Year | Estimated Black Market Size | Tax Revenue Lost (€) | Basis/Methodology |
|---|---|---|---|---|
| ECA/GCI | 2025 | €91.6bn | €22.9bn | Assumed 25% EU-wide tax rate on GGR |
| EGBA | 2025 | €18bn | – | 27% of online gambling GGR |
| GGL, Blockchain Research Lab (Germany) | 2025 | 22.97% of national market | – | Channelisation rate analysis |
| Kansspelautoriteit (Netherlands) | Second half 2025 | 53% of GGR by licensed firms | – | Market observation |
Ongoing Disagreement Over Market Metrics
The actual size of Europe’s black market continues to be hotly contested. The European Gaming and Betting Association (EGBA) reported in March that illegal operators made up 27 percent of Europe’s online gambling GGR in 2025, which would equate to roughly €18bn – far less than the ECA/GCI estimate.
Country-specific studies offer additional perspectives. In Germany, a study commissioned by regulator GGL and conducted by Blockchain Research Lab found the illegal share of online gambling at 22.97 percent. GGL board member Ronald Benter commented, “The scientifically calculated channelisation rate confirms our previous assumptions about the extent of the black market.”
The Netherlands illustrates the complex relationship between licensing and market share. In the second half of 2025, the Kansspelautoriteit estimated 91 percent of players used only licensed operators, yet these operators captured just 53 percent of GGR. This discrepancy suggests significant player losses on illegal platforms, where consumer protections can be lacking.
Regulatory Actions and Industry Proposals
Efforts to thwart illegal online gambling span a wide spectrum of measures. Some advocate for expanded regulation, such as Finland’s move to abandon its monopoly model in favor of a licensing system, and calls to allow regulated online casino gambling in jurisdictions like France. Approaches also include blocking illegal and mirror websites, disrupting payment services to unlicensed operators, removing illegal gambling content from search engines and app platforms, increasing restrictions on advertising, strengthening alliances with social media, and enhancing resources for regulatory bodies to pursue offshore entities.
Trade associations have stressed the need to consider channelisation rates when legislating new restrictions or tax regimes, as overly strict markets may push players toward illegal alternatives. For example, Denmark managed to secure court orders blocking 334 illegal websites in 2025, streamlined procedures for telecoms to block mirror sites, and worked with Google to take down illicit gambling apps.
France’s industry association AFJEL has urged regulators to bring online casino games into the legal market to provide better protection for users already frequenting illegal sites. However, France’s regulator ANJ and the government remain cautious, citing addiction risks while prioritizing actions against the infrastructure supporting illicit gambling, such as payment providers, hosting services, and social networks.
Calls for Coordinated Efforts
The EGBA continues to push for collective EU action, especially against fraudulent gambling sites and apps that mimic licensed brands. Ekaterina Hartmann, EGBA’s director of legal and regulatory affairs, said, “Fragmented national approaches to these types of fraud are not enough, we need coordinated EU-level action to ensure consumers and legitimate operators aren’t left fighting an uphill battle against fraud.”
Industry stakeholders emphasize that enforcement alone cannot solve the problem if licensed offerings become less visible or less attractive to consumers. Belgium’s BAGO, for instance, calls for intensified measures including stronger actions against illicit operators, financial blocking, and enhanced regulatory capacity. BAGO president Tom De Clercq stated, “The fight against illegal gambling must become an absolute priority. The Gambling Commission itself shows that traditional methods of enforcement are reaching their limits. We therefore need rapid blocking of illegal websites and payment flows, as well as closer cooperation between supervisory authorities, the police and the judiciary.”
These diverse market estimates underscore the need for cohesive policy and enforcement responses. Unlicensed operators exploit regulatory gaps by advertising and accepting payments across borders, often reaching vulnerable populations, while licensed providers remain subject to tight local regulations.
- Author
Daniel Williams
