EU black market estimated at €91.6bn, far above rivals

Kyle Kevin

iGaming Writer

Fact Checked

€91.6 billion. That is the figure the Campaign for Fairer Gambling now puts on Europe’s illegal online gambling market for 2025, and it is more than double the €48 billion the licensed industry says the online market actually generates. The gap is not a rounding error and it has set off an argument about how the number was built, who should pay to shrink it and whether governments should raise taxes instead.

€91.6 billion in unregulated activity against €36.5 billion in regulated activity. That is how the Campaign for Fairer Gambling, backed by a study from Gaming Compliance International (GCI), breaks down the €128 billion EU online gambling market for 2025. The split is the story: the licensed half of the market is under half its size, and the difference is not made up of small unregulated operators trading in the margins. It is a structural gap.

The €91.6 Billion Black Market Claim

GCI built the number by monitoring the marketplace and converting web traffic and audience activity into revenue through a value-per-visit benchmark. The team used specialist human analysis alongside machine learning, benchmarking and third-party data, and it chose to publish the lower end of its modelled range rather than the higher one. Ismail Vali, president of Gaming Compliance International, said the decision was deliberate: the point of the exercise is to show how much is being missed, not to produce the most flattering estimate.

The report also expands the market boundary beyond what most studies do. EGBA’s figures for online gambling cover the UK and the 27 member states, putting the online market at roughly €48 billion in 2024. GCI’s €128 billion does not include the UK and instead measures the full EU digital marketplace. That is the single biggest reason the two numbers cannot be compared directly, and it is the first thing anyone arguing about the 72% figure needs to settle.

AGBrief has covered how national regulators arrived at their own smaller illegal-market figures, and the spread is wide: €12 billion across Europe, €2 billion in France, €547 million in Germany for 2024 and €617 million in the Netherlands for the first half of 2025. The Campaign expects the challenge. Its rebuttal is to ask the critics to test the methodology, publish a competing total-marketplace analysis and show where the difference originates.

Why the Numbers Disagree

Much of the gap is methodological rather than political. Traffic-based models cannot see app use, so they miss a whole channel of illegal activity. Revenue-per-visit benchmarks assume a conversion rate that no regulator can observe on the other side of the transaction. And illegal operators change their traffic patterns precisely when they are being watched, which means the denominator moves while the numerator stays fixed. The UK Gambling Commission has flagged these limits in its own review of traffic-based approaches, which weakens the most common estimation tool.

As a result, the €91.6 billion figure should be read as an order of magnitude, not a measurement. Carl Brincat of LeoVegas said the trend it describes is real even though a single number should be treated with caution. EGBA’s position is broader: illegal gambling is difficult to measure by its very nature, which is why so many studies exist and why their answers differ so widely. The industry’s complaint is that the Campaign is presenting a contested number as settled fact in a debate about fiscal policy.

Who Is Using the Black Market

For Vali, the headline percentage masks a much narrower problem. The report finds that in the UK, 94% of unregulated gambling activity is concentrated among children and self-excluded players. That is the uncomfortable part: the audiences the regulated market is built to exclude are the audiences illegal operators are winning. They cannot be served by a licensed operator without breaking their own rules, so the exclusion that protects one group becomes the acquisition channel for another.

The acquisition mechanics are more sophisticated than the old advertising wars. Affiliates, streaming services, social media and exclusive sports rights now feed consumers who are already looking for alternatives. Vali describes illegal operators as finding audiences that do not compete directly with the enormous advertising budgets of mainstream operators. The Campaign’s framing follows: this is an ecosystem, not a pile of websites. Take down one route and another appears, which is why a licensing crackdown alone will not move the number.

Enforcement Over Tax

Where the Campaign and the licensed industry genuinely part company is on what to do next. The Campaign argues that governments which tax lightly have no reason to protect their licensed base, and that a properly taxed sector gives regulators real leverage over affiliates. Derek Webb’s line is blunt: if the sector is taxed adequately, affiliates start asking why they are losing revenue to operators who pay the tax. Britain’s example is the illustration: after raising remote gambling tax from 21% to 40%, the Treasury funded the Gambling Commission and the DCMS with £26 million to address the illegal market.

That logic meets a wall in an industry already facing higher taxes in several European jurisdictions. Borut Petek of Super Technologies calls higher taxation of licensed operators a route to making the problem worse, because illegal operators pay no tax and carry no compliance burden. EGBA’s argument is that every tax increase widens the competitive gap, showing up to players as weaker odds and thinner bonuses. Enforcement, not fiscal pressure, is the sector’s answer.

The Dutch case adds a third front. VNLOK has taken legal proceedings against Meta over the platform’s ad library, arguing that illegal gambling sites’ adverts are still being served even after they are flagged. The report’s infrastructure list runs longer than gambling regulators: affiliates, advertising platforms, payment processors, app stores, search engines, social media, streaming services, cloud providers and game suppliers. It is this list, not the individual illegal sites, that the industry says governments should actually be regulating.

The Infrastructure Problem

The political difficulty is jurisdictional. Gambling remains largely a national competence in Europe, while advertising, payments, search, cloud hosting and streaming operate across borders without respecting them. Borut Petek argues for stronger European cooperation against the cross-border infrastructure that sustains illegal operators, while still stopping short of EU-wide gambling regulation. Kieran O’Keefe, adviser to the Campaign, proposes a more radical route: treat illegal gambling as an internet-harms issue and use the machinery already built for it.

The Campaign’s underlying warning is about who pays for enforcement. It does not only want to shield licensed operators from offshore competition; it wants governments to capture more revenue from the legal sector once enforcement works. The operators’ counter is that the tax increase comes first and the enforcement comes after, which widens the gap while the sector is weakest. The report leaves three questions for the EU agenda: how much gambling is outside national licences, how effectively governments can police the infrastructure behind it, and whether enforcement would give governments room to tax the legal market without losing players. Nothing in the study answers the last one yet.

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