A RECENT study on illegal online gambling across Europe, commissioned by Euromat and carried out by research partners Regulus Partners and HELIOS, offers the most comprehensive analysis to date of the scale, evolution and key drivers of Europe’s illegal online gambling market. The findings are striking.

According to the research, the illegal online gambling market reached approximately €12bn in 2025, accounting for around 25 per cent of Europe’s total online gambling market. Even more significant, the market has tripled in size since 2019.

The report has gained significant media traction. More than 18 articles have reported on the study in recent weeks – including Casinolife, Gaming International Online, iGamingFuture, Casino Inside and SCCG – with the main focus being restrictive policies, national monopolies, the rise of crypto gambling and other primary drivers of the illegal online market. Articles by Casinoguru and iGamingTimes have highlighted the report’s findings regarding the concerning growth of the illegal market.

Unsurprisingly, with increasing media reports have come new or intensified calls for stronger enforcement measures and for tougher action against illegal operators across the continent. On September 14, in a blogpost published on the regulator’s website, the chair of Dutch Gambling Authority Kansspelautoriteit, Michel Groothuizen, demanded tougher actions and enhanced cooperation at EU level to combat illegal gambling. In accordance with perhaps the most important takeaway from the report, he warns that a well-regulated legal national market and well-functioning national regulator are not in themselves sufficient to combat illegal gambling.

The timing of the study is crucial. Across Europe, policymakers are considering new measures to tighten rules on advertising, extend cooling-off breaks and impose stake limits – all of which raises the question whether policymakers have properly considered the impact such measures may have on channelling consumers away from regulated markets. The debate should ultimately focus on how policies weakening the attractiveness of the regulated market could unintentionally create both opportunities and incentives for illegal operators.

The stakes are high for policymakers and for the legal gambling sector. The challenge is not simply to regulate gambling more heavily, but to regulate it more effectively. With new data now on the table providing policymakers with evidence and a clearer understanding of the drivers behind illegal gambling, now is the time to harness new momentum.

AS we leave behind another warm summer where temperatures have climbed to new heights, policies and legislation have kept moving. Across Europe, key developments in anti-money laundering and artificial intelligence have continued shaping the gaming environment, and Euromat has remained actively engaged every step of the way.

On June 3, 2026, the EU’s Anti-Money Laundering Authority launched a public consultation on its draft guidelines on ongoing monitoring of business relationships. The consultation, which closes on September 3, 2026, seeks input from stakeholders on the guidelines’ aim to clarify how obliged entities should conduct ongoing monitoring of business relationships for anti-money laundering and combatting funding of terrorism purposes. While these draft guidelines do not create new legal obligations beyond the Anti-Money Laundering Regulation, national supervisors are likely to use them as benchmarks. Recognising the potential impact, I participated in AMLA’s online public hearing on July 9, 2026, where I communicated the perspective of the gaming sector. AMLA will now consider the feedback received and prepare final guidelines, expected later this year.

Another important development took place on August 2, 2026, when the transparency rules (Article 50) of the EU AI Act became enforceable, directly affecting gambling operators developing an AI system or placing one on the market or putting it into service under the operator’s own name or trademark. Providers must now ensure users are clearly informed when interacting with AI systems and must ensure AI-generated or manipulated content is labelled and detectable. These transparency rules will have wide-ranging implications for online gambling within areas such as chatbots, marketing, personalisation and synthetic representations of people. While systems already on the market before August 2 have until December 2, 2026, to meet the new requirements, the message for operators is clear: now is the time to get ahead of regulation and monitor your AI tools to ensure they are transparent. Non-compliance could result in fines up to €15m or three per cent of global turnover.

As regulation continues to evolve, Euromat remains committed to advancing the interests of our members and working towards a competitive, sustainable and successful future for the land-based gaming sector.

ACROSS Europe, consensus is growing that illegal gambling is no longer a fringe issue, but a fast-growing threat reshaping the market and undermining public policy.

To put numbers on this threat, Euromat is finalising an upcoming report analysing 28 European online gambling markets: to identify the causes, size, growth, trends and key characteristics of Europe’s growing illegal market ecosystem.

The findings are hard to ignore. In 2025 alone, the illegal online gambling market generated roughly €12bn in net revenue, accounting for a striking 25 per cent of the total online gambling market across the jurisdictions in question. Indeed, the illegal market has tripled in size since 2019.

What drives players toward the illegal market? The research clearly points to regulatory design. Illegal markets thrive where legal ones become inconvenient. Restrictive policies cause regulatory friction and burdens for consumers, which encourages them to seek products and services legally unavailable close to home – but illegally accessible just one click away.

The report shows six main drivers of the illegal market in online gambling. First, limited choice (often the result of monopolies) pushes customers wanting variety toward illegal options. Advertising restrictions reducing visibility of regulated offers is another factor. So, too are bans on key online gambling products, as well as price distortions and consumer-facing taxes which make the legal market less attractive financially. Finally, spending restrictions can encourage circumvention.

Country comparisons are especially revealing. Germany, which restricts customers at practically every level, has a growing illegal market. France, Europe’s largest illegal market, has bans on all online gaming products except poker and bingo. Ireland, by contrast, has very little regulatory burden (no restrictions on consumer expenditure and no taxes directly falling on the consumer) and therefore a very small illegal market. The analysis shows a clear correlation between the number and degree of restrictions placed on consumers and the size of the illegal market in a given jurisdiction.

Taken one by one, all such measures may be well-intentioned. But taken together, they risk creating a system that pushes users to illegal activity. There is thus a fine line between protecting consumers and pushing them away. For policymakers, the challenge is clear: to design frameworks channelling demand into regulated environments rather than feeding illegal markets – and the harmful behaviours the regulations aim to mitigate in the first place. The data is clear; now’s the time to use it.

ACROSS the continent, consensus is growing that illegal gambling is no longer a fringe issue, but a fast-growing threat reshaping the market and undermining public policy.

To put numbers on this threat, Euromat has published a report analysing 28 European online gambling markets: to identify the causes, size, growth, trends and key characteristics of Europe’s growing illegal market ecosystem.

The findings are hard to ignore. In 2025 alone, the illegal online gambling market generated roughly €12bn in net revenue, accounting for a striking 25 per cent of the total online gambling market across the jurisdictions in question. Indeed, the illegal market has tripled in size since 2019.

What drives players toward the illegal market? The research clearly points to regulatory design. Illegal markets thrive where legal ones become inconvenient. Restrictive policies cause regulatory friction and burdens for consumers, which encourages them to seek products and services legally unavailable close to home – but illegally accessible just one click away.

The report shows six main drivers of the illegal market in online gambling. First, limited choice (often the result of monopolies) pushes customers wanting variety toward illegal options. Advertising restrictions reducing visibility of regulated offers is another factor. So too are bans on key online gambling products, as well as price distortions and consumer-facing taxes which make the legal market less attractive financially. Finally, spending restrictions can encourage circumvention.

Country comparisons are especially revealing. Germany, which restricts customers at practically every level, has a high and growing illegal market. France, Europe’s largest illegal market, has bans on all online gaming products except poker and bingo. Ireland, by contrast, has very little regulatory burden (no restrictions on consumer expenditure, and no taxes directly falling on the consumer) – and therefore a very small illegal market. The analysis shows a clear correlation between the number and degree of restrictions placed on consumers and the size of the illegal market in a given jurisdiction.

Taken one by one, all such measures may be well-intentioned, but taken together they risk creating a system that pushes users to illegal activity. There is thus a fine line between protecting consumers and pushing them away. For policymakers, the challenge is clear: to design frameworks channeling demand into regulated environments rather than feeding illegal markets and the harmful behaviours the regulations aim to mitigate in the first place. The data is out; now’s the time to use it.

THIS month we take a step back and look at several policy developments on the horizon. A series of important EU policy developments are taking place, potentially reshaping the regulatory landscape with new challenges for the gambling industry.

A hot topic in the EU is the launch in April of the EU’s controversial digital age-verification app. European Commission president Ursula von der Leyen announced that the app, advanced through a non-binding recommendation, was “technically ready” and would be rolled out “soon”. The commission has also published a technical blueprint and an EU age-verification scheme for member states to implement nationally or to integrate into the EU Digital Identity Wallet.

The aim is to create a harmonised, privacy-preserving standard for platforms to rely on when meeting their obligations, under the Digital Services Act, to protect minors online. While the political focus for now is mostly on restricting minors’ access to harmful or illegal sexual content online, or to social media platforms per se, the same tool could ultimately be extended to other websites or platforms offering adult-only content – including gaming and gambling services.

Meanwhile, we continue to follow closely developments ahead of the Commission’s Digital Fairness Act, expected by end 2026. The DFA will likely address practices (not always clearly defined heretofore in existing EU rules) like “addictive design,” “dark patterns,” personalised or unfair pricing and misleading advertising. The DFA signals a broader shift in how the EU is approaching consumer protection in digital environments and it could have important consequences for online gambling.

Finally, the EU’s Anti-Money Laundering Authority has launched a consultation on draft guidelines for business-wide risk assessments, a tool regulated entities must use to identify and manage money-laundering and terrorist-financing risks across their operations. For the gambling sector, the stakes are especially high. Maintaining – at most – a “medium risk” classification is absolutely essential to avoid disproportionate regulatory burdens undermining our industry’s viability in Europe. The consultation remains open until 15 July 2026; those affected are well advised to engage.

So, we have still a lot of work to do this year. To ensure the safety, competitiveness and success of our members and of the gaming sector across Europe.

WHEN the EU adopted the Digital Services Act in autumn 2022, it set out to renovate the digital ecosystem by preventing illegal and harmful activity. Applicable from February 2024, the DSA became the EU’s flagship framework for governing digital platforms and intermediaries.

DSA enforcement against very large online platforms and search engines – or those with more than 45 million users per month in the EU – is carried out by the European Commission. VLOPs or VLOSEs not in compliance face fines of up to six per cent of annual global turnover.

For other platforms, designated national digital service coordinators are the main enforcers. Supporting DSCs, in one of the DSA’s most innovative concepts, are a host of trusted flaggers: designated experts – including potentially both professional and civil-society organisations – duly authorised by DSCs to identify illegal content online.

Obtaining trusted-flagger status varies from one EU Member State to another. DSCs oversee the application process and make sure entities demonstrate real expertise, competence, accuracy and objectivity. The status can even be revoked or suspended if an entity misuses its position or lets its standards slip.

The trusted-flagger label offers opportunities for Euromat members: a new tool of cooperation in preventing illegal online gambling. As highlighted in last month’s InterGame column, this is a fight Euromat is taking head-on: including with our spring 2026 illegal online gambling report. Trusted flagger status is yet another way Euromat members and partners across the industry, together with national regulators, can join forces in stopping illegal online activity: to ensure such operators are identified quickly and their content quickly removed.

Though the DSA is only enforceable in the EU, its influence is wider. EU accession countries, including Montenegro, are increasingly aligning their rules with the EU acquis in preparation for membership – potentially as early as 2028. The UK’s Online Safety Act, adopted in autumn 2023, shares the DSA’s ambition to protect users from illegal and harmful online content. The UK’s Ofcom serves as an active enforcer of the OSA’s requirements for digital platforms.

The DSA’s trusted-flagger system remains dynamic, with the European Commission preparing guidelines to streamline the application and accreditation process; a public consultation is planned for Q2 2026, with new guidance in place by the end of the year.

Collective efforts to tackle illegal online gambling across Europe must be dynamic, too. Such efforts are crucial: to protect users from harmful activity, prevent loss of legitimate public revenue, and preserve a system of fair competition for legal operators.

ACROSS Europe, there is a growing consensus that illegal gambling has become not just a core economic threat to those playing by the rules of the regulated gaming sector but a threat to social health more broadly. If Europe is serious about protecting players, safeguarding public revenues and ensuring fair competition, stronger enforcement against illegal operators must become a shared priority.

Licensed gaming operators across Europe follow strict regulations. They invest heavily in compliance and responsible gambling measures, including age verification and anti-money-laundering checks. But illegal operators shirk all this. They evade oversight, avoid paying their fair share of taxes and undermine legitimate businesses – all while targeting consumers with the help of misleading advertising on unregulated platforms.

The consequences go beyond gaming. Legal businesses are undermined, public services lose out on precious owed resources and vulnerable individuals, including minors, are left outside the protection of safeguards like deposit limits, self-exclusion systems or identity checks.

Euromat has commissioned a new report outlining the scope of the problem and our members are putting forward ideas for how to make things better.

Several ongoing initiatives make clear the need for more EU-wide measures. In just one recent example, Romanian member of the European Parliament, Victor Negrescu, argued for an EU-wide tax on online gambling to crack down on illegal gambling online as well as to generate new EU own resources which can be used for education or health. It is true that gambling, like taxation, has historically been a competence exclusive to members states, so MEP Negrescu’s proposal likely faces an uphill battle politically.

And yet the debate itself reflects a growing consensus. Euromat’s report highlights that online illegal gambling is only becoming more and more of a problem. Given the inherently transnational element of the online world, even stronger cooperation between national authorities will be needed.

For Europe’s regulated gaming sector, the bottom line is clear. Combating illegal gambling is not about restricting legitimate operators, but about defending them. Stronger enforcement, better cooperation between regulators and more accountability for online platforms hosting illegal advertising would all help ensure that consumers are channelled toward responsible, licensed operators. Europe has the rules; it needs coordination and determination in enforcing them.