EU Scams Study Finds Ad Systems May Let Unlicensed Gambling Operators Advertise

A study written for the European Commission under the Digital Services Act says platform advertising systems may let unlicensed gambling operators reach users in countries where they hold no licence, with no platform check of their licensing status. Dutch regulators and operators are already pressing Meta on exactly that gap.

• A study for the European Commission's Directorate-General for Communications Networks, Content and Technology (DG CNECT) says ad systems may enable unlicensed gambling operators to target users in countries where they hold no valid licence
• Spark Legal and Policy Consulting and Open Evidence wrote the report, which the Commission published on 20 October to support its supervision of very large online platforms under the Digital Services Act (DSA)
• Citing Debunk.org, the study says 99% of gambling scam cases involved ads, and it describes fake casinos that block withdrawals
• It finds that high-assurance verification of advertisers remains the exception, and interviewees called for proof of licensing from advertisers in regulated sectors, gambling included
• The findings follow the Kansspelautoriteit's report of more than 4,600 illegal gambling ads to Meta in April

A Commission Scams Study Names the Licence Gap in Platform Advertising

The report, titled "Support contract on financial scams study", was written for DG CNECT's e-Commerce unit. The EU Publications Office released it on 16 October and the Commission published it on 20 October, saying it procured the study in 2025 to support its DSA supervisory and enforcement tasks. According to its legal notice, the views are the authors' and do not necessarily reflect the Commission's official opinion, and the study says it does not assess any platform's DSA compliance. Articles 34 and 35 of the DSA require very large online platforms and search engines to assess and mitigate systemic risks, including the spread of illegal content, which the study says includes fraud.

The authors drew on more than 400 desk sources, including platforms' 2025 systemic risk assessment reports, 15 structured interviews, a DG CNECT survey of national authorities answered from 16 Member States, and a workshop. Gambling scams form one strand of "unexpected gain scams", one of six categories alongside investment, romance, e-commerce, employment and collaboration, and charity and disaster relief scams.

How the Study Says Gambling Scams Reach Users

The study describes fake online casinos, sports betting services and gaming platforms that promise guaranteed winnings or reliable betting systems, encourage small first deposits, rig outcomes so losses are inevitable, and then block withdrawals or freeze accounts.

Paid advertising is a primary distribution mechanism for these scams, the study says, citing Debunk.org's finding that 99% of gambling scam cases involved ads placed to target any country and language. It states that platform advertising systems "may enable unlicensed gambling operators to illegally promote services to users in countries where they hold no valid licence", exposing users to unregulated platforms "without any platform-level verification of operator licensing status". It also cites Trend Micro research on hundreds of fake apps on the Apple App Store and Google Play that switch on hidden gambling functions after review.

Verification Remains the Exception

Most platforms rely on advertiser self-declaration, the study finds. Google, LinkedIn, Pinterest, TikTok and Bing restrict or require certification for categories including gambling, but the authors call that narrower than universal verification. One interviewee pointed to Google's financial services verification, which checks a licence against the relevant registry in almost 20 countries, six of them in the EU. Citing Reuters, the study says mandatory verification in Singapore and Taiwan cut scam ads by between 29% and 96%.

The Commission says there is no sector-specific EU legislation for gambling services and that EU countries are autonomous in organising them, so whether an advertiser is licensed is a national question each platform must answer market by market.

The Licence Check Is the Missing Control

Several large platforms already treat gambling as a restricted ad category, so the gap the study identifies is not a missing rule but a missing check against national licence registers. Google's financial services model shows registry-based verification can work at scale, and the Singapore and Taiwan figures suggest it moves the numbers.

The Gambling Evidence Is Thinner Than the Headline

The jurisdictional point is framed as a possibility, and its footnote leads back to a single trusted flagger. The study also runs together rigged fake casinos and operators licensed elsewhere advertising into markets where they hold no permit, which need different remedies, and it sizes neither. Its value is that a document commissioned for DSA supervision now names the gap.

National Pressure Is Already Testing the DSA Route

VNLOK has asked a Dutch court to find Meta in breach of its DSA obligations over illegal gambling ads, and Paf says it has agreed a Swiss pilot to give Meta licence documents. The International Association of Gaming Regulators plans a free licence-checking site. Each is a version of the check the study describes as missing.

The study gives Brussels an evidence base for asking platforms to verify licences before serving gambling ads, but not a measure of how much unlicensed advertising gets through. Until someone counts it, the case will be argued market by market.