Two Black-Market Studies Land in a Day: €12bn in Europe, $50bn Worldwide
By Antonina Tupikova · Founder, iGaming Times3 min read
Euromat puts Europe's illegal online market at €12 billion and says it has tripled since 2019. The Betting and Gaming Council promotes a separate report putting the global figure at $50 billion. The two numbers cannot be compared, both were commissioned by interested parties, and both reach the same conclusion about what enforcement is doing wrong.
- Research commissioned by Euromat puts Europe's illegal online gambling market at an estimated €12 billion in net revenue for 2025, tripled since 2019 and around 25% of the European online sector
- A separate report by Fincord Intelligence, promoted by the Betting and Gaming Council, puts global illegal online gambling at approximately $50 billion in gross revenue for 2025
- Fincord estimates around 5,000 operator structures ran more than 15,000 websites and apps, using mirror domains, VPN access and browser-based applications to return quickly after blocking
- It found illegal operators deliberately targeting people who have self-excluded, including through sites marketed as Non-GamStop casinos, and put cryptocurrency at around 35% of payments
- Both land in the same week as a paper prepared for Entain making the same argument from the operator side
Two Numbers, Two Sponsors, One Week
Two separate attempts to size the illegal online gambling market were published within hours of each other, and neither is measuring the same thing.
The first was commissioned by Euromat, the European Gaming and Amusement Federation, which represents the continent's land-based entertainment and gaming sector. Conducted by the advisory firm Regulus Partners and the web traffic specialist Helios across 28 European markets, it estimates that Europe's illegal online gambling market generated €12 billion, approximately $14.1 billion, in net revenue during 2025. The study says the market has tripled in size since 2019 and now accounts for around 25% of the European online gambling sector. The method combined web traffic and digital marketing analysis with macroeconomic and regulatory data.
Helios managing director Filip Jelavić placed the cause squarely on policy. "It's clear that online gambling black markets don't happen by accident but instead are the result of government policies that create consumer friction," he said. "In such an environment the key drivers are a combination of limited choice based on regulation and state monopolies, low visibility, distortions of price or value, as well as interventionist measures such as affordability checks." He added that a handful of illegal operators have reached sufficient scale to establish recognisable brands and take meaningful market share, and that cryptocurrency has been central: "The traffic analysis that we've undertaken shows that the rapid growth of cryptocurrencies has been key to building many of these businesses in terms of product differentiation and regulatory workarounds."
The Dutch state lottery has meanwhile taken a Curacao-licensed operator to court over unlicensed play aimed at its market, one of several such actions in recent months.
Euromat president Jason Frost said offshore operators hold an advantage over licensed competitors because they avoid gambling taxes and regulatory costs, and that the association will use the research as the basis for engagement with European governments and enforcement bodies.
The Second Report Is About Infrastructure, Not Size
The Betting and Gaming Council has separately promoted a report by Fincord Intelligence estimating global illegal online gambling revenue at approximately $50 billion in gross revenue for 2025. Its more useful contribution is structural. Fincord estimates that around 5,000 operator structures used more than 15,000 websites and apps to reach consumers in 2025, relying on mirror domains, VPN access and browser-based applications that allow a blocked service to return almost immediately.
The finding with the sharpest edge concerns self-exclusion. Researchers say some operators deliberately target users who have excluded themselves through official routes, citing sites marketed as Non-GamStop casinos that promote to people registered with the British scheme, reached through search engines, social media, affiliates, influencers, Telegram and WhatsApp. Illegal sites compete on fewer restrictions, the report says, including deposit bonuses of up to 500% and faster payouts. Around 35% of payments across illegal sites were made in cryptocurrency, a share Fincord estimates could reach 70% by 2030. Fincord, which is based in Ukraine, also raised concerns that some illegal sites are associated with Russia.
Its recommendation is to stop chasing domains. "Illegal gambling is no longer a collection of isolated websites," a Fincord spokesperson said. "Governments must target the infrastructure that allows these illegal ecosystems to survive, rather than relying solely on blocking individual websites." The report names payment services, cryptocurrency intermediaries, affiliates, advertisers, software suppliers and hosting providers as the targets.
BGC chief executive Grainne Hurst said the report showed illegal gambling was "no longer simply a regulatory issue", and that operators were "deliberately targeting vulnerable customers in the UK, including people who have self-excluded, using social media, affiliates and messaging platforms to avoid the protections of the regulated market". She called on the government to coordinate law enforcement, regulators, payment providers and technology companies "to target the networks supporting these operators, not just individual websites".
The Two Headline Numbers Cannot Be Put in the Same Sentence
€12 billion is net revenue across 28 European markets. $50 billion is gross revenue worldwide. Those are different denominators over different territories, and anyone placing them side by side to show the problem growing is comparing nothing to nothing. This is not a quibble about presentation. It is the reason black-market estimates have so little purchase with treasuries: every figure arrives with its own scope, its own method and its own sponsor, and no two can be checked against each other. The Vanguard Overwatch paper published this week made exactly this point, arguing for triangulation across operator data, traffic indicators, affiliate analysis and payments intelligence rather than a single headline.
Every Study This Week Was Paid For by Someone With a Position
Euromat represents land-based operators who compete with online supply. The BGC represents licensed British operators facing a tax rise. The Vanguard paper was prepared for Entain. None of that makes the research wrong, and the traffic and payments work in the Euromat study is real analysis rather than assertion. But it does mean the sector currently has no black-market estimate that a sceptical minister could cite without being asked who funded it. The absence is the industry's own problem to solve, and it is why regulators publishing their own channelisation figures matters more than another commissioned report.
The Self-Exclusion Finding Is the One That Should Move Policy
Strip out the sizing and one claim in the Fincord report stands apart, because it is specific, falsifiable and does not depend on a market estimate: that operators are marketing to people who have registered with a national self-exclusion scheme, and reaching them through search, affiliates and messaging apps. That is a targeted harm against an identified vulnerable population, it happens on platforms with names and owners, and it can be investigated without agreeing on how big the market is. The UK has documented the Non-GamStop sector before; what it has not done is treat evasion of self-exclusion as a distinct enforcement priority.
Two studies, two numbers, one message: blocking domains has stopped working. That much the industry, the regulators and their critics now agree on. The argument is only about who should pay to fix it.


