A Report for the Campaign for Fairer Gambling Puts Unregulated Operators at 72% of the EU's Online Market

Gaming Compliance International estimates €91.6bn of unregulated gross gambling revenue across the EU 27 in 2025, up 74% on 2023, and about €22bn in lost tax. The headline number will be quoted all week, so the definitions behind it and who commissioned the work both matter.

• Unregulated online gambling generated an estimated €91.6bn in gross gambling revenue across the EU 27 in 2025, or 72% of a €128bn online market, according to a study by Gaming Compliance International conducted on behalf of the Campaign for Fairer Gambling and reported by NEXT.io
• That is a 74% increase on the €52.6bn the report attributes to 2023, when unregulated operators are said to have taken 67% of online gross gambling revenue
• The study estimates about €22bn in gross gambling revenue related tax was lost to unregulated operators in 2025, and identifies 6,238 unregulated operators and 17,501 affiliates targeting consumers across the 27 member states
• Of the 121 million Europeans the report says were reached by online gambling content, 88 million encountered it through unregulated operators; among consumers actively interacting with such content, 91% of what they saw promoted the unregulated sector
• Some 95% of qualifying illegal streams of sports events viewed in Europe during the FIFA World Cup carried advertising for gambling not licensed in the relevant jurisdiction, the report says

A Very Large Number, and the Argument It Is Built to Support

A report published on Tuesday puts the unregulated share of the European Union's online gambling market at nearly three quarters. Gaming Compliance International, working for the Campaign for Fairer Gambling, estimates that unregulated operators took €91.6bn in gross gambling revenue across the EU 27 in 2025, against a total online market of €128bn. On the same basis it puts the 2023 figure at €52.6bn and 67%, which makes the increase 74% in two years.

The study goes beyond revenue. It counts 6,238 unregulated operators and 17,501 affiliates active across the bloc, and about €22bn in gross gambling revenue related tax foregone in 2025. On exposure, it says 121 million Europeans were reached by online gambling content and 88 million of them through unregulated operators, and that for consumers who actively engage with gambling content, 91% of what they encounter promotes the unregulated sector. It describes much of that promotion as "cloaked advertising" built to evade platform controls, and reports that 95% of qualifying illegal sports streams watched in Europe during the FIFA World Cup carried advertising for operators not licensed where the viewer was.

The recommendation follows from the framing. Enforcement, the report argues, should stop chasing individual websites and address the ecosystem that lets them reach consumers: affiliates, social media, search, apps, payments, peer to peer messaging and illegal streaming, policed across borders rather than one jurisdiction at a time.

"The answer is not weaker regulation or tax concessions for licensed operators," said Derek Webb, founder of the Campaign for Fairer Gambling. "Europe has an enforcement problem. Unregulated gambling operates across borders, platforms and infrastructure while enforcement remains overwhelmingly national. A licence 'from somewhere' is not permission to operate everywhere."

GCI president Ismail Vali put the same point at the operators. "Six thousand unregulated operators are not six thousand separate problems," he said. "They rely on the same ecosystem to advertise, find consumers, distribute products, move money, and stay online. That is also their vulnerability."

The Number Cuts Against the Industry's Favourite Argument, Which Is Why It Will Be Contested

The licensed industry's standard response to tax rises and advertising limits is that they push players to the black market. This report accepts the black market is enormous and explicitly refuses that conclusion, saying the answer is not weaker regulation or tax concessions. Both sides now have a channelling argument and the same underlying phenomenon to point at, which means the fight moves to method: what counts as unregulated, how revenue is estimated for businesses that publish nothing, and whether an operator licensed in one member state and taking bets in another is unregulated or merely unlicensed locally. None of that is visible from a headline percentage.

Commissioned Research Is Not Disqualified by Being Commissioned, but It Has to Show Its Working

The Campaign for Fairer Gambling is Webb's vehicle and has spent a decade arguing for tighter restrictions. That does not make the findings wrong, and GCI's data on affiliates and cloaked advertising is the kind of measurement regulators do not do for themselves. It does mean the report should be read alongside the regulators' own estimates rather than instead of them, and those vary widely: the Dutch regulator's chairman said this month that half of every euro staked in his market goes to illegal operators, which is a lower share than 72% and derived differently again.

The Ecosystem Argument Is the Part Worth Keeping

Domain blocking is the tool most European states reach for, and its record is poor because a blocked domain is replaced in hours. The report's case is that the reachable chokepoints are elsewhere: the affiliates that rank in search, the payment rails, the app stores and the streams that carry the advertising. That is harder politically, because it means regulators leaning on intermediaries that are not licensees and in many cases are not in the jurisdiction at all. It is also the only part of the report that tells a regulator what to do differently on Monday.

Europe now has an estimate large enough to embarrass every regulator in the bloc. What happens next depends on whether anyone audits the method before quoting the number.