Key Points
- Unregulated GGR across 27 EU member states jumped 74% between 2023 and 2025, reaching an estimated €91.6bn.
- Among Europeans actively interacting with online gambling content, 91% of what they encountered promoted the unregulated sector.
- The average initial licensing fee for a multi-product licence across the four “transnational” jurisdictions named in the report sits at approximately €33,000, against roughly €1.1 million across EU 27 markets.
Online gambling which remained unregulated was said to have made a gross gambling revenue of €91.6 billion in the year 2025 for the whole EU, which represented 72 per cent of the total €128 billion market for online gambling in Europe. The information above was gathered from a recent study carried out by Gaming Compliance International (GCI) which was commissioned by the Campaign for Fairer Gambling. The unregulated Gross Gambling Revenue increased by 74 per cent to €52.6 billion in the year 2023 while the regulated one grew by 8.6 per cent to €36.5 billion in 2025.
Based on an average EU tax rate of roughly 24% on gross gambling revenue, the study estimates that EU member states failed to collect around €22bn during 2025. That figure is a modelled estimate, not a directly observed government loss, and GCI frames it accordingly. Placed in a wider context, a separate GCI global report published in May 2026 put unregulated online gambling wagering value worldwide at $5.9 trillion, with unregulated operators accounting for 78% of worldwide online gaming gross revenue. The EU study also identified 6,238 unregulated online gambling operators and 17,501 affiliates actively targeting consumers across the EU 27.
The Audience Is Already Captured Before a Single Bet Is Placed
The most striking finding in the report is not the GGR number. It is where the market is actually lost. Some 121 million Europeans were reached by online gambling content in 2025, with 88 million accessing it through unregulated operators. Among consumers actively interacting with online gambling content, 91% of what they encountered promoted the unregulated sector. That is GCI’s audience-exposure measurement, spanning search, social media, advertising, apps, affiliates and streaming combined, not a standalone click-rate figure.
GCI president Ismail Vali put the structural problem plainly: “Unregulated gambling is winning audience attention across search, social, affiliates, advertising, streaming and apps before the consumer ever reaches a gambling site.” Regulators are still building walls around individual unlicensed domains, while the infrastructure routing Europeans toward those domains operates entirely upstream, largely unchallenged. The report described much of this activity as “cloaked advertising,” designed specifically to evade the automated review systems used by platforms including Google and Meta, with ad brokers, more than half of them based inside the EU, selling disguised ads into every member state.
Kick, Pirated Streams, and What the 2026 World Cup Revealed
The connection between unregulated gambling promotion and pirated sports content is not incidental, and the 2026 FIFA World Cup produced a sharp illustration of how deep it runs. The GCI report found that 95% of qualifying illegal streams viewed in Europe during the tournament carried advertising for gambling not licensed in the relevant jurisdictions, across 17.8 billion qualifying stream views in Europe.
The report names Kick directly in this context. Kick launched publicly in late 2022, weeks after Twitch banned streaming from unregulated gambling sites, a move widely understood to target Stake-sponsored streamers. Bijan Tehrani confirmed nearly $1 billion in personal investment into Kick by April 2026. Using SimilarWeb traffic data, GCI found that 19% of all traffic leaving Kick during World Cup peak periods went to Stake. The report found Kick blocks its slots category in six EU countries, with the block functioning in one, Greece. Entain separately described Kick as a “central hub of the illegal gambling influencer ecosystem,” citing its dedicated gambling category with minimal age verification and its role as a launchpad for content spread across TikTok, Instagram and YouTube. Florida’s attorney general sued Kick Streaming, Stake.us, Easygo, Ed Craven and Bijan Tehrani in August 2026 over sweepstakes casino operations, alleging the platform functions as a continuous advertisement for Stake. That case remains pending.
A Licence From Somewhere Is Not a Licence to Operate Everywhere
The fee comparison at the centre of the report explains much of the incentive structure for operators choosing jurisdictions outside national EU regulatory frameworks. GCI’s data shows the average initial licensing fee for a multi-product licence across EU 27 member states sits at approximately €1.1 million, with an average tax rate of 24% on gross revenue. Across the four jurisdictions the report classifies as “transnational,” Malta, Anjouan, Curaçao and the Isle of Man, that average initial fee drops to approximately €33,000, with a tax rate of 2.3%. The report notes these figures exclude additional requirements such as bank guarantees and share capital obligations.
The Maltese membership has special legal significance. The European Commission initiated infringement procedures in June 2025 with regard to Malta for the violation of EU legislation concerning cross-border recognition of judgments by the adoption of its domestic legislation – Article 56A law, or Bill 55. Further, on 23 April 2026, Advocate General Nicholas Emiliou gave his opinion on Case C-683/24, stating that Bill 55 is inconsistent with the relevant EU legislation. It should be pointed out that his opinion is not obligatory for the court judges to accept, although Emiliou has repeatedly made similar decisions in other cases connected to Bill 55.
Derek Webb, founder of the Campaign for Fairer Gambling, said: “A licence ‘from somewhere’ is not permission to operate everywhere. If an operator takes money from consumers in a European jurisdiction, it should comply with the laws and protections of that jurisdiction.”
What GCI Is Asking Regulators to Change?
The report’s core enforcement argument is that blocking individual unregulated websites is insufficient. It calls for cross-border coordination targeting the advertising infrastructure, payment systems, affiliate networks and streaming platforms sustaining unregulated operators as a connected ecosystem. Vali added: “Six thousand unregulated operators are not six thousand separate problems. They rely on the same ecosystem to advertise, find consumers, distribute products, move money, and stay online. That is also their vulnerability. You cannot optimise what you do not measure. Europe needs to see the whole marketplace and enforce across the ecosystem that sustains it.” Policymakers at the European Parliament have held roundtable discussions on the findings, with cross-border enforcement mechanisms, including possible changes to Europol’s authority, under discussion, though no formal policy decisions have been announced.
Expert Analysis
We think this report deserves careful reading, and equally careful scrutiny. As Forbes noted in its analysis of the GCI data, the firm counts every site and app actively taking money from a country’s residents, mirror domains included, which produces figures materially larger than comparable estimates from other organisations. GCI’s US figure for unregulated gambling sits alongside an American Gaming Association estimate roughly a quarter of the size, a gap attributable to definitional differences rather than calculation error, but a gap that illustrates how much the measurement methodology shapes the headline number.
It does not make the findings of the EU 27 any less reliable, however. It is important to consider the commissioning agency of the study. The Campaign for Fairer Gambling has been funded and established by Derek Webb, a former professional poker player, creator of the game known as Three Card Poker and one who sold all his casino games in 2011. Since establishing CFG, the stated aim of Derek Webb has been tighter enforcement and regulation of the gambling industry. This is a consistent stance from the consumer protection perspective.
Where the report lands on solid ground is the audience-exposure data. The finding that 91% of gambling content encountered by actively interacting European consumers promotes the unregulated sector describes a structural capture of the audience that site-blocking alone, operating downstream of advertising ecosystems and streaming platforms, has not reversed. That is the number regulators should be interrogating, because the enforcement model it challenges is still the dominant one.
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