Key Points
- The European Casino Association’s annual GCI study puts the EU illegal online gambling market at €91.6bn in 2025, up 14% year-on-year, with estimated tax losses of €22.9bn across member states.
- The Netherlands reveals a sharp gap in how channelisation is measured: 91% of players use licensed operators, yet only 53% of total gambling spend stays within the regulated market, pointing to the highest-risk players concentrating on illegal sites.
- Enforcement strategies continue to be segregated on a national level, whereas attempts at addressing the issue at an EU level, such as expanding the powers of Europol or a 1% cross-border gambling tax, face major obstacles.
A Black Market That Grew While Regulators Watched
When the European Casino Association convened a high-level roundtable at the European Parliament on 3 July 2026, the headline number organisers had prepared was already obsolete. The event title still referenced a 2024 estimate of €80bn. Then ECA chair Erwin van Lambaart presented the 2025 figures from Gambling Compliance International: the illegal online gambling market targeting EU consumers had reached €91.6bn, up around 14% year-on-year, with more than 6,200 unlicensed operators actively targeting European consumers.
The ECA derived its tax loss figure by applying a 25% GGR assumed rate to that total, arriving at €22.9bn in foregone member state revenue; that rate is drawn from previous Yield Sec methodology and is a comparable estimate, not an audited figure.
“According to the GCI report data of 2025, there is no denying the fact that the phenomenon of illegal online gambling has become an increasing international problem which endangers players, particularly the youth, depriving societies of required tax incomes and making a threat to the licensed market,” stated van Lambaart.
Not Everyone Agrees on the Scale
The ECA/GCI estimate sits well above other published figures, and the gap shapes how policymakers frame the problem. The EGBA, in a March 2026 submission to the European Commission, estimated illegal operators at roughly 27% of Europe’s online gambling GGR, worth approximately €18bn. The EGBA figure measures the illegal share of a defined regulated market total; the ECA/GCI study attempts to size the unlicensed market in absolute terms, which produces a larger number.
Country-level data sits between those two positions. In Germany, a Blockchain Research Lab study commissioned by regulator GGL put the illegal share of online gambling at 22.97%, leaving a channelisation rate of 77.03%. GGL board member Ronald Benter said: “The scientifically calculated channelisation rate confirms our previous assumptions about the extent of the black market.”
No national regulator reported a shrinking illegal market in 2025.
The Netherlands: Where the Money Goes Tells a Different Story
The Dutch market illustrates why player-count channelisation figures can obscure a deeper problem. According to spring 2026 monitoring data from the Kansspelautoriteit, around 91% of Dutch players used only licensed operators in the second half of 2025. On that measure alone, the market looks largely regulated.
Only 53% of total estimated gambling spend went through those licensed operators in the same period. The other 47% went to unlicensed platforms, spent by a smaller group who lose far more per session on average. These players are unable to utilise services such as self-exclusion, deposit limits, and complaint procedures.
The KSA saw a 34% increase in reports of criminal activity to 2,005 instances and noted that fines imposed on foreign entities are limited to 10% of the total GGR worldwide under existing legislation. A bill will be discussed by the regulator in conjunction with the Justice Ministry.
The GGR in the Dutch licensed market was down roughly 18% from 2024 to 2025. The KSA linked that directly to deposit limits introduced in October 2024 and successive gambling tax increases. Measures intended to reduce harm in the regulated market appear to have pushed the highest-spending players toward illegal operators where no limits apply.
Denmark Blocks, France Debates, Belgium Escalates
There is fragmentation of enforcement in the EU due to the fact that gambling is regulated at the national level. In 2025, Denmark received orders from the court banning 334 websites involved in illegal gambling. The regulator also worked with the telecommunications sector in removing mirror sites and reported the existence of illegal gambling apps on Google.
France presents a different tension. Online casino games remain illegal under French law, yet industry association AFJEL has argued that bringing them into a regulated framework would extend consumer protections to players who are already using illegal platforms. The ANJ and the French government have declined, citing addiction risks. Current enforcement targets payment providers, hosting companies and social media platforms that carry illegal gambling traffic.
Belgium’s gaming association BAGO has pushed for rapid website and financial blocking alongside closer coordination between regulators, police and the courts. BAGO president Tom De Clercq said: “The Gambling Commission itself shows that traditional methods of enforcement are reaching their limits. We therefore need rapid blocking of illegal websites and payment flows, as well as closer cooperation between supervisory authorities, the police and the judiciary.”
What the EU Can Actually Do?
EGBA director of legal and regulatory affairs Ekaterina Hartmann made the case for action above the national level: “Fragmented national approaches to these types of fraud are not enough, we need coordinated EU-level action to ensure consumers and legitimate operators aren’t left fighting an uphill battle against fraud.”
The ECA has called for illegal online gambling to be included as a named priority in the European Commission’s June 2026 proposal to expand Europol’s mandate. Europol’s cross-border reach is considered more effective against operators that target multiple EU markets while sitting outside any single regulator’s jurisdiction.
The proposal by MEP Victor Negrescu for a 1% EU gambling levy on gross turnover would generate between €2bn and €4bn per year. An EU-wide gambling tax is subject to unanimous agreement from all member states under Article 113 of the Treaty on the Functioning of the EU. The Commission’s July 2025 funding proposals included no gambling tax measure.
Expert Analysis
There exist two enforcement approaches being implemented in tandem at the same time in Europe; each one is tugging at opposite ends. The approach that involves supply-side suppression of websites and payment methods needs coordination across countries that individual national regulators cannot sustain. The approach involving demand-side channelisation needs certain regulatory settings that may be counterproductive, as evidenced by the example of the Netherlands.
Germany reinforces the same dynamic. A turnover-based stake tax on online slots makes legal operation economically difficult, several licensed operators have already left the market, and the unlicensed sector has expanded into the space they vacated.
Both the ECA’s €22.9bn estimate and the EGBA’s narrower €18bn illegal GGR figure agree on one point: existing national tools have not contained unlicensed market growth, and revenue flowing to illegal operators has increased for another consecutive year. Whether expanded Europol powers, tighter cross-border payment enforcement, or product legalisation in markets like France can reverse that is the question the current round of EU-level discussions has not yet answered.
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