No, most online gambling money in Europe is not flowing through licensed sites
The comfortable assumption in this industry is that the black market is a nuisance at the edges: a few offshore casinos, some crypto sportsbooks, nothing that moves the needle. The story filed as 110864 la union europea alerta que el 72% de los ingresos del juego online no está regulado says the opposite. According to a new analysis of the EU-27, unregulated operators account for EUR 91.6 billion of gross gaming revenue, or 72% of a European online market valued at EUR 128 billion. On that arithmetic, the licensed sector is the minority partner.
The rest of this piece does three things: separates what the report actually says from how the headline reads, lays out the figures, and weighs the enforcement approaches available against each other. There is a verdict at the end, and it is not “block more domains”.
Who published the 110864 la union europea alerta figures, and who didn’t
Worth getting this straight before anyone quotes it in a licence application. The numbers come from “Online Gambling 2024–2025: EU 27 Europe”, produced by Gaming Compliance International (GCI) for the Campaign for Fairer Gambling (CFG). The scope is the European Union’s 27 member states. The publisher is not a European Union institution.
So “the EU warns” is shorthand for “an analysis of the EU-27 market, commissioned by a gambling-reform campaign group”. That does not make the figures wrong. It does mean you should read them the way you read any advocacy-funded market sizing, including the industry’s own channelisation estimates: the methodology and the definition of “unregulated” are doing a lot of work, and they rarely get the same scrutiny as the headline percentage.
The definitional point matters most. The report describes this activity as taking place outside the local regulatory framework. On that basis, an operator holding a perfectly valid licence in one member state and taking bets from players in another, without a local licence, counts as unregulated. That is a defensible measure of where consumer protection, taxation and supervision actually apply, and it is also why the number lands so much higher than the “criminal offshore only” figure some people carry in their heads.
The figures, in one place
The two-year trajectory is the part operators should be uncomfortable about, not the 72% on its own.
| Measure | Figure |
|---|---|
| Unregulated online GGR, 2023 | EUR 52.6 billion |
| Unregulated online GGR, 2025 | EUR 91.6 billion |
| Growth, 2023 to 2025 | +74% |
| Total EU-27 online gambling market | EUR 128 billion |
| Unregulated share of that market | 72% |
| Europeans exposed to online gambling content in 2025 | 121 million |
| Europeans exposed to unregulated operator content | 88 million |
| Share of content promoting unregulated operators, among people actively engaging with online betting | 91% |
A 74% increase in two years is not drift. Whatever combination of tax rises, product restrictions, advertising bans and offshore marketing produced it, the licensed channel lost ground quickly while regulators were busy tightening the rules that apply to the licensed channel.
The gap opens before the bet is placed
The report’s sharpest claim is about sequencing: the enforcement gap starts before money changes hands. The warning sign is not the payment, it is the discovery.
Hence the exposure data. In 2025, 121 million Europeans encountered online gambling content, and 88 million encountered content from unregulated operators. Narrow it to people who actively engage with online betting, and 91% of the content they came across promoted the unregulated sector. Read that number slowly. Someone in Europe who is already interested in betting will, on these findings, be served nine pieces of unlicensed promotion for every one from a licensed brand.
That is a marketing distribution problem dressed up as a compliance problem. Licensed operators in most EU markets face advertising caps, bonus restrictions, affiliate accountability rules and, in several countries, near-total media bans. Unlicensed operators face none of that and buy the same attention on the same platforms. The asymmetry is the mechanism, and it sits entirely upstream of the deposit.
Weighing the enforcement options against each other
Regulators have four broad levers. They are not equally matched to a problem that starts with content discovery.
| Approach | Where it acts | Trade-off |
|---|---|---|
| Domain and DNS blocking | At the point of access | Fast to order, easy to route around with mirrors and apps; treats symptoms, not supply of traffic |
| Payment blocking | After the player has already decided to deposit | Needs banks, PSPs and card schemes onside; crypto and intermediary rails keep reopening it |
| Marketing, affiliate and platform enforcement | Before the bet, at discovery | Addresses the 91% content asymmetry directly, but requires pressure on ad networks, search, social and streaming platforms that no single regulator controls |
| Licensing and tax design (channelisation) | On the licensed side of the market | Can pull demand back legitimately; politically hard, and loosening rules for licensees is unpopular with the same reform constituency that commissioned this report |
The honest verdict from the data: the first two levers are downstream of the decision, and the fourth is the only one that changes the offer players see. The third is where the numbers point, and it is also the messiest, because it means holding intermediaries rather than operators accountable. Nobody in Brussels or in a national regulator’s enforcement unit gets a quick win there.
What it means in practice
For licensed operators and affiliates: expect this report to be cited in consultations, and expect it to cut both ways. The licensed industry will use the 72% figure to argue that restrictive rules push players offshore. Reform campaigners will use the same figure to argue that the whole online model is under-supervised. Compliance teams should assume more scrutiny of affiliate traffic sources, brand-adjacent search and social placements, and streaming partnerships, because that is where the evidence is strongest.
For platforms and ad networks: an 88-million exposure figure attached to unlicensed operators is the kind of number that ends up in a regulatory annex. The direction of travel is toward intermediary liability.
For players: the practical takeaway is duller than the headline and more useful. If most gambling promotion you encounter comes from operators without a local licence, then the default assumption about any site you find through an ad, a stream or a messaging group should be that no local regulator stands behind it. Check the licence number against the regulator’s own register, not the footer. Unlicensed sites can still run games with plausible RTP figures and RNG certification claims, but there is no supervised route to complaint, no enforced KYC standard, and no guaranteed payout if the operator decides otherwise.
And the arithmetic does not change with the licence: every commercial game carries a house edge, licensed or not. Set deposit and loss limits, use cool-off tools, and if gambling stops being entertainment, national helplines and self-exclusion schemes exist for exactly that. If you are under the legal age in your jurisdiction, none of this applies to you at all.
Common questions
Did the European Union itself publish this?
No. The analysis covers the EU-27 but was produced by Gaming Compliance International for the Campaign for Fairer Gambling. The “EU alerts” framing comes from the coverage, not from an EU institution.
Does “unregulated” mean illegal?
Not necessarily in the criminal sense. The measure is activity happening outside the local regulatory framework, which can include operators licensed in another jurisdiction serving players without a local licence.
What is the single most telling figure?
Not the 72%. It is the 91%: among people actively engaging with online betting, that share of the gambling content they encountered promoted unregulated operators. The market share follows the marketing share.
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