Fairer Gambling report puts EU illegal betting market at €91.6bn

A report commissioned by the Campaign for Fairer Gambling claims unregulated operators generated €91.6 billion in gross gambling revenue across the EU's 27 member states in 2025, dwarfing the €36.5 billion attributed to licensed operators over the same period.

On that basis, unlicensed activity would make up 72% of a €128 billion EU online gambling market, according to the analysis, carried out by Gaming Compliance International (GCI) on behalf of the campaign group.

GCI president Ismail Vali said the work was designed to move beyond partial datasets and individual operator snapshots that have previously characterised black market estimates. "We are putting a quantified value on the total marketplace, using the same methodology across regulated and unregulated activity," he said, adding that the firm had opted to publish the lower end of its modelled range rather than the upper end. "What we are looking to do is to get to this point: you are all being stolen from," Vali said.

The figure sits well above other recent estimates. A Regulus Partners and Helios study produced for Euromat this month put Europe's illegal online market at €12 billion, equivalent to 25% of the total, while H2 Gambling Capital has estimated the illegal share at roughly €18 billion, or 27%.

National regulators have published smaller figures still: PwC has estimated France's illegal market at €2 billion, Germany's regulator recorded €547 million in unlicensed revenue for 2024, and the Dutch regulator put the figure at €617 million for the first six months of 2025.

The European Gaming and Betting Association (EGBA), which represents EU-licensed operators, said GCI's number sits at the upper end of a field of widely differing studies. "Illegal gambling is hard to measure by its nature, which is why there have been so many studies about it, with widely varying results," an EGBA spokesperson said, noting that other research points to illegal activity accounting for around a quarter of online revenue.

Much of the gap stems from how GCI builds its figures. The firm converts web traffic and audience data into revenue through what it calls a value-per-visit benchmark, combining human analysis with machine learning, AI and third-party monitoring. The UK Gambling Commission has previously flagged limitations in traffic-based approaches generally, including their inability to capture activity through illegal operators' apps.

GCI's estimate of the total EU online market, at €128 billion, also diverges sharply from EGBA and H2 figures suggesting online gambling made up 39% of Europe's €123.4 billion gambling market in 2024 — around €48 billion, a total that includes the UK, unlike GCI's EU-only figures.

A GCI spokesperson said the report should be assessed on its evidence rather than dismissed on the basis of who produced it. "Anyone who believes €91.6 billion is wrong should test the methodology, produce a competing total-marketplace analysis, and show where the difference comes from," the spokesperson said.

Despite the gap between estimates, there is little disagreement that the problem is worsening. "Illegal activity is substantial and growing, and for us it is the biggest challenge facing the sector today," the EGBA spokesperson added. Carl Brincat, senior director of legal and regulatory affairs at LeoVegas, said any single figure should be treated with caution given the hidden nature of illegal activity, "although the underlying trend it describes is real."

Campaign for Fairer Gambling founder Derek Webb argued that the core failure lies in enforcement, not measurement. "We should have the philosophy that governments need to be capable of reacting to change at precisely the moment when the need to do things is accelerating because of innovations in social media, AI and crypto," he said, calling for action against the wider commercial infrastructure — affiliates, advertising networks, payment processors, app stores, search engines and streaming platforms — that the report says sustains illegal operators.

"We need to attack the companies that are enabling this and making money from it," Webb said. Campaign adviser Kieran O'Keefe said the report sets out each part of that supporting ecosystem in detail.

The dispute is already spilling into the courts. In the Netherlands, gambling trade body VNLOK has launched legal action against Meta over its continued hosting of illegal gambling adverts on its social platforms, which it says persisted even after being formally flagged.