Unregulated online gambling generated an estimated €91.6 billion from consumers across the EU’s 27 member states in 2025. That figure comes from a new report by Gaming Compliance International (GCI), commissioned by the Campaign for Fairer Gambling (CFG). GCI calculates that this represents 72% of an online market worth €128.0 billion. For gambling affiliates, however, some of the findings behind that headline figure are more relevant. The report also adds new fuel to the debate over the true size of Europe’s black market.
Among those findings is a count of 17,501 affiliates promoting unregulated operators in 2025. GCI also estimates that 91% of the content encountered by actively engaged consumers promoted the unregulated sector. Yet other research produces much lower estimates for the illegal share of the market. This article of QMRA examines what GCI measured, why its figures differ from other black market estimates and what the findings mean for gambling affiliates and their compliance.
What the GCI report actually measures
GCI published Online Gambling 2024-2025: EU 27 Europe in September 2026. The report covers online casino and sports betting, including poker. It does not include lotteries, prediction markets, social casinos or land-based gambling.
One important point is how GCI defines the word “unregulated”. An operator only falls into this category when it actively targets consumers in a jurisdiction and transacts with them there. It must also operate without a licence issued by that jurisdiction. Simply being able to visit a website is therefore not enough. If consumers cannot place bets or make payments, GCI does not count the site as unregulated.
Operators can still fall within the definition when they hold a licence in another jurisdiction. The report identifies Anjouan, Curaçao, the Isle of Man and Malta as transnational licensing jurisdictions. Malta occupies a particular position because it is both an EU member state and a transnational licensor. GCI argues that holding one of these licences does not give an operator the right to generate revenue in an EU country without the required local licence.
Unregulated online gambling by region and product
The headline figure is only one part of the report. GCI also divides the market by year, region and gambling product. Its estimated unregulated share increased from 67% in 2023 to 71% in 2024 and reached 72% in 2025. Over those two years, estimated unregulated revenue climbed from €52.6 billion to €91.6 billion. That represents an increase of 74%.
| Region (EU 27) | Regulated GGR 2025 | Unregulated GGR 2025 | Unregulated share |
|---|---|---|---|
| Northern Europe | €5.0bn | €6.9bn | 58% |
| Southern Europe | €11.3bn | €17.1bn | 60% |
| Eastern Europe | €7.0bn | €30.7bn | 81% |
| Western Europe | €13.2bn | €36.9bn | 74% |
| EU 27 total | €36.5bn | €91.6bn | 72% |
The type of gambling makes a difference as well. Across the EU 27, GCI estimates that 75% of casino revenue comes from the unregulated market. For sports betting, it puts the figure at 59%. The report also estimates €22.0 billion in lost tax revenue, using an average GGR tax rate of 24%.
Why other black market estimates are far lower
GCI’s 72% estimate is considerably higher than other published figures for Europe’s black market. Research carried out by Regulus Partners and Helios for Euromat estimates the illegal online market in Europe at €12 billion, equal to a 25% share. H2 Gambling Capital arrives at roughly €18 billion, or 27%.
Figures from individual countries also produce lower estimates. Germany’s regulator calculated unlicensed revenue of €547 million in 2024. In the Netherlands, the regulator reported €617 million for the first half of 2025. The European Gaming and Betting Association (EGBA) therefore places GCI’s findings at the upper end of a broad range of estimates.
Methodology explains much of this difference. GCI converts web traffic and audience activity into revenue by applying a “value per visit” benchmark. The UK Gambling Commission has pointed to broader limitations in traffic-based methods, including gaps in data about app use. There is also a large difference in the estimated size of the overall market. GCI calculates a total online market of €128.0 billion for the EU 27 alone. EGBA and H2 data, in comparison, indicate a figure of about €48 billion for Europe’s entire online gambling market in 2024, including the UK.
GCI says it uses the lower end of the range produced by its model. The organisation also invites critics to test its methodology. Despite disagreement over the size of the market, there is broader agreement about the underlying trend. EGBA describes illegal gambling activity as substantial and growing, while still questioning the black market figure presented in the GCI report.
Where gambling affiliates appear in the data
GCI places affiliates among the “ecosystem essentials” on which unregulated operators rely. The same category includes social media, payment services, search engines, apps and streaming platforms. For gambling affiliates active in regulated markets, this part of the report deserves particular attention because it places affiliate marketing directly within the wider enforcement debate.
17,501 affiliates promoting unregulated operators
For 2025, GCI identifies 6,238 unregulated operators actively targeting consumers in the EU 27. It also counts 17,501 affiliates promoting those operators. A year earlier, the corresponding figures were 6,220 operators and 20,632 affiliates. GCI counts every mirror and redirect domain as a separate operator result, so the total does not represent 6,238 individual companies. The methodological notes explain this approach for operators in detail, but provide less information about how the affiliate total was calculated.
Audience exposure and self-exclusion avoidance
The report’s 91% figure refers to what GCI describes as audience exposure. This measure looks at consumers who do more than simply see gambling content and instead actively interact with it. Clicking an advertisement or registering with a gambling site are two examples. Affiliate content forms part of this combined measure alongside the other channels examined by GCI.
One type of affiliate content receives specific attention in the report: pages aimed at people looking to avoid self-exclusion systems. GCI cites “Casinos Not on CRUKS” in the Netherlands and “Casinos Not on ROFUS” in Denmark as examples. The report also warns that people who have self-excluded may find that unregulated operators are the only gambling sites still accessible to them.
Streaming and cloaked advertising
GCI also examines gambling content on the streaming platform Kick. Six EU countries officially block the platform’s slots category, yet the report found that the restriction worked effectively only in Greece. At the time of GCI’s review, users in most EU jurisdictions could still access unregulated gambling content and affiliate links through Kick. The researchers also examined brokers selling cloaked advertising, where paid advertisements are disguised to get through platform checks. More than half of those brokers were based within the EU 27.
Reading black market figures with care
The 72% estimate for unregulated online gambling needs context when it is cited. That applies to gambling affiliates writing about the size of the market as much as it does to other industry participants. Three points in particular affect how the figure should be read.
First, a campaign organisation commissioned the research. The report states that Derek Webb LLC funds the Campaign for Fairer Gambling. Second, GCI’s definition of “unregulated” includes operators that may hold a licence in Malta or another jurisdiction. The label therefore does not correspond exactly with every country’s legal definition of illegal gambling. Third, GCI relies on traffic and audience modelling to estimate revenue, a method that other researchers approach with some caution.
The broader argument behind the report nevertheless has support across the sector. Blocking one website has limited effect when an operator can move to another domain within days. EGBA board member Borut Petek told iGaming Business that enforcement increasingly needs to focus on the infrastructure supporting the black market. He specifically identified payments, affiliates, advertising platforms and technology suppliers.
What unregulated online gambling means for affiliate compliance
CFG founder Derek Webb has taken the argument further by calling for affiliates themselves to be licensed. There is no EU-wide licensing system for gambling affiliates today because gambling regulation remains largely a national responsibility. The report does, however, reflect a broader development within the sector. Regulators and other organisations increasingly discuss gambling affiliates as part of enforcement rather than viewing them only as a marketing channel.
Independent certification approaches the same compliance risk from another direction. QMRA assesses affiliates against codes written for individual gambling markets. Under the QMRA code for Sweden, for example, affiliates may not promote an operator that lacks a Swedish licence. They must also make the licence status of every operator clear. For the Italian market, QMRA checks whether every promoted operator holds an ADM licence covering the exact domain being advertised.
Content designed to avoid self-exclusion systems is one area where the black market and affiliate compliance meet directly. The Swedish code, for example, prohibits affiliates from encouraging self-excluded people to gamble. The business model behind affiliate marketing is explained further in Gambling Affiliation: How does it work?. A closer look at the unlicensed market in one country is available in Illegal Casino Italy: Risks and Explanation. Standards covering all markets can be found on the QMRA homepage.
Frequently asked questions about unregulated online gambling
These are the questions gambling affiliates are most likely to have about the report and its findings.
How much of the EU market is unregulated online gambling?
GCI estimates that unregulated operators generated €91.6 billion from an EU online market worth €128.0 billion in 2025, giving them a 72% share. Other studies of the black market arrive at much lower figures, with estimates of roughly 25% to 27%.
Does unregulated online gambling mean illegal gambling?
Not necessarily. GCI classifies operators as “unregulated” when they target and transact with consumers in a country without holding a licence there. This category can include operators licensed in Malta, Curaçao, the Isle of Man or Anjouan. National law ultimately determines whether their activity is illegal.
How many gambling affiliates promote unregulated operators?
GCI identified 17,501 gambling affiliates promoting unregulated operators across the EU 27 in 2025. The corresponding figure for 2024 was 20,632.
What does audience exposure mean in the report?
Audience exposure refers to the content consumers encounter after actively interacting with online gambling. The measure covers affiliates, advertising, social media, search and other channels. GCI found that 91% of this content promoted the unregulated sector in 2025.
Who commissioned the report?
The Campaign for Fairer Gambling commissioned Gaming Compliance International to produce the report. The report states that Derek Webb LLC funds the campaign.
