European gaming stakeholders are alarmed at the extent of black market activity in the UK and the Netherlands, arguing that these illicit operations reduce tax revenue and require urgent attention from operators and regulators.
The European Gaming and Betting Association’s (EGBA) Sustainability Report 2025 contains testimonies from several of the continent’s biggest gaming groups, all of whom express concern about the extent of black market activity.
New spending caps introduced in the Netherlands have been specifically highlighted as a concern by EGBA. Like its neighbour across the North Sea (the UK), the Netherlands has been undertaking a regulatory review, and enhancement, lately.
In 2024 the country introduced new spending caps on gambling, largely due to concerns around the proliferation of gambling and its societal impact since online market launch back in October 2021.
This has led to what EGBA has called a surge in black market activity in the country which has led to unregulated sites matching the regulated market for revenue. Meanwhile, in the UK the trade association has cited figures that £2.7bn is being staked annually on the black market.
A statement signed by John Coates (Joint Group CEO, bet365), Stella David (CEO, Entain), Jesper Svensson (CEO, Betsson Operations), Peter Jackson (CEO, Flutter Entertainment), Nils Andén (Chief Online Betting and Gaming Officer, FDJ United) and Mattias Wedar (CEO, LeoVegas), and Jimmy Maymann (Co-CEO, SuperBet Group), attempted to hammer the point home.
“Yet while we continue to invest significantly in responsible play and compliance, unregulated, untaxed black market operators, based outside Europe, are thriving across the continent.
“These operators target vulnerable players with unlimited access and significant
bonuses, offer no customer protections or support for struggling players, and don’t contribute to public finances or European sports.
“They operate entirely beyond regulatory oversight, avoiding all costs and obligations, and face few repercussions.”
Hitting governments where it hurts
The black market argument is getting a bit old. That is not to say it’s not true, plenty of studies show that there is a huge proliferation of black market websites across Europe, and that many consumers struggle to tell the difference between the regulated and non-regulated.
The trouble is that the industry has been making the case about black market activity, particularly in response to potential regulatory developments – affordability checks in the UK being a good example of this. After years of hearing the argument there is the risk that governments and other policymakers may be rolling their eyes.
Taxation may be the key to this. Governments all across Europe value the gambling industry for its tax revenue contributions, and want to keep this stream open even if they have concerns about betting’s visibility or societal impact.
Alongside the usual concerns about the black market’s life of safeguards, in its latest report, EGBA highlighted that its members generated €3.8bn in both corporate and gaming tax to respective European governments.
The revenue being lost to the black market is not just being lost by operators, it is also being lost by the various national governments of Europe. EGBA asserts that in the UK, for example, £335m was lost in gaming tax to unregulated actors during 2024.
The CEOs letter stated: “In 2024, our companies paid €3.8bn in taxes to help fund public services, sustaining 62,000 jobs, and developing player support tools, now used voluntarily by 34% of players, and sent a record 100 million messages to our players to promote safer play.
“Our efforts are backed by dedicated teams working to support our customers every day, with 89% of our employees completing dedicated safer gambling training. We also invested €735m in the success of European sports last year, from grassroots to professional competitions.”
Aside from raising the black market argument, EGBA’s key members have reiterated a call for balanced regulation and coordinated action against the black market and standardisation of markers of harm at the European level.
This latter goal seems to have caught the attention of European authorities, with the project being worked on by the European Committee for Standardisation. EGBA will likely be hoping that its vocal statements about the black market will catch similar attention.
