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Strengthening the Licensed Market: Shared Insights on Tackling the Black Market

27 November 2025

At the Sustainable Gambling Conference 2025, industry leaders and regulators examined why the unlicensed gambling market continues to grow across Europe and what is required to keep players within the licensed ecosystem. Their combined reflections highlighted both the scale of the challenge and the opportunities for coordinated action.

 

 

Panelists agreed that while several regulated markets perform comparatively well in terms of channelisation, warning signs are clear. Rapid shifts are placing pressure on established frameworks, and customers continue to gravitate toward experiences they perceive as smoother or more rewarding. In some jurisdictions, a large majority of players gamble exclusively with legal operators, yet a significant share of total spend still flows to unlicensed actors. This raises concerns not only about consumer protection but also about the invisibility and vulnerability of those engaging in the black market.

A recurring theme was the need to understand the wider ecosystem that sits between customers and products. Panel participants noted that players do not seek out unlicensed sites because they prefer illegal gambling, but because they seek engaging, friction-free experiences. If regulated environments become too restrictive or fragmented, customers will inevitably look elsewhere. Several participants pointed out that regulatory changes often lack sufficient consultation with licensed operators, making it difficult to anticipate how consumers may respond.

The regulatory paradox featured prominently: increased rules on the regulated web often strengthen highly adaptive illegal operators. Regulators described a landscape where they are bound by strict rules while facing actors who operate anonymously, rapidly, and largely without constraint—often aided by mainstream digital platforms.

Collaboration with banks, payment providers, and technology companies was identified as essential to disconnect illegal operators from their customers more effectively than traditional enforcement alone.

Panelists called for a more evidence-led, outcome-oriented approach to regulation—one that evaluates whether measures work, acknowledges when they do not, and avoids over-reliance on blanket rules.

Several underlined the need for deeper understanding of why and how players move toward the black market, and how the licensed sector can offer safer, more appealing customer experiences that meet consumer expectations without compromising protection.

Together, these insights reinforced a shared message: addressing the black market requires coordinated effort, honest dialogue, and a regulatory balance that protects players while keeping the licensed offer competitive and trusted.