EU black market gambling report puts unlicensed online operators at €91.6 billion in 2025

A new analysis commissioned by the Campaign for Fairer Gambling says unregulated operators accounted for €91.6 billion of gross gambling revenue in the EU’s 27 member states in 2025, versus €36.5 billion for regulated operators. For PSPs, acquirers, and banks, the number matters because it points to a market where enforcement gaps are not a side issue but the main operating condition.

1. The report, produced by Gaming Compliance International (GCI), puts the unregulated share of the EU online gambling market at 72% of the total €128 billion marketplace. That is materially above other recent estimates, so the debate is now less about whether black-market activity exists and more about how big the gap really is.
2. Ismail Vali, president of GCI, says the team combined specialist human analysis, machine learning and AI with marketplace monitoring, benchmarking, and increasingly extensive third-party data. He says the report deliberately publishes the lower end of its modelled range rather than the upper end. In other words, the methodology is meant to be conservative, not aggressive.
3. The report argues that the scale of the market reflects a systemic failure to police the digital gambling marketplace, not just offshore operators evading national regulators. That framing matters for payment providers because it shifts the conversation from isolated licensing issues to the infrastructure that allows unlicensed volume to keep flowing.
4. Other estimates are much lower. A Regulus Partners/Helios study for Euromat, published this month, puts Europe’s illegal online market at €12 billion, or 25%, while H2 Gambling Capital estimates it at about €18 billion, or 27%. National figures cited in the report also vary: PwC puts France’s illegal market at €2 billion, Germany’s regulator puts unlicensed revenue at €547m for 2024, and the Dutch regulator puts it at €617m for the first half of 2025.
5. The European Gaming and Betting Association (EGBA) says the report sits at the top of a wide range and notes that illegal gambling is hard to measure by its nature. That is the practical problem for PSPs and acquirers: the market is large, the measurements disagree, and everyone involved is still arguing over who should pay to fix enforcement.