CFG analysis reveals €91.6bn unregulated online gambling market across EU-27, with 72% of gross gaming revenue outside national regulatory perimeters

Executive summary: CFG published an EU-27 analysis showing 72% of online gambling GGR (€91.6bn) is unregulated, with 91% of consumer-facing content coming from unlicensed operators. The scale of the unregulated market undermines consumer safety, deprives member states of tax revenue, and creates an uneven playing field for licensed operators who bear compliance costs.

Who is involved: CFG (industry analyst), European Commission, national gambling regulators in 27 EU member states, licensed and unlicensed online gambling operators.

Likely next: Expect renewed calls for a harmonised EU enforcement framework, possible amendments to the Digital Services Act to cover gambling, and national regulators pursuing payment-blocking and ISP-blocking measures against unlicensed sites.

A new CFG study covering all 27 EU member states finds that nearly three-quarters of online gambling revenue evades local oversight, amounting to €91.6 billion in gross gaming revenue. The enforcement gap means consumer protections, tax collection, and anti-money-laundering controls are absent for the vast majority of the market. The report highlights that 91% of gambling content encountered by active consumers originates from unlicensed operators. These findings put pressure on the European Commission and national regulators to close cross-border enforcement loopholes.

What's next — scenarios

Base: EU-wide enforcement coordination within 12-18 months (55%)

Member states adopt a joint enforcement mechanism under the Gaming Regulators European Forum, reducing unregulated share to below 50% and recovering an estimated €15-20bn in taxable GGR.

European Commission publishes enforcement guidance by Q1 2027
At least 15 member states sign a multilateral cooperation agreement
Payment service providers receive mandatory blocking orders

Upside: Industry-led self-regulation and whitelisting (20%)

Major operators and platforms create a pan-European whitelist verified by an independent body, cutting unregulated GGR to 35% without new legislation.

EGBA and major operators announce a voluntary whitelist by end-2026
Google and Meta integrate whitelist into ad policies
National regulators endorse the scheme

Downside: Fragmentation persists, black market grows (25%)

Divergent national approaches and legal challenges stall EU action; unregulated share rises to 80% as operators exploit regulatory arbitrage, costing states €25bn+ in lost revenue annually.

Court rulings against national blocking measures in two major markets
Commission delays enforcement proposal beyond 2027
Unlicensed operators launch EU-targeted marketing campaigns

What to watch

European Commission communication on gambling enforcement (expected Q4 2026)
Gaming Regulators European Forum meeting minutes (next scheduled Nov 2026)
National regulator actions: payment-blocking orders in Germany, France, Italy
EGBA/industry association position paper on EU-wide licensing (due late 2026)
Court rulings on ISP/payment blocking in Netherlands and Sweden (H1 2027)

Timeline

2026-09-23 — CFG: EUROPE'S €91.6 BILLION UNREGULATED GAMBLING ECONOMY (PR Newswire)

Analysis — what this means

Likely next events

European Commission to issue enforcement guidance by Q1 2027
Gaming Regulators European Forum plenary in November 2026
German regulator (GGL) to publish first annual black-market estimate Dec 2026
French ANJ to test payment-blocking pilot with banks Q1 2027

Sectors affected

Online gambling operators (licensed and unlicensed)
Payment service providers and acquirers
Advertising platforms (Google, Meta, TikTok)
ISP and DNS providers subject to blocking orders

Regulatory implications

Potential amendment of Digital Services Act to include gambling-specific due-diligence obligations for very large online platforms
Revision of EU Anti-Money Laundering Directive to explicitly cover unlicensed gambling payment flows
Member states may introduce mandatory play on licensed domains only, enforced via ISP blocking

Historical parallels

EU payment blocking against unlicensed gambling in Belgium (2011) and Netherlands (2021)
Danish licensing regime (2012) reduced black market from 40% to under 10% within three years
UK Gambling Commission’s 2019 credit-card ban cut unlicensed play by an estimated 15%