Facts on regulation
Article series
European Gambling RegulationPart 4 of 4Start with Part 1: Balancing the Odds: British and Dutch Gambling Regulation
Navigating Channelisation and Unlicensed Play: What Data Reveals about Europe’s iGaming Landscape
A data-driven analysis of shifting player behaviors, regulatory strategies, and market challenges for legal and unlicensed online gambling in the UK, Netherlands, and beyond.
Keeping gambling within licensed markets requires more than counting blocked websites. Regulators need to understand where players go, how much they lose and whether protective measures reach those most at risk.
British and Dutch estimates, alongside enforcement examples from Denmark and Germany, show the limits of a single Europe-wide account of the black market. The figures use different definitions; the available legal tools also differ. This article examines the evidence available in October 2025, with a later Dutch statistical revision clearly identified.
VPN technology has legitimate privacy uses as well as potential uses in bypassing geographical restrictions. Its use alone does not identify unlicensed gambling.
The relevant questions are whether an operator is authorised for the market it serves and how unlicensed activity is measured. VPN adoption, website traffic, player counts and gambling revenue should not be used as interchangeable proxies.
Two markets, different measures
Great Britain
Frontier Economics’ 2024 study, commissioned by the Betting and Gaming Council, estimated £2.7 billion in annual online stakes with unregulated operators, approximately 2.1% of online stakes. This was a survey-and-customer-data estimate, not a regulator’s complete count.
The figure refers to money wagered, which can include repeated betting of winnings. It is not gross gambling revenue, profit or an estimate of player losses. It also cannot substantiate an unrelated range for the proportion of British players using licensed sites.
The Netherlands
In its autumn 2025 monitoring report, the Ksa estimated licensed online GGR of €600 million and unlicensed GGR of €617 million for January–June 2025. Its estimate at that time put the licensed share of GGR at 49%. These were half-year revenue estimates, not annual stakes.
A separate player measure found that approximately 94% of online players used only licensed operators. The 49% figure did not mean that only 49% of players used licensed sites. The two measures suggested that unlicensed activity was concentrated among a smaller group with relatively high losses.
Later revision: The Ksa subsequently revised the licensed GGR share for the first half of 2025 to 56%. The original estimate should not be presented as the current estimate for that period or as settled proof that unlicensed revenue exceeded licensed revenue.
Enforcement: Denmark and Germany
Denmark: court-ordered access blocking
On 26 June 2025, the Frederiksberg court approved blocking 178 websites offering gambling illegally to Danish consumers. The Danish Gambling Authority said this brought the total blocked since 2012 to 616. Its process uses DNS blocking through internet service providers and assesses whether an offer targets Denmark, including factors such as language and currency.
The count demonstrates enforcement activity. It does not, by itself, show how much gambling was prevented or explain subsequent changes in legal-market revenue.
Germany: limits on access-provider orders
In case 8 C 3.24, decided on 19 March 2025, Germany’s Federal Administrative Court addressed blocking orders under section 9(1), sentence 3, no. 5 of the 2021 Interstate Treaty. The provision’s reference to intermediary-liability rules sharply limited when ordinary internet access providers could be ordered to block gambling sites. The judgment did not impose a general prohibition on every form of blocking.
The GGL explained that it had already shifted attention towards hosting providers. In March 2025 it reported about 930 domains blocked or no longer accessible through that work, while warning that providers could change hosts and become reachable again.
Why someone chooses an unlicensed site needs to be investigated, rather than inferred from technology use or a change in aggregate revenue.
Understanding player behaviour
Frontier’s British research identified bonuses, anonymity and fewer restrictions among reported attractions of unregulated offers. Those findings describe the study’s respondents and methods; they do not establish that every unlicensed player has the same motivation.
Some consumers may knowingly seek unrestricted products. Others may struggle to identify which operators are licensed for their country. These are different problems, requiring different responses.
Questions for policy evaluation
- Can consumers readily identify a locally licensed operator?
- Do protective interventions reduce harmful losses, and among which groups?
- Do affected players stop, reduce their activity or move elsewhere?
- Do enforcement measures interrupt access or merely shift it to replacement domains?
These questions connect market monitoring with consumer outcomes. They cannot be answered by assuming that a lower tax rate or more advertising would necessarily produce a safer market.
The role of digital intermediaries
Search engines, advertising services, payment providers and hosting companies can influence whether consumers find and use an unlicensed operator. The German hosting-provider example illustrates one route for intervention, but legal responsibilities depend on the service and jurisdiction involved.
European coordination also needs precise terminology. TRIS supports the notification and examination of draft technical rules under Directive (EU) 2015/1535. It is not a harmonised European gambling-licensing framework.
Cooperation is useful when it produces measurable outcomes, such as fewer repeat appearances of an illegal offer. A large number of takedown requests is an activity measure, rather than proof of lower gambling harm.
Conclusion
Channelisation and enforcement data can reveal weaknesses in a regulated market, but only if their definitions and limitations remain visible. British stakes estimates, Dutch GGR estimates and counts of blocked domains answer different questions.
Effective evaluation combines those measures with evidence about player behaviour and protection. The objective is to understand which interventions work, for whom, and whether the benefits persist when unlicensed operators adapt.
KEEP THE METRICS SEPARATE
A player percentage, a revenue share and a blocked-domain count should never be presented as if they describe the same outcome.
Sources and further reading
- Frontier Economics: the scale of black-market gambling in Great Britain (2024 study).
- Kansspelautoriteit: autumn 2025 monitoring report.
- Kansspelautoriteit: explanation of revised 2025 estimates.
- Danish Gambling Authority: 178 websites blocked, 26 June 2025.
- Federal Administrative Court: judgment 8 C 3.24, 19 March 2025.
- GGL: consequences of the blocking judgment and hosting-provider enforcement, 20 March 2025.
- European Commission: Directive 2015/1535 notification procedure.
Correction — 14 October 2026: We removed unsupported VPN percentages and a British channelisation range; corrected the Dutch figures’ period and definitions, including the distinction between players and GGR; and added the Ksa’s later revision. We also clarified the German judgment and TRIS, removed an unverified quotation and withdrew unsupported claims about enforcement effectiveness. The analysis otherwise retains its October 2025 context.