Redefining “Reasonable”: How iGaming Operators Are Rewriting Strategy Under Europe’s New Rules

New rules, new operating strategies

In the Netherlands, the KSA’s September 2025 announcement set out licensing-policy changes taking effect on 1 January 2026. Applicants must provide an exit plan, an AML risk assessment under the Wwft and a plan for notifying important operational changes. Failure to comply with qualifying Dutch court judgments can count against an applicant’s reliability. Existing operators seeking a successor licence face renewed assessment, including of their addiction-prevention and advertising policies. This is an application for a new licence, rather than an automatic extension.

In Great Britain, some reforms were already binding by December 2025 while others remained under development. The online slot stake limit became £5 for adults on 9 April 2025, with a £2 limit for 18–24-year-olds from 21 May. Light-touch financial-vulnerability checks began in August 2024; separate enhanced financial-risk assessments were still being piloted during 2025. Treating the white paper, a pilot and an implemented licence condition as interchangeable obscures what operators actually had to do.

Italy’s Legislative Decree 41/2024, Article 6, provides for remote-gambling concessions lasting up to nine years, without renewal, and a €7 million one-off payment for each concession. That entry cost gives scale a clear role in a business case. Whether it produces consolidation or a shift towards supplying other operators is a commercial question, rather than an outcome established by the legislation alone.

Turning obligations into workflows: AI and regtech

Automation can help prioritise alerts and make case records more consistent. That is a practical use case, not proof that an AI-labelled product reduces gambling harm or satisfies every national obligation.

The Gambling Commission’s remote customer-interaction rules illustrate the distinction. They require operators to identify risks, take timely action and evaluate the results. Strong indicators must trigger automated processes, with manual review in each customer’s case and an opportunity to contest an automated decision. Responsibility remains with the licensee when a supplier performs part of the work.

For procurement, the useful questions are specific. Which risks can the system detect? What does it miss? Who reviews a flag? How quickly can staff intervene? Can the operator show whether its response helped? A tool that produces more alerts without improving those decisions may add workload rather than protection.

Channelisation: the importance of the denominator

Sweden’s regulator estimated channelisation at 85% for 2024 in the competitive gambling market, compared with 86% for 2023. Its separate estimate that 96% of players used licensed operators measures something different. A person can use both licensed and unlicensed services; a player percentage is not a revenue percentage.

A 2025 peer-reviewed study by Marionneau and colleagues analysed taxation and estimated channelisation across 29 European countries, using 2018 and 2021 cross-sections. It found no evidence of a negative correlation between tax rates and channelisation. The study does not demonstrate that higher taxes or restrictions on products and advertising necessarily push play offshore. Its observational design and estimated market data also limit causal conclusions.

For an operator or policymaker, the implication is to scrutinise the measure before using it. A revenue estimate, a traffic count and a survey of players answer different questions. Their coverage, year, assumptions and uncertainty should be visible. They cannot simply be combined into a single European black-market total.

Financial and strategic consequences

Tax changes are one identifiable pressure on a market-level business case. At Budget 2025, the UK government announced an increase in Remote Gaming Duty from 21% to 40% from April 2026, and a separate 25% remote-betting rate from April 2027, with specified exceptions including UK horse racing. At this article’s original publication, these were announced future changes.

Alongside entry fees, staffing and platform costs, such changes can alter the return an operator expects from a jurisdiction. They do not establish that every business will withdraw, consolidate or pass costs to players. Those responses depend on its product mix, scale and commercial choices.

A useful strategy review separates the cost of entering a market from the cost of serving it responsibly over time. It also asks what happens if a licence ends: how player funds are returned, how records are retained lawfully and how the business stops accepting new play. The Dutch exit-plan requirement makes that last question particularly concrete.

Growth opportunities in other regions require the same jurisdiction-by-jurisdiction calculation. Licensing, tax bases, enforcement and player-protection obligations differ. A headline tax rate alone is a poor basis for deciding where to allocate capital.

What “reasonable” means in practice

Industry associations, operators, researchers and regulators have different perspectives on the balance between commercial viability and protection. Arguments about channelisation deserve examination, but a stakeholder’s preferred policy should not be presented as an independently established finding.

For management teams, the practical task is to connect each applicable obligation to a working process: who is responsible, what evidence is retained and how effectiveness is reviewed. Capital allocation, product design and compliance then become parts of the same decision.

For policymakers, the corresponding challenge is to evaluate both consumer outcomes and the licensed market’s reach. Neither a growing compliance budget nor a high channelisation estimate is sufficient evidence, on its own, that harm is being reduced.