Facts on regulation
The Catalyst Years — What Drove the Regulatory Shift?
How geopolitics, financial risk, digital migration, and public opinion redefined compliance and competition for the world’s online gambling markets.
Intro
Since 2020, the global iGaming industry has undergone a profound regulatory transformation. A convergence of pressures—geopolitical crises, financial crime crackdowns, mounting research on gambling harms, rapid technological advancements, and high-profile policy debates—has turned “reasonable measures” from abstract guidelines into detailed, enforceable obligations. These five forces, amplified by growing political and public concern, have redrawn the map for market access, compliance requirements, and competitive risk across licensed gambling jurisdictions worldwide.
Digital dice and a world map: The global landscape of iGaming regulation (2020–2025), where compliance and risk are now as strategic as innovation.
In this evolving environment, compliance has become as strategic as product innovation—shaping which operators can participate, how player protection is defined, and whether the sector’s legitimate future will be secured or undermined by growth in the unlicensed market.
RESEARCH PERSPECTIVE
“We have seen legal compliance move from a box-ticking exercise to the central strategic challenge for every gaming business with international ambitions.”
— Dr. James Noyes, gambling regulation researcher (City, University of London)
The leap to digital: Technology, mobile connectivity, and new social behaviors have reshaped participation, risk, and regulation in global gambling markets.
Setting the Scene: The Digital Surge and Regulatory Lag
The global gaming boom accelerated dramatically after 2020. Pandemic restrictions, mobile technology advancements, and cross-border marketing pushed participation online at unprecedented rates. With this growth came significant regulatory challenges: money laundering risks, fraud, and the normalization of gambling among new demographics—particularly younger populations.
Regulation, which had lagged behind technological innovation, has now begun catching up, establishing mandatory, auditable standards for “reasonable measures” across nearly every major gambling market. Yet as global revenues surged, soaring compliance and regulatory costs fundamentally reshaped operator strategies—a financial paradox this series explores in depth, with Article 3 in this series detailing the true cost of transformation and its impact on competitiveness across international markets.
Five Major Drivers of Regulatory Transformation
1. Geopolitical Upheaval and Sanctions
The Ukraine conflict and expanded international sanctions forced regulators to reassess cross-border risks. Sweden’s Lag (2025:327), implementing the EU’s June 2025 sanctions directive, exemplifies this shift—criminalizing not only direct sanctions breaches but also circumvention attempts via VPNs or proxies. The law mandates automated screening systems, immediate incident reporting, documented staff training, and transparent escalation workflows.
2. Financial Crime and AML
Record-breaking fines and new anti-money laundering directives—including EU AMLD V/VI (the Fifth and Sixth Anti-Money Laundering Directives )., UK Gambling Act reforms, and enforcement actions in Germany and the Netherlands—have transformed Know Your Customer (KYC) processes, continuous monitoring, and instant escalation of suspicious activity from recommended practices into mandatory requirements for all operators.
3. Public Health Evidence
Major studies—particularly the GambleAware/Ipsos international comparison—have linked widespread gambling marketing and rapid digitalization to increased consumer harm. These findings have prompted regulatory responses similar to those implemented for alcohol, tobacco, and foods high in fat, salt, and sugar.
4. Technology and Digital Play
Artificial intelligence, mobile applications, and global payment platforms have created new opportunities for both regulatory compliance and circumvention. Operators and regulators now deploy real-time risk scoring, player behavior monitoring, and advanced anti-circumvention technologies, though innovation frequently outpaces enforcement capabilities.
5. Channelisation and Taxation
Rising taxes, increased compliance costs, and stricter player protection measures have, in some markets, driven portions of the player base to unlicensed operators. In 2025, for the first time, unlicensed gambling revenue in the Netherlands surpassed that of the licensed market—a channelisation crisis now prompting urgent policy review and reform.
Public sentiment in the spotlight—how advocacy, ratings, and debate shape gambling regulation through the lens of social will.
Setting the Scene: The Digital Surge and Regulatory Lag
The global gaming boom accelerated dramatically after 2020. Pandemic restrictions, mobile technology advancements, and cross-border marketing pushed participation online at unprecedented rates.
With this growth came significant regulatory challenges: money laundering risks, fraud, and the normalization of gambling among new demographics—particularly younger populations.
Regulation, which had lagged behind technological innovation, has now begun catching up, establishing mandatory, auditable standards for “reasonable measures” across nearly every major gambling market. Yet as global revenues surged, soaring compliance and regulatory costs fundamentally reshaped operator strategies—a financial paradox this series explores in depth, with Article 3 in this series detailing the true cost of transformation and its impact on competitiveness across international markets.
RESEARCH PERSPECTIVE
“In each of these countries, regulating gambling marketing was a political choice… a public health argument was made that increased consumption had led to, or would lead to, increased harm, and gambling was being normalised for children and young people, so there should be limits.”
— Ipsos/University of Bristol for GambleAware, 2024
Comparative research also shows similar reform cycles in markets for alcohol, tobacco, and unhealthy foods: scientific consensus is a trigger, but new regulation requires policymakers and the public to judge the risks as unacceptable. Recent UK polling supports this dynamic, with more than two-thirds of adults now backing tighter gambling advertising rules ([Ipsos, 2024]), underlining how regulatory change aligns with shifts in public opinion.
Market Analogy: Regulation’s Familiar Cycle
The evolution of gambling regulation closely mirrors patterns seen in alcohol, tobacco, and more recently, cryptocurrency markets: liberalization leads to rapid expansion, rising harms follow, public debate intensifies, and governments implement stricter controls.
Digital technology accelerates this entire cycle, simultaneously enabling innovation, enhancing enforcement capabilities, and creating new circumvention opportunities that keep regulators and unlicensed operators in constant competition.
2020–2025: Sweeping new laws, tougher enforcement, and rising standards have reshaped the legal map for every gambling market. Today, compliance is not an option—it’s a license to operate.
Major Laws and Regulatory Overhaul: 2020–2025
The years 2020 to 2025 saw sweeping regulatory reform across every major iGaming jurisdiction, each now defining “reasonable measures” with clear operational and legal standards:
Sweden (2025 – Lag 2025:327): Implements the EU June 2025 sanctions directive. Criminalizes breaches and circumvention (VPNs, proxies, false IDs). Mandates automated sanctions screening, documented staff training, rapid incident reporting, and transparent escalation. The approach is now studied by other EU regulators.
United Kingdom (2023 – Gambling Act Reforms): Prioritizes AML and player protection in the White Paper. Mandates KYC, technical audits, strict marketing rules, and real-time incident reporting. Substantial fines have elevated regulatory adherence to the board level.
European Union (2020–2025: AMLD V/VI, NIS2): Harmonized onboarding, risk controls, and sanctions monitoring. Mandatory cybersecurity requirements for all operators. Sets minimum standards but allows for stricter national rules.
Germany (2021–2023 – Glücksspielstaatsvertrag): State-driven enforcement replaces self-regulation. Requires ISP/payment blocking for unlicensed sites. Implements live transaction monitoring and regular technical audits.
Netherlands (2021–2024 – Remote Gambling Act): Strict licensing, extensive audits, and mandatory self-exclusion. Features rapid escalation protocols for suspicious activity. In 2025, unlicensed operator revenues surpassed licensed revenues (channelisation challenge).
Canada – Ontario (2022–2025 – Gaming Control Act): Continuous AML monitoring and proactive risk escalation. Mandates responsible gambling tools for all licensees.
Singapore (2022–2024 – Casino Control/Gambling Control Acts): Centralized licensing and strict AML/CTF standards. Implements technology-driven audits and mandatory player protection.
Africa (2022–2025 – National/State Codes): South Africa, Kenya, and Nigeria adopt digital onboarding (local ID KYC). Require regular due diligence and regulated advertising. “Leapfrogging” older compliance models.
United Arab Emirates (2025 – GCGRA Framework): Strictest Middle East regime; ISO 27001 required. Real-time risk monitoring and rigorous financial oversight.
Regional Snapshots
Sweden/EU: The 2025 sanctions law positions Sweden among the world’s strictest compliance jurisdictions.
UK/Netherlands: Multi-million euro/pound fines have driven industry-wide compliance upgrades.
Africa/Asia: Markets are leapfrogging legacy regulatory frameworks through digital onboarding and real-time verification systems.
UAE: Selective licensing underpinned by mandatory ISO 27001/NIS2 alignment.
INDUSTRY PERSPECTIVE
“Legal compliance is now at the core of the business model—it’s the price of access to regulated markets and sustainability as a brand”
— Industry CEO, European market press
The Cost of Transformation
Compliance technology and operational expenditures have reached unprecedented levels:
Operators increasingly invest in AI-powered KYC systems, transaction screening platforms, and VPN detection tools.
Technology budgets have grown by an estimated 15–20% across EU and North American markets since 2020.
ISO 27001, NIS2, and equivalent certifications require continuous external audits and comprehensive staff training programs, with annual compliance costs reaching millions of euros for mid-sized operators.
EU-wide AML compliance spending reached €7 billion in 2025, with iGaming representing a significant portion of this investment.
Many operators have exited high-risk markets, declined customers from specific jurisdictions, or pursued consolidation strategies, citing prohibitive costs and legal uncertainties.
Smaller firms experience disproportionate impact, with compliance costs consuming higher percentages of revenue and creating substantial barriers to market entry or expansion, while unlicensed and illicit activity continues to grow.
REGULATORY PERSPECTIVE
“There is no future for operators unwilling to commit to player protection and transparency—the public, press, and political demand for accountability has never been higher.”
— Regulator interview, UKGC/EGBA
Data, Privacy, and the Migration to Unlicensed Markets
Tighter AML and KYC requirements increasingly rely on extensive data collection, prompting renewed privacy and GDPR debates that pit regulator demands for comprehensive monitoring against advocacy for data minimization and internet freedom.
Simultaneously, escalating compliance burdens and regulatory friction are fueling growth in unlicensed gambling and cross-border player migration. In the Netherlands, grey-market turnover exceeded €450 million in 2025; in the UK, black market estimates exceed £2.5 billion annually. This tension among player protection, privacy rights, and competitive viability will intensify in the coming years.
Conclusion and Series Transition
The iGaming sector is negotiating a new social contract—one that grounds legitimacy in demonstrable, auditable compliance.
In an era of artificial intelligence, digital engagement, and global money flows, both operators and regulators face a constantly moving target: mitigating risk and harm while maintaining competitive viability and market legitimacy.
While “reasonable measures” now stands at the heart of every regulatory overhaul, the specifics of how these obligations have evolved—and what they require in daily operations—will be comprehensively explored in the next installment of this series.
Further Reading
Ipsos & University of Bristol / GambleAware (2024): Drivers of Gambling Marketing Restrictions – An International Comparison
UK Gambling Commission—Regulatory Updates and Guidance (2023–2025): Official White Paper, Rules, and Penalties
Published-Facts-on-Channelisation-in-Europe’s iGaming Market / Industry Case Studies and Analytics (2025)
EXPLORE ARTICLE SERIES
Redefining Reasonable: Regulatory Transformation in Global iGaming
Article 1 of 4 in a series exploring ”European gambling regualtion in focus”: The Catalyst Years – What Drove the Regulatory Shift?
Drawing on recent reforms, enforcement actions, and market data from Europe, North America, Asia, Africa, and the Middle East, the series traces what triggered the post‑2020 regulatory surge, how laws and guidance now define “reasonable” conduct, how operators have responded in practice, and which technologies and policy debates will shape the next generation of compliance, player protection, and channelisation.
Article series
REGULATION
Redefining Reasonable: Regulatory Transformation in Global iGaming – a four part series
Article one: THE CATALYST YEARS (2020 – 2025) WHAT DROVE THE REGULATORY SHIFT?
ARTICLE TWO: TO BE WRITTEN: HOW REGULATORS ARE REDEFINING THE MEANING OF “RESONABLE MEASSURES”
ARTICLE THREE: TO BE WRITTEN: THE OPERATOR RESPONSE—ADAPTION; COSTS AND MARKET OUTCOME
ARTICLE FOUR: TO BE WRITTEN: TECHNOLOGY, RESEARCH, AND THE NEXT “REASONABLE MEASURES”
