The Catalyst Years — What Drove the Regulatory Shift?

Setting the Scene: The Digital Surge and Regulatory Lag

The shift online was already under way before the pandemic. The UK government's 2023 White Paper reported that online gambling, excluding National Lottery products, rose from 14.4% of British adults in the previous four weeks in 2018 to 18.6% in 2022. Over the same period, participation in land-based gambling fell.

That change altered the regulatory task. Mobile access, digital payments and detailed records of play created both risks and opportunities for intervention. The question became how existing protections should work when gambling was available at almost any time and place. Different governments answered it through different combinations of licensing, product rules, monitoring and enforcement.

Five Major Drivers of Regulatory Transformation

1. Geopolitical Upheaval and Sanctions

Sanctions enforcement became a more prominent part of cross-border business risk. Sweden's Act on International Sanctions (2025:327), effective from 10 June 2025, implements Directive (EU) 2024/1226 of 24 April 2024. The Act defines criminal offences and penalties for sanctions violations, including specified forms of circumvention. It does not prescribe a universal automated screening system or make VPN use, by itself, a sanctions offence.

2. Financial Crime and AML

Enforcement exposed failures in existing controls. In March 2023, three William Hill Group businesses agreed to pay £19.2 million in regulatory settlements for social responsibility and anti-money laundering failings. At EU level, the 2024 AML package introduced a new authority and a more harmonised rulebook. Adoption and application are different milestones: the new AML Regulation generally applies from 10 July 2027.

3. Public Health Evidence

A November 2024 study by Ipsos and the University of Bristol, commissioned by GambleAware, examined how six jurisdictions approached gambling marketing. It found that evidence about harm helped inform restrictions, but political decisions were central to whether reform happened. This was comparative policy research, not an experiment establishing one universal causal effect of digitalisation.

4. Technology and Digital Play

Digital supervision also became part of the regulatory infrastructure. In Germany, online operators must connect to supervisory systems that include cross-operator limit and activity files. Such systems show how a policy requirement can become a technical operating obligation. They do not, on their own, establish how effectively harm is prevented.

5. Channelisation and Taxation

Governments also face the question of how much activity remains within their licensed markets. The Dutch regulator's autumn 2025 monitoring report originally estimated that licensed operators accounted for 49% of online gross gaming revenue in the first half of 2025, although about 94% of online players gambled exclusively legally. These different measures should not be conflated. The report raised concerns about movement to illegal suppliers; it did not isolate taxation as the cause.

Later revision, April 2026: In its spring 2026 report (pp. 16–17), the Ksa revised the first-half 2025 licensed revenue share from 49% to 56% after correcting the search-volume data used to estimate the illegal market. The 49% figure above records the estimate available when this article was first published.

Public Opinion and Political Choice

The Ipsos and University of Bristol comparison found that research evidence alone did not determine whether governments restricted gambling marketing. Political willingness to act, commercial interests and judgements about acceptable harm also mattered.

Public opinion is one part of that debate. In an Ipsos survey published in June 2024, 74% supported more regulation of gambling advertising on social media and 72% supported more regulation on television. The survey covered 4,207 adults aged 18–75 in Great Britain, with fieldwork conducted in October 2023. These findings describe attitudes to specific advertising channels, rather than support for every proposed gambling restriction.

Market Analogy: Regulation's Familiar Cycle

The marketing study also compared gambling with debates over alcohol, tobacco and foods high in fat, salt and sugar. Those comparisons help explain the policy questions: how evidence is interpreted, which risks are judged unacceptable and how commercial freedoms are balanced against protection.

They do not establish that every market follows the same sequence. Gambling products, national institutions and enforcement capacity differ. A reform that is workable in one jurisdiction cannot simply be assumed to have the same effect elsewhere.

Major Regulatory Changes: Selected Examples, 2020–2025

The period brought several distinct kinds of change. These examples should not be read as a single global compliance checklist.

• Sweden, 2025: The new sanctions Act implemented the EU's April 2024 directive and took effect on 10 June 2025. Its central role is to define sanctions offences and penalties.
• Great Britain, 2023: The government's White Paper proposed reforms to gambling in the digital age. A White Paper sets out policy; the measures require their own legislative or regulatory implementation.
• European Union, 2024: The AML package established a new EU authority and a common regulation. The regulation's general application date is 10 July 2027. Separately, NIS2 covers specified sectors and entity types; it does not automatically apply to every gambling operator.
• Germany, 2021: The 2021 Interstate Treaty on Gambling made previously prohibited online products licensable under restrictive conditions and created a joint regulator. This was a change in the licensing framework, not a replacement of industry self-regulation alone.
• Netherlands, 2025: Monitoring distinguished the share of people using legal sites from the share of online gross gaming revenue captured by them. That distinction became central to the channelisation debate.
• Ontario, 2022: The regulated private-operator online market launched on 4 April. Operators needed AGCO registration and an operating agreement with iGaming Ontario, including standards for integrity and player protection.
• Singapore, 2022: The Gambling Control Act and Gambling Regulatory Authority Act took effect on 1 August. The new authority's remit covered the gambling landscape beyond casinos.
• United Arab Emirates, 2023: The GCGRA was established in September as a federal commercial gaming regulator. The establishment of a regulator should not be confused with proof of a universally applicable ISO certification requirement.

Data, Privacy, and the Migration to Unlicensed Markets

Customer checks and monitoring involve personal data. Under the GDPR's principles, organisations must have a lawful purpose, limit collection to what is necessary and protect the information they hold. Financial crime and player-protection requirements need to be implemented alongside those duties, not treated as a general exemption from them.

Market measurement requires similar care. The Dutch regulator reported €600 million in licensed online gross gaming revenue for the first half of 2025. Gross gaming revenue means stakes less prizes paid, not total money wagered. Its estimated licensed revenue share (subsequently revised, as noted above) and its player-based channelisation measure answer different questions; neither should be presented as an exact count of all illegal gambling.

The policy challenge is to assess protection and market participation together, while distinguishing observed changes from explanations that still need testing.

Conclusion and Series Transition

The regulatory changes of 2020–2025 did not create one worldwide model. They did make a recurring question more concrete: how can an operator show that the protections required in a particular market work in practice?

Legal duties, enforcement, research evidence and public expectations all inform the answer. The next article in this series examines how those duties are defined and what they require in day-to-day operations.