sector . But local trade body Deutscher Online Casinoverband ( DOCV ) argued the figure was closer to 20 % of the online market , as the GGL had calculated the revenue as a percentage of both retail and online GGR in the country . difficult to gauge the extent of the black market because of the tactics operators employ .”
Ismail Vali , founder of Yield Sec , a technology platform that uses AI and machine learning to scrape illegal gambling player data , is convinced that regulator estimates will not present a clear picture of the offshore market until it includes real-time data on player activity .
The UKGC ’ s 2025 black market report uses various methods to gather its data , including combining web traffic data and gambling behaviour data to estimate the gross gambling yield ( GGY ) of the online unlicensed market . However , there are concerns over its accuracy : the data was collected between July 2018 and June 2019 .
“ That ’ s the year before Yield Sec data started ,” Vali notes , adding that at the time the UKGC did not want to work with the company . “ We use an apples-toapples methodology across legal and illegal sites so we know what players were on which websites and how long they spent there . And we can work out what we call a value per visit [ across both legal and illegal domains ]. We have found that much more reliable than working from gross gaming revenue [ GGR ].”
One argument in favour of consistent methods across all reports is to stop governments and regulators overestimating channelisation rates , which Hoffstedt says is often done to present the image of a healthy and thriving legal market . “ There ’ s a general view that reports are mostly speculation and assessments from governments and authorities tend to assess channelisation at a higher rate compared to the industry .”
One interesting example is the Netherlands , where in a recent market report regulator Kansspelautoriteit ( KSA ) estimated the country has a 95 % channelisation rate , thanks in part to strict rules around advertising . But data on player spend and GGR made by illegal sites suggested the rate was closer to 87 % as players on average spend more money on illegal sites than on licensed sites . Despite the discrepancy in the data , the KSA chose to publicise the higher rate , which was based on estimates from Nielsen-owned market research company GfK and H2 Gambling Capital . H2 uses an in-house industry forecasting model to determine the size of legal markets rather than illegal ones .
Likewise , in an update on Germany ’ s regulated market last June gambling regulator Gemeinsame Glücksspielbehörde der Länder ( GGL ) put the value of the illegal market at € 600 million , or just 4 % of the overall
MONOPOLY SUPPORT
While channelisation has long been on the radar of private operators , BOS ’ Hoffstedt has seen monopoly operators take more of an interest . In ATG ’ s black market report in March it flagged that local payment identification measure Bank ID was available to illegal operators . This , CEO Hasse Lord Skarplöth said , should be stopped by banks in Sweden .
“ It ’ s definitely a benefit that legacy operators have joined in on this advocacy against the illegal market ,” he says of ATG ’ s report . “ They have a big market share in many European jurisdictions and probably also connections to the government that private operators don ’ t have .”
Monopoly operators have been hit hard by growing competition in their respective markets . In Finland the Veikkaus monopoly saw profits plummet 19 % in H1 2024 in what is one of Europe ’ s remaining grey markets . But the jurisdiction submitted its new gambling laws to the European Commission for review in November and is on the way to liberalising its online gambling market by January 2026 .
IS ENFORCEMENT AGAINST THE BLACK MARKET WORKING ?
Newly reformed markets like Finland and Ireland , which passed its Gambling Regulation Bill into law in October , can formulate and enact regulations to challenge the black market before the market matures and a shift in rules harms already established local operations .
ICE 2025 • ISSUE 137 • 31