The European Gaming and Betting Association has called on the European Commission to take coordinated action against online gambling fraud, submitting evidence that illegal operators generated an estimated €18bn in gross gaming revenue across Europe in 2025 — roughly 27% of the continent’s total online gambling market.
The submission was made in response to the Commission’s call for evidence ahead of its forthcoming Action Plan on Fighting Online Fraud, a cross-sector initiative aimed at suppressing online fraud and strengthening enforcement cooperation across EU member states. Adoption of the Action Plan is expected to begin in Q2 2026.
What the Evidence Reveals
The EGBA submission documents a range of methods through which fraudsters exploit licensed gambling brands to deceive consumers. Illegitimate websites frequently use domain names designed to mimic those of licensed operators, while illegal gambling apps have been found on both the Google Play Store and Apple App Store. The trade body’s evidence includes examples of brands operated by Flutter Entertainment’s tombola being impersonated and offered to European customers.
Phishing campaigns that imitate licensed brands were also highlighted, alongside social media advertisements that steer users towards non-EU-based real-money apps disguised as games. Some operators outside the EU falsely claim to hold EU gambling licences and present their gambling products as legitimate games, leaving players exposed to potential identity theft, loss of deposited funds, and gambling-related harm in the absence of self-exclusion systems.
A recurring feature identified by EGBA member testimonies is the speed with which fraudulent domains and apps reappear after being shut down — a pattern that demonstrates the limits of existing monitoring and enforcement frameworks relying on national responses alone.
Fragmented National Enforcement: Why It Falls Short
The EGBA argued that uncoordinated national approaches cannot keep pace with the cross-border nature and operational agility of fraudulent gambling networks. A domain taken down in one jurisdiction can reappear under a variant URL targeting consumers in another within days. Apps removed from one national version of an app store continue circulating elsewhere.
Dr. Ekaterina Hartmann, director of legal and regulatory affairs at EGBA, led the collection and submission of the evidence. She described the problem in direct terms:
“The evidence we’ve gathered shows how fraudsters are systematically exploiting the trust consumers place in the licensed gambling environment, putting European consumers at risk and allowing the illegal online gambling market to grow. From fake websites and fraudulent apps to phishing campaigns and social media scams, these threats reappear as quickly as they’re taken down. Fragmented national approaches to these types of fraud are not enough — we need coordinated EU-level action to ensure consumers and legitimate operators aren’t left fighting an uphill battle against fraud.”
The EGBA’s call echoes positions taken by European regulators in recent months. In October, the chair of the Netherlands Authority for the Gambling Market urged regulators to join forces internationally to tackle a black market that was, in the chair’s words, showing fewer and fewer geographical and ethical boundaries. That call came amid a broader cross-border enforcement discussion that saw seven European gambling regulators convene in Madrid to address the structural gaps in cross-border oversight.
The Scale of the Illegal Market
The €18bn figure cited by EGBA represents illegal operators’ estimated GGR in 2025, accounting for approximately 27% of Europe’s total online gambling market. That share has grown as regulatory tightening in several EU markets — including restrictions on advertising, deposit limits, and product constraints — has pushed channelisation rates downward in some countries.
The problem is not uniform across the continent. In Germany, research from the University of Leipzig estimated a channelisation rate of just 50.7% to legal online operators in 2023, with a substantial portion of online revenue flowing to unlicensed platforms. The German Sports Betting Association has previously warned of accelerating black market growth, linking it directly to product and marketing restrictions that reduce the competitiveness of licensed offerings.
The Dutch market presents a parallel concern. The Netherlands, which launched its regulated online gambling market in 2021, saw its GGR channelisation rate drop below 50% in the first half of 2025 — a sign that a substantial segment of player activity is migrating to unlicensed platforms. The Dutch regulator recently raised concerns about shifting social attitudes towards gambling, a dynamic that intersects with the enforcement challenge EGBA is highlighting at the EU level.
App Store Distribution: An Unresolved Gap
One component of the EGBA evidence that merits specific attention is the distribution of unlicensed gambling apps through major app store platforms. The submission includes evidence from the Spanish version of the App Store showing a range of gaming apps that, according to the EGBA, are not licensed by Spain’s DGOJ regulatory body. The trade body stated it is uncertain whether the apps in question involve real-money gaming but was explicit that none carry DGOJ authorisation.
This distribution vector is difficult to address at the national level. App stores operate globally, content moderation is handled by private platform operators rather than gambling regulators, and enforcement actions against individual app listings do not prevent rapid reappearance under variant names. EGBA’s submission argues this gap requires the EU’s Action Plan to extend to platform liability and cross-border takedown cooperation.
Context: EGBA’s Broader Regulatory Push
The fraud submission is part of a wider EGBA effort to engage EU institutions on gambling regulation. The Brussels-based trade body represents the leading licensed and regulated online gambling operators within the EU, whose collective membership holds 321 online gambling licences and serves more than 30 million customers across 21 European countries. Tipico, Germany’s leading sports betting operator, joined as the association’s latest member in January 2026.
EGBA has consistently argued that a more harmonised EU-level regulatory framework would reduce the black market by creating clearer and more consistent rules for licensed operators. The Action Plan on Fighting Online Fraud represents a near-term opportunity for the Commission to take concrete steps on a specific and well-documented subset of the problem. Whether Q2 2026 adoption translates into meaningful enforcement mechanisms — rather than aspirational guidance — will be the test that matters for both operators and consumers.
Source: European Gaming and Betting Association (EGBA)
