The Gaming Regulators European Forum (GREF) is comprised of gaming and betting authorities in some of Europe’s most active markets. The forum recently outlined a commonly agreed upon commitment on how they plan to address problem gambling across the continent.

A statement released by GREF detailed some of the ways members would work together through cross-border cooperation that includes coordinating “joint actions” against what it deems to be illegal gambling websites operating in Europe. Each country is free to use its own definition of “illegal gambling”.

Regular Meetings and Other Communications to Keep the Forum Cohesive

Other items outlined include the sharing of expertise, information, and best practices as well as setting up alerts so that all member states can be on the same page at the same time when an issue needs to be addressed. The team also stated that the various national regulatory bodies would hold regular meetings to keep each other apprised and in the loop.

None of the language we have seen addresses grey markets – jurisdictions where gambling operations are not allowed unless they are licensed locally or sometimes even by another EU member state, but players are free to choose where they play. However, some of the participants are indeed from countries most widely seen as grey markets.

With the advent of countries such as Germany, Ireland, the Netherlands, and the UK undertaking regulatory reform, Europen gambling industry participants have been bringing up the subject of the black market and outright illegal operators in some discussions.

The statement from GREF reads: “This joint action will enable us to better identify and minimize illegal gambling activities while acknowledging that each regulator remains free to define what amounts to illegal gambling and to use the enforcement tools provided by its own national regulatory framework.

“We expect that this common action will enable a constructive dialogue with online platforms, including social media platforms. We also expect that this common action will raise consumer awareness regarding the risks associated with illegal gambling.”

The Belgian Gambling Commission (BGC), l’Autorité Nationale des Jeux (ANJ) of France, Germany’s Gemeinsame Geschäftsstelle Glücksspiel (GGL), the Hellenic Gaming Commission (HGC) of Greece, Ireland’s Regulator of the National Lottery, and the Great Britain Gambling Commission (UKGC) are among the most prominent members of the forum.

Ireland’s Department of Justice has recently stated that it will include support for the Gambling Regulatory Authority of Ireland (GRAI) [Údarás Rialála Cearrbhachais na hÉireann]

in its Justice Plan 2023, carrying on the work begun in 2021 to repeal existing gambling law in Ireland and replace it with a modern framework that addresses both land-based and online betting and gambling.

The Irish Department of Justice and Equality is a member of the forum as is the Finnish Ministry of Social Affairs and Health. Both government bodies have been heavily involved in the push for new regulatory frameworks in their countries.

GREF: Unlicensed Operators put Consumers at Risk

As one voice, forum members assert that “illegal gambling” (as defined by each member-state) undercuts the development of a fair gaming market as well as consumer protections.

“In light of these considerations, we commit ourselves today to working together against illegal gambling, in order to ensure effective implementation of our national regulations,” the organization stated.

Germany’s nascent regulatory authority, the GGL said upon its taking over responsibilities from regional ‘placeholders’ that it would create and implement tough standards and aggressively pursue unlicensed firms serving games or sports betting opportunities in the country.

Holland’s KSA has recently stepped up enforcement actions against licensed providers that breach the rules as well as foreign gambling websites they deem to be targeting Dutch players without a license.

However, not all regulated stakeholders are in unanimous agreement that stricter rules and enforcement are in players’ best interests.

According to research from PwC as provided to the UK’s Betting and Gaming Council (BGC) in early 2022, British gamblers who used unlicensed punting sites more than doubled in just two years. The count went from 220,000 to 460,000 in that timeframe. PwC estimated that the amount bet at non-UK-licensed online websites was billions of pounds annually.

The report stated: “This analysis suggests that the UK has a more ‘open’ online gambling market and currently has a smaller unlicensed market share than our European benchmarks.

“Whilst it is not possible to isolate the impact of individual regulatory characteristics, the above assessment suggests that jurisdictions with a higher unlicensed market share tend to exhibit one or more restrictive regulatory or licensing characteristics.”

Referring to the long-awaited UK Gambling Review, BGC Chief Executive, Michael Dugher said: “We support the Gambling Review but there is a real danger that it leads to the regulated industry being smaller and the illegal black market growing substantially.

“This research is stark about the dangers of the black market, we have to learn lessons from abroad, and make the right choice at this dangerous crossroads.”

Stringent Regulations May Drive Players to Black Market Sites

The PwC report didn’t stop at the UK’s borders however and it examined several other European countries. It found the following:

After Norway created a state monopoly and restricted all gambling stakes, implemented affordability checks and advertising restrictions, the black market grew to more than a 66% share of all stakes.

The country’s plans for DNS blocking to keep Norwegian players at state-sanctioned websites recently hit a speed bump when it was determined that the landing page searchers would be redirected to, the Norwegian Lottery Authority’s website, which did not conform to national privacy standards.

Norway currently enjoys a 100/100 rating at Freedom House with 40/40 for political rights and 60/60 for civil liberties. It’s unclear if DNS blocking would affect that score.

In France, 57% of all money staked is at unlicensed websites rather than at France’s state-monopoly gambling portals.

Advertising for betting and gambling is strictly prohibited in Italy but the black market accounts for nearly a quarter of all money staked online, according to the report.
The report did not state the percentage of unlicensed betting that occurred prior to the increased regulatory restrictions.

However, it did also note that Spain has seen 20% of all stakes being placed at unregulated websites since a 2020 Royal Decree in Spain severely restricted all gambling advertising. The BGC asserts that those numbers are the result of players not having access to information on safe gambling due to the advertising ban.

In 2020 Denmark also placed restrictions on licensed operators banning deposit incentives such as match bonuses while the Danish Tax Authority warned of the potential of a 9% increase in the black market share.

In Sweden, 38% of self-excluded gamblers who chose to close their accounts at locally licensed operations were still able to bet online with operators not licensed in Sweden.

Source: Cross-Border Regulators Body Gref Outlines Black Market Strategy, SBC News, April 11, 2023

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