Belgium: concerns over the black market in gambling 

The European market for illegal gambling is growing significantly. According to a study commissioned by EUROMAT and carried out by Regulus Partners and Helios, unauthorised activities are reported to have grown by an average of 18 per cent per year since 2019. Belgium is one of the countries particularly affected. 

In Belgium, the illegal market is already attracting some young gamblers 

The phenomenon is no longer merely a theoretical threat to the Belgian authorities. A survey carried out in 2025 by DataSynergy for the Gaming Commission, involving around 1,000 Belgians aged between 18 and 30, gives an indication of the scale of the problem. 

Among the gamblers surveyed, 84 per cent stated that they used legal sites. However, 28 per cent also indicated that they used illegal platforms, and around 8 per cent said they gambled exclusively on unauthorised sites. 

Another notable finding was that three illegal brands featured amongst the ten best-known gambling platforms among those surveyed. The regulated market and the black market therefore do not necessarily operate as two completely separate worlds. Some gamblers use both. 

Illegal platforms have become fully-fledged international businesses 

Around 25 operators alone account for 64 per cent of traffic linked to illegal gambling across the 28 jurisdictions analysed. 

The largest group of sites belonging to a single owner accounts for around 12 per cent of traffic. The leading individual brand accounts for around 10 per cent. 

These figures paint a picture of a sector far removed from the image of small, scattered clandestine sites. The main operators now have international brands and are investing in digital promotion and sponsorship. Some also accept payments in cryptocurrencies. 

Complex corporate structures and the use of licences issued by certain jurisdictions further complicate the identification of owners and the enforcement of decisions taken by national authorities. 

The line between legal sites and illegal platforms is becoming less clear 

The appearance of these platforms poses another challenge. Some illegal operators offer particularly well-designed websites, mobile apps and major social media campaigns. Partnerships with celebrities or international sports organisations can also boost their visibility. 

For a player, it can therefore become more difficult to recognise immediately that a platform does not hold the required licence in their country. 

In Belgium, the Gaming Commission maintains a blacklist of websites identified as illegally offering games to Belgian residents. The domains in question may be blocked, and an official message then informs the user of the platform’s illegal nature and the associated risks. However, this strategy faces one difficulty: operators can adopt new domain names after a block has been imposed. 

Up to 13 billion euros by 2026 

The estimated economic scale of the phenomenon explains the concerns. According to the study commissioned by EUROMAT, the unauthorised European market is projected to have recorded an average annual growth rate of 18 per cent between 2019 and 2026. At this rate, its gross gaming revenue could reach up to 13 billion euros in 2026. 

The researchers examined 28 European jurisdictions by cross-referencing several categories of information, including website traffic, digital promotional activity, macroeconomic data and various national regulations. 

In particular, Helios studied illegal websites that were actively promoting themselves between March and May 2026, and then cross-referenced these observations with traffic data provided by Similarweb. The study thus describes a structured and largely professionalised market, rather than a collection of small, independent clandestine operators. 

Belgium is explicitly mentioned amongst the markets where the number of illegal websites actively promoting their services is said to exceed that of platforms holding a national licence. The study makes the same observation for several other countries, notably France, Germany, Spain, the Netherlands, Portugal and Cyprus. 

This situation arises at a time when Belgian regulations have been gradually tightened. Since 1 September 2024, the minimum age for participating in games of chance and betting has been set at 21. For authorised online operators, the legal deposit limit is set at 200 euros per week per player account, with specific rules applying when an increase is requested. Belgium has also tightened restrictions relating, in particular, to advertising and bonuses. 

Illegal sites are exempt from many of these obligations. They are therefore able to offer promotions or certain terms and conditions that are no longer available in the same way from operators holding a Belgian licence. 

Advertising restrictions fuel a sensitive debate 

According to the study’s authors, around 46 per cent of the markets examined impose advertising restrictions that they consider significant. Belgium is included in this group alongside, amongst others, Germany, Italy, Spain and the Netherlands. 

Researchers argue that advertising restrictions, taxation of players in certain countries, bans on certain categories of games, and monopoly situations may contribute to driving some consumers towards unauthorised foreign platforms. 

The report draws on the principle of ‘channelling’ here: to keep players within the regulated market, the legal offering must remain sufficiently attractive compared to illegal platforms. 

According to this reasoning, when a gambler can no longer find certain features or conditions with authorised operators, they may seek them elsewhere. Once registered on an illegal platform, they may then transfer a larger proportion of their gambling activity there. 

A small proportion of players could have a major impact 

The size of the illegal market does not depend solely on the number of people using it. According to Regulus Partners, the top 1 per cent of the most active players generate nearly half of the revenue in the European black market. 

A regulated market can retain the vast majority of players whilst losing a significant share of spending if certain particularly active players turn to offshore platforms. 

In other words, simply measuring the number of users on legal sites is not necessarily sufficient to determine what proportion of the money wagered actually remains within the regulated system. 

Cryptocurrencies complicate blocking efforts 

Digital payment methods also pose a challenge. According to the study, cryptocurrencies enable illicit operators, in particular, to reduce their reliance on traditional payment systems. This means that certain measures designed to block transactions become less effective. 

This technical capability is compounded by the increasing professionalism of major illegal operators and their ability to switch domains when the authorities block an address. 

Smaller platforms, meanwhile, remain more dependent on intermediary sites that bring them new players. 

Player protection or maintaining the legal market: what is the right balance? 

The growth of the black market presents the authorities with a tricky dilemma. Licensed operators in Belgium must comply with rules concerning, in particular, identity checks, self-exclusion mechanisms, deposit limits, advertising and access to games. Illegal platforms can ignore these obligations. 

The issue is therefore not simply a matter of tightening up the regulations. It is also a question of determining how to keep players within a regulated environment when foreign operators offer them services that are not subject to Belgian restrictions.