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The report assesses black market activity across 28 European jurisdictions, including the UK, Netherlands and Germany. According to estimates across a mature black market ecosystem, 25 operators account for approximately 64% of relevant black market traffic.
Thanks to the “rapid growth of crypto currencies” and globally recognisable branding through marketing and sponsorships, this handful of operators are generating the majority of illegal gambling traffic across Europe.
The report also cites brands targeting a specifically banned vertical or product within a jurisdiction as driving black market activity. While markets across Europe have many examples, one such flagged in the report is that iGaming remains illegal for licensed operators in France.
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One answer is that the industry is no longer being valued primarily on the promise of endless growth. The market instead wants to see profit, cash generation and manageable regulation maintained across all facets of a listed business. Ed Birkin, managing director of H2 Gambling Capital, says the longer-term decline in gambling stocks runs much deeper than just changes to earnings forecasts.
“The industry share price declines have been much more severe than the cut to earnings projections which means that, while there may be some weakening in some companies’ fundamental growth drivers, the valuations that investors are putting on them have been the main driver of share price declines – although weaker fundamentals lead to lower valuations, so the reality is that they’re completely intertwined.”
Entain’s demotion comes after another – and arguably more significant – symbolic move by Flutter Entertainment. Flutter began trading on the New York Stock Exchange in January 2024 and later moved its primary listing from London to New York.
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Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.
The trade body has long been critical over the discrepancy between channelisation estimates made by the regulator, and other independent reviewers.
The DOCV reinforced its calls for a unified federal licensing regime for online casino games and stronger enforcement mechanisms against illegal operators.
