Germany: Evaluation on the Horizon – Dispute Over Scope, Impact, and Side Effects
Since 2021, Germany has relied on a nationwide coordinated regulatory framework for online gambling. The focus is on player protection tools (e.g., centralized blocking and limit systems) and stricter oversight of advertising. Politically, the decisive question is whether the regulation achieves its core objectives: addiction prevention, youth and player protection—while simultaneously ensuring sufficient market channeling so that the market is not “lost” to unlicensed providers.
Enforcement against illegal offerings follows a clear logic: not only the providers themselves, but also their infrastructure should come under pressure. In practice, this primarily involves cease-and-desist orders, payment blocking, and—depending on the specific case—measures that make access more difficult (network blocks). Additionally, efforts are focused on “bottlenecks,” such as advertising: A key component is that advertising platforms adapt their guidelines so that only authorized providers can place ads.
The authorities’ view is that enforcement is having an effect—evident, for example, in how many services, domains, and advertising campaigns are shut down over time. At the same time, the question of measurement remains politically sensitive: What counts as the black market, how is it quantified—and how does one assess ways to circumvent regulations? It is precisely these points that are likely to play a central role in the upcoming evaluation discussion, because this is where it will be decided whether and where enforcement needs to be tightened.
Netherlands: More Player Protection – and Suddenly, Pressure from Illegal Activities Grows
The Netherlands is considered a textbook example of how quickly the balance between the legal market and illegal offerings can shift. Following the opening of the regulated online market, the regulator has recently placed significantly greater emphasis on player protection measures—including stricter rules regarding deposits and creditworthiness. The desired effect: less problematic gambling and lower average losses.
The regulator openly describes the downside: While the number of active players is not necessarily declining, the legal gross gaming revenue is stagnating or shrinking—and at the same time, the illegal market continues to grow. Particularly striking is the difference between “channeling by players” and “channeling by money.” In other words: Although many people formally gamble within the legal framework, a significant portion of the money may flow into unlicensed offerings—especially when strict player protection rules are perceived by some as “too restrictive.”
Added to this is a classic enforcement problem: sanctions against offshore providers are legally possible, but often difficult to enforce in practice—particularly when it comes to collecting fines. This makes the illegal market not only a player protection issue but also a question of state enforcement capacity. The debate is therefore increasingly focusing on more effective levers: payment flows, platform partnerships, and faster blocking mechanisms.
Sweden: High Channelization – but Online Casinos Remain the Weak Link
Sweden realigned its gambling regulations as early as 2019 and now regularly measures channelization. As a result, the country remains comparatively stable at the overall market level: the share of gaming within the licensing system is high. At the same time, the detailed data reveal a familiar pattern: channeling varies noticeably depending on the product category—the online sector, in particular, is considered vulnerable.
Swedish analyses also shed light on why players gamble outside the licensed system in the first place: reasons cited include “better odds” offered by unlicensed competitors, more attractive bonus offers—and a particularly sensitive issue: circumventing self-exclusion via the national exclusion system. This is a contentious issue in player protection policy because high-risk groups, in particular, are more likely to attempt to bypass restrictions.
For regulation , this means: It is not enough to look good on average. The key factor is whether the most problematic gaming segments are designed in such a way that legal providers remain competitive—without undermining player protection. Sweden thus exemplifies the European balancing act: maintaining high levels of channeling without leaving the door open to circumvention strategies.
Denmark: Consistent Enforcement – Blocking, Platform Partnerships, and an Eye on New Trends
For years, Denmark has relied heavily on practical enforcement tools against illegal offerings. A key tool is DNS blocking, which is ordered by the courts and is intended to restrict access to unlicensed gambling sites via Danish providers. What stands out here is not so much a “one-off strike” but rather continuity: blocking is regularly updated because new domains and mirror sites are constantly emerging.
At the same time, the regulator emphasizes two aspects: First, that an increasing number of blocked sites does not automatically mean the illegal market is growing—it can also reflect more intensive searches and more consistent enforcement. Second, that efforts are being made to evaluate the impact of blocking measures using data, such as through traffic analyses before and after blocks.
Denmark is also closely monitoring new forms of illegal or gray-area gambling that primarily attract young audiences—such as hybrid forms combining gaming and gambling. At the same time, the authority is focusing on collaborations with major platforms and tech companies (apps, social media, streaming) to more quickly disrupt advertising, distribution channels, and access to illegal offerings. The model is thus an example of “enforcement as an ecosystem”—targeting not just providers, but their reach.
Belgium: Strict Rules, Blocking Lists—and Yet the Illegal Pull Grows
Belgium has traditionally pursued a restrictive approach: access restrictions, advertising limits, and a robust blocking system are intended to safeguard player protection. At the same time, the digital market is extremely porous. A key tool is the “blacklist” approach: unlicensed gambling sites are listed and reported to providers for blocking. These lists are continuously updated; additionally, Belgium is working to accelerate the detection of illegal offerings (e.g., via national domains).
Player protection is particularly evident through EPIS and self-exclusion: the number of blocking and exclusion measures is high, and there are indications that a great many access attempts are already intercepted at the gateway to the legal system. This is a strength—but at the same time a risk: if blocked or restricted players continue to find offers among unlicensed competitors, the problem is merely shifted.
In the current debate, Belgium is therefore frequently cited as an example of how stricter rules without equally strong enforcement regarding payments, platforms, and advertising can lead to a paradoxical situation: The legally regulated market becomes “cleaner,” while the unregulated market absorbs players who want to circumvent the restrictions. Demands from the market and regulatory circles therefore aim for greater enforcement powers, better resources, and more effective restrictions on payment flows.
France: No legal online casinos – yet illegal offerings remain widely available
France is a special case in Europe because online casinos are not generally provided for in the licensing system. Online sports betting, poker, and horse betting are primarily permitted and regulated – while virtual casino games on the internet are considered illegal. This leads to a structural tension: demand exists, but the legal supply does not match the same range of products. This is precisely where many offshore providers step in.
Regulators primarily address this through administrative blocking mechanisms, blacklists, and—increasingly important—measures against payment flows. France has visibly tightened regulations in recent years and publishes information on blocked sites; in addition, the market is regularly warned about new “substitute forms” that can function like betting (such as certain prediction formats) and are illegal from the authorities’ perspective.
For a European comparison, France is therefore particularly interesting: even a ban on certain forms of online gambling does not automatically solve the problem—it merely shifts it. Success then depends even more heavily on enforcement, payment mechanisms, and international cooperation.
Finland: Major System Change – Licensing Market Starts in 2027, Applications Accepted Starting in 2026
Finland is currently undergoing one of the largest regulatory overhauls in Europe. The country is gradually moving away from the pure monopoly model in the online sector and introducing a hybrid system: Certain products remain exclusively with Veikkaus, while other areas are being transferred to a licensing competition. The explicit goal is to reduce harm while simultaneously improving channeling—that is, bringing gambling back into supervised, national structures.
Specifically, the roadmap stipulates that companies can apply for licenses starting in March 2026; the launch of licensed offerings is then scheduled for July 2027. Veikkaus will remain within the existing monopoly framework until the end of June 2027. At the same time, the regulatory framework will be reorganized so that licensing and supervisory duties will be handled by a new or restructured authority starting in July 2027.
Noteworthy is the combination of market opening and strict safeguards: marketing remains possible, but only under clear restrictions—including rules on methods, sponsorship, and direct advertising.
Finland is thus attempting to solve a problem familiar to many countries: offshore gambling exists anyway—the question is whether it can be better regulated through a controlled opening rather than allowing it to grow in the shadows.
Spain: High Fines, Website Blocking, and Clear Signals to Providers
Spain is among the countries that visibly enforce regulations through sanctions and publication of measures.
The market is fundamentally regulated; at the same time, the authorities take strong action against unlicensed operators. Typical are “very severe” sanctions against offshore providers, combined with high fines and orders to block websites.
At the same time, Spain demonstrates that regulation is not directed solely against illegal operators: licensed operators are also sanctioned if they violate technical requirements or player protection obligations. This is relevant to the debate on channeling, because trust in the legal market also depends on whether rules are actually followed there.
In a European comparison, Spain thus represents an approach that relies on deterrence and visibility: high penalties, clear consequences, and ongoing communication about measures—as a signal to both providers and payment and advertising environments.
Austria: Pressure for Reform Ahead of 2027 – Monopoly Issue Remains a Core Political Conflict
Austria is heading toward a critical juncture: Central licenses expire in 2027, including sectors such as lotteries and online gambling, as well as several casino licenses. This increases political time pressure, as a new legal framework and a tender or re-award must be prepared—including procedures under EU law. At the same time, the issue is highly political: The question of “monopoly or multiple licenses?” determines not only market structure but also taxation, player protection frameworks, and enforcement mechanisms.
Among other things, IP and payment blocking are being discussed as tools against unlicensed online offerings. At the same time, it is openly acknowledged that such blocks can be circumvented in practice (VPNs, alternative payment services). This is the same conflict of objectives as in other countries: the tighter the restrictions, the greater the incentive to circumvent them—if enforcement cannot keep pace.
The industry has long voiced strong criticism that an overly restrictive or “isolationist” model strengthens the black market. The government is simultaneously working on the groundwork for the upcoming tender phase. The coming months will determine whether Austria opts for continuity (monopoly) or a controlled market opening—and to what extent enforcement and payment rules are factored into the decision.
Switzerland: Network blocks are the law—but circumvention and speed remain the weak points
With the Gambling Act , Switzerland has established a system since 2019 that generally permits online casinos—but only for operators who already hold a Swiss casino license. Foreign online casino providers without a Swiss license are prohibited; the Federal Gaming Board maintains a block list for this purpose, which providers must implement.
In practice, the debate centers on two points: First, the speed and responsiveness to new domains and mirror sites. Second, the ability to circumvent the blocks, as tech-savvy users can bypass them.
Media reports and market voices also point to a significant scale of illegal offerings—with estimates suggesting that a large portion of online casino activity takes place outside the regulated system.
From a player protection perspective, this is particularly critical because key protective mechanisms do not apply in the illegal sector. Switzerland thus represents a model that is formally clear (licenses only for Swiss concessionaires), but in everyday digital life faces the same reality check as other countries: without effective levers for payments, advertising, and platforms, blocking alone remains an incomplete tool.
An EU Problem with National Responses – and Three Recurring Leverage Points
Despite differing models, the debate in nearly all countries boils down to the same three leverage points:
- Attractiveness of the legal market: Player protection only works if legal offerings are used—and are not perceived as “too restrictive”—while the black market offers unlimited allure.
- Enforcement at key points: Domain blocks are important, but often insufficient. Payment flows, advertising platforms, app stores, social networks, and affiliate channels are becoming increasingly central.
- Measurability and transparency: Anyone seeking to evaluate channeling from a policy perspective needs reliable, comparable data—otherwise, regulators, providers, and policymakers will be talking past one another.
For Germany, the upcoming evaluation phase is thus not only a national litmus test but also part of a fundamental European question: How does one regulate a digital gambling market so that protective measures are effective—without unintentionally strengthening the black market?
Read the eighth part of our series on the evaluation of the State Treaty on Gaming here.
Want to stay up to date? Subscribe to our newsletter and follow us on LinkedIn, X, and Facebook.