Three Trojan Horses

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Other studies have made similar estimations. In June last year two thirds of bettors surveyed by YouGov said the tax increase, which will also hit online sports betting from next year, would drive them to play with unlicensed operators.

The UK has historically maintained a high channelisation rate due to it being particuarly mature with a huge competitive offering. According to the report, up to 1,491 licensed sites provides sufficient choice for engaged players.

The report utilised various methods to estimate the size and scale of Europe’s black market, including web traffic, digital marketing, macros data and regulations in place across the 28 markets surveyed.

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In her letter David warned another tax increase, on top of April’s RGD increase to 40% of GGR, could increase its operational expenses for retail by £100 million annually.

This could precipitate as many as 1,470 shop closures and the loss of up to 15,900 jobs, according to figures commissioned via the Betting and Gaming Council and consultancy firm EY.

David further emphasised the impact such a tax rise would have on high street workers and communities.

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The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.

The DOCV, another trade body representing licensed online casino operators in Germany, also expressed support for the prosecutorial efforts. However, it emphasised that the raid exposed regulatory gaps which had allowed organised crime to flourish.

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%.