EU Scam Study Finds Gambling Ads Run Without License Checks

The Study Describes a Risk, Not a Breach

Open Evidence and Spark Legal and Policy Consulting wrote the report under a 2025 contract supporting Digital Services Act supervision. Its scope line is explicit: it "does not evaluate compliance by providers of VLOPs and VLOSEs". VLOP stands for Very Large Online Platform, the DSA category that carries systemic risk duties.

The gambling passage is a conditional. Platform advertising systems "may enable unlicensed gambling operators to illegally promote services to users in countries where they hold no valid licence", the study says. It adds that this "could expose users to unregulated platforms without any platform-level verification of operator licensing status".

No platform is named in that passage. Gambling scams sit inside the report’s "unexpected gain" category, one of six it maps. Paid advertising is called a primary distribution mechanism for them, citing a Debunk.org finding that 99% of gambling scam cases involved ads.

As described in the study, an app developer submits an app that is policy-compliant. The store approves it. The developer can then switch on gambling functionalities remotely after release. The study calls this server-side toggles and post-review code injection.

Google, LinkedIn, Pinterest, TikTok and Bing all require a gambling certification, as a restricted category, the study records. A system that cross-checks a registration number and license against a registry is in place in collaboration with compliance partner G2RS. According to the study, it checks financial services licenses, but not gambling licenses. That is a 15M reading of two excerpts from the report that appear 40 pages apart.

A Dutch Court Will Test It First

The live case is in Amsterdam. VNLOK’s own research found that of the Facebook gambling ads they examined, more than 90% were from illegal sites. Meta has been summoned by VNLOK on 28 September for illegal gambling ads on Facebook and Instagram. VNLOK asks the court to declare that they are in breach of the DSA.

Meta removed between 11% and 15% of gambling website ads that VNLOK flagged in May and June. That leaves between 85% and 89% of the dodgy adverts VNLOK spotted up and about. That is a 15M subtraction from the association’s own figures.

"Illegal gambling operators can only reach Dutch consumers by using the infrastructure of large online platforms," said VNLOK’s chairman, Bjorn Fuchs. VNLOK is the association of Licensed Dutch Online Gambling Operators, and his remarks are translated from Dutch.

Platform rules have been the pressure point all year, as Indonesia’s scrutiny of gambling content showed.

Source: European Commission, "Digital Services Act study on financial scams on online platforms and ways to counter them", https://digital-strategy.ec.europa.eu/en/library/digital-services-act-study-financial-scams-online-platforms-and-ways-counter-them