GCI Puts Unregulated Share of EU Gambling Exposure at 91%

The figure comes from Online Gambling 2024-2025: EU 27 Europe, produced by GCI for the Campaign for Fairer Gambling and released in September. The full report puts total EU-27 online GGR at €128.0 billion for 2025, with €91.6 billion unregulated and €36.5 billion regulated.

GCI uses “unregulated” for platforms that are not authorised or licensed in the EU jurisdiction where they target and transact with consumers. An operator may therefore hold a licence elsewhere and still fall into this group.

The €91.6 billion number itself is not new to 15M. On July 7, 15M reported the figure after the European Casino Association presented GCI data at a European Parliament roundtable. The September publication adds the full 2024-25 tables, GGR methodology and audience data.

Exposure Stayed Above 90%

GCI defines Audience Exposure as a blended measure covering affiliates, operator sites, payments, social media, advertising, streaming, peer-to-peer communications, search and LLMs, products and apps.

It concerns consumers doing more than simply seeing gambling content. Clicking an ad, registering on a site or interacting with a social post can count.

The unregulated share was 92% in 2024 and 91% in 2025. GCI calls the metric an “early warning indicator,” rather than a revenue measure.

Based on the report’s numbers, 15M calculates a 19-percentage-point gap between unregulated Audience Exposure and unregulated GGR share in 2025.

GGR Rose With Almost No Operator Growth

Estimated unregulated GGR increased from €80.6 billion in 2024 to €91.6 billion in 2025, up 13.6%. The number of unregulated operators tracked by GCI barely moved: 6,220 became 6,238. That is roughly 0.3% growth.

Affiliates went the other way. GCI counted 20,632 affiliates promoting unregulated operators in 2024 and 17,501 in 2025. The drop works out at about 15.2%.

Those counts do not explain the revenue increase on their own. They do show that GCI’s higher 2025 GGR estimate was not accompanied by a similar rise in its operator or affiliate counts.

The Market Size Is Contested

GCI’s 72% estimate sits well above other measurements. A September Euromat study by Regulus Partners and Helios estimated the illegal share at €12 billion, or about 25%, across 28 European markets. In March, EGBA put illegal operators at an estimated €18 billion, or 27% of European online GGR in 2025. The studies use different scopes and methodologies, so the figures are not directly comparable.

GCI uses a Value per Visit model to convert marketplace activity into GGR. Its methodology combines site and app analysis with factors including KYC, product, pricing, promotions, payments and deposit thresholds. Human analysis, machine learning and AI are also used in the process. The 72% is therefore a modelled GCI estimate, not an EU regulatory statistic.

The newer number is 91%. Even there, GCI stops short of treating exposure as future revenue. Its own definition says the metric shows where market share could move. It does not establish that unregulated GGR will reach the same share.