A projection that black market gambling advertising will surpass regulated-operator spend in the UK by 2028 is not, on its face, a Dutch story. But timing has a way of making connections. In the same week that figure surfaced publicly, The Hague began circulating proposals for a blanket gambling advertising ban — citing persistent gaps in player protection, particularly around self-exclusion. The two developments share an uncomfortable logic: tighten advertising rules on licensed operators without addressing unlicensed channels, and you may accelerate the very harm you intended to prevent.
The UK Precedent That Nobody Wants to Inherit
The UK Gambling Commission has spent the better part of five years layering restrictions onto licensed operators — affordability checks, deposit limits, tighter bonus conditions, and a steady expansion of the GAMSTOP self-exclusion scheme. What it has not done, and what no regulator has yet managed effectively, is constrain the advertising reach of offshore sites operating without a UKGC licence.
The 2028 projection, if it holds, would represent a structural inversion: a regulatory framework that costs licensed operators market share while unlicensed competitors absorb the displaced demand. That is not a hypothetical concern. Affiliate traffic data and payment processing trends already suggest that a meaningful cohort of UK players who encounter friction on licensed platforms are not stopping — they are redirecting. Non-UK casino and betting sites explicitly targeting British players have proliferated, and their marketing budgets appear to be scaling accordingly.
For operators holding UKGC licences and absorbing the compliance costs that come with them, this is a competitive disadvantage built by the regulator itself. The Commission is aware of the tension. Whether its enforcement tools — largely dependent on payment blocking and ISP-level restrictions that are easily circumvented — are equal to the task is a separate and more difficult question.
The Netherlands Faces the Same Fork in the Road
The Dutch Kansspelautoriteit (KSA) opened its online licensing regime in October 2021, and the advertising rules that followed were already among the stricter in Europe: a ban on untargeted advertising took effect in July 2023, prohibiting TV, radio, and outdoor gambling ads that could reach under-18s. The proposed blanket ban now under government review would go further, eliminating most forms of gambling promotion regardless of targeting precision.
The stated rationale centers on self-exclusion failures — specifically, that players registered with the Cruks national exclusion register are still being reached by marketing through channels that current rules do not adequately control. That is a legitimate concern. But the policy response being considered does not obviously solve it. Licensed operators subject to a blanket ban would lose a primary tool for retaining players within the regulated ecosystem; unlicensed sites, by definition, would not be bound by the same restriction.
The Dutch market is still young enough that the black market has not yet achieved the penetration it has in the UK. That window may not stay open. A senior compliance consultant familiar with the KSA's enforcement posture noted that "the regulator has been relatively aggressive on payment blocking, but the sites keep reappearing under new domains. Advertising restrictions that only bind licensed operators make the economics of that arms race worse, not better."
M&A Signals Where Confidence Actually Lives
Against this regulatory uncertainty, the deal flow in European iGaming tells its own story. Greentube's acquisition of Czech operator Kingsbet CZ, Banijay's completed takeover of Tipico, and VICI's closing of the $1.2 billion Golden Entertainment transaction all reflect sustained appetite for regulated-market exposure — including in jurisdictions where the advertising environment is under pressure. Investors and acquirers are not exiting; they are consolidating.
That consolidation logic is partly a hedge. Larger, diversified operators can absorb marketing restrictions that would cripple smaller single-market rivals. A blanket ad ban in the Netherlands would disproportionately affect independent Dutch-facing operators and mid-tier affiliates, while multinationals with cross-border brand recognition and CRM infrastructure maintain retention through channels that are harder to regulate — loyalty programs, app-based messaging, direct email to opted-in users. Scale, in other words, becomes a compliance advantage.
This is not a neutral outcome for competition. Regulators who favor blanket restrictions should be explicit about the market structure they are likely to produce: fewer, larger licensed operators; a wider unlicensed fringe; and a shrinking middle tier that provided much of the product and price diversity that made regulated markets attractive to consumers in the first place.
The Takeaway
The UK's emerging black market advertising problem is a warning, not an anomaly. It is the predictable result of applying progressively heavier compliance burdens to licensed operators in markets where the unlicensed alternative remains accessible. The Netherlands has the advantage of observing that dynamic before replicating it, but the blanket ad ban proposal suggests the lesson has not fully landed in The Hague.
Regulatory frameworks that treat advertising restriction as a harm-reduction tool are not wrong in principle — the evidence on gambling advertising's effect on at-risk populations is serious and cannot be dismissed. The error is in applying those restrictions asymmetrically: tightly on licensed operators, loosely or not at all on the offshore market. Until regulators develop enforcement mechanisms with genuine reach beyond payment blocking and domain blacklisting, every incremental restriction on licensed marketing is, at least in part, a subsidy to the black market.
