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New research is raising a red flag about one of the gambling industry’s favorite talking points: how big the “black market” really is.
A scoping review published in PLOS ONE on January 23 argues that estimates of unlicensed online gambling in the Nordic region are often too shaky to be used as a basis for policy, even though they’re regularly cited in debates about tougher rules, advertising limits, and channelisation targets.
While regulators think otherwise, research team say it can’t be used as a basis for policy
The research team reviewed 32 reports covering Denmark, Finland, Norway, and Sweden, and found that the same question, how much gambling activity is happening with operators outside national licensing systems, can produce wildly different answers depending on who is counting and what data they lean on.
A major issue, the authors say, is that many widely circulated figures come from non-transparent sources or rely heavily on private market-intelligence data, sometimes blended with other inputs in ways that are hard to audit. In the paper’s dataset, most estimates referenced numbers from H2 Gambling Capital, and industry-funded reports tended to produce higher offshore estimates, which can then get recycled in political arguments about rolling back consumer protections.
Current estimates are too uncertain to be used
Håkan Wall, a Karolinska Institutet researcher and one of the paper’s authors, warned that when the methodology is unclear, the numbers can end up doing more damage than good. “Current estimates are too uncertain to be used as a basis for political decision-making,” he said, adding that opaque figures can be used to steer policy even when the foundation is weak.
The paper doesn’t deny that unlicensed gambling exists, or that it can create real risks around age checks, player safeguards, and criminal exposure, but it pushes back on how confidently the size of the market is sometimes presented. The authors argue that better monitoring will likely require more openness about methods and a mix of indicators, rather than a single headline figure that can’t be independently checked.
