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The committee also suggested a ban on inducements (free bets, sign-up bonuses) as these promotions stimulate betting activity and recruit new or lapsed customers.
Another point of contention was content marketing and influencer promotions. The Lords committee advised treating this as advertising and, if a full ban were not immediately feasible, prioritising its prohibition.
Sponsorships and advertising with sports teams was also flagged as according to the report, voluntary efforts had failed to reduce the industry’s exposure.
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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%.
The trade body has long been critical over the discrepancy between channelisation estimates made by the regulator, and other independent reviewers.
The DOCV reinforced its calls for a unified federal licensing regime for online casino games and stronger enforcement mechanisms against illegal operators.
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For example, on the role of pirate sports streaming in driving traffic towards illegal gambling, while regulators in markets such as Turkey are confronting large-scale unlicensed activity. The more fragmented and technically sophisticated the illegal market becomes, the more important the intelligence behind enforcement is likely to become.
Madsen knows from experience how difficult it can be to escape gambling when access remains readily available.
“I’m trying to address every stage: prevention, support for people who are already struggling, and then action against the illegal sites.”
