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The report utilised various methods to estimate the size and scale of Europe’s black market, including web traffic, digital marketing, macros data and regulations in place across the 28 markets surveyed.

Helios, a specialist consultant in gambling web traffic, analysed the number of black market websites actively marketing across the 28 markets included in the report, between March and May.

This data was cross referenced with SimilarWeb traffic analysis to confirm the scale of activity. In some markets, the number of illegal sites being actively marketed was much higher than those that have local licences to operate.

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Independent analysis by Bettormetrics found Kambi partners either led or shared the lead on measures including time to market, live uptime and bet delay. It also outperformed its B2C and B2B competitors on live uptime in World Cup markets including over/unders on total goals.

“All the testing in the world cannot tell you precisely where you stand against the rest of the market on key aspects of the product,” Lamb says. “It was very positive to see Kambi as a leader in these key metrics.”

The way customers used the offering was equally instructive. Bets outside the match-winner market accounted for 63% of pre-match turnover, compared with 57% in 2022, reinforcing the importance of depth beyond traditional markets.

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She emphasised that half of Entain’s retail employees were women, with over 50% working flexible or part-time hours. More than 2,500 of its employees are under 25 years old.

The letter argues that the proposed increase would hit the workers and communities Labour’s “Makerfield Test” is supposed to protect, while potentially costing the Exchequer money rather than raising it.

Entain stressed the importance of its retail networks in providing local employment and community engagement.