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HLTV corroborated this, highlighting its editorial tone as adult-oriented.
The ASA reviewed whether the ads were directed at under-18s through their placement or content. Its rules prohibit advertising through media where more than 25% of the audience is likely to be under 18.
While the audience data did not conclusively define the website’s age demographics, the regulator noted small percentages of under-18s in HLTV’s social channels but found the website’s content and presentation clearly targeted adults.
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Other estimates are considerably higher, illustrating how difficult the market is to measure. As an example, separate research from Gaming Compliance International put the value of unregulated online gambling at $5.9 trillion in wagering value in 2025, while estimating that unregulated operators accounted for 78% of global online gaming GGR.
Another report, commisisoned by Euromat, estimates that Europe’s black market has sustained a compound annual growth rate of 18% between 2019 and 2026, and will be worth up to €13 billion by the end of the year.
For enforcement authorities, however, the challenge is not simply estimating its size. It is keeping track of an ecosystem that can continually change domains, infrastructure and acquisition channels. That is where Madsen sees Trace2Trace fitting in.
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Notably for highly engaging verticals light online slots, if players are receiving a smaller-than-expected RTP (return to player), or bonuses have been restricted, they could again transition to an illegal offering where there are no such restrictions.
As has been flagged in previous reports, Regulus highlighted that the top 1% of active customers accounts for almost 50% of black market revenue across Europe. This follows a similar trend across licensed gambling as the report highlights “online gambling is a consumer discretionary expenditure item. This means a large proportion of expenditure is concentrated into a relatively small number of players.”
In its market-specific breakdown, the report noted a “rapid reduction in channelling” in the UK, following the increased use of affordability checks.