Belgium alerted to ‘system failure’ as the black market enjoys visibility advantage

(AsiaGameHub) –   Authorities and regulatory bodies of Belgium have been warned that ‘the visibility of the legal online gambling market is undergoing a critical decline’, and that a rising number of black market operators are capitalizing on this trend.

This alert was issued by the Belgian Association of Gaming Operators (BAGO), the industry trade group made up of Belgium’s five largest operators: Ardent Group (which runs the Casino de Spa and Circus brands), Napoleon Sports & Casino (operating under the Super brand), Golden Palace Group, Kindred Group (owner of FDJ United) and Betsson AB.

Fresh data collected from BAGO member firms shows that unlicensed operators make up 23% of total gambling expenditure in Belgium, a figure that is projected to rise in 2026.

Members have observed that the growing prominence of illegal gambling brands is having a ‘disproportionate impact on the vulnerable groups they target’, with BAGO reports revealing that 47% of people registered in Belgium’s EPIS self-exclusion system continue to place bets through unlicensed operators.

“Looking at these figures, we can see how deeply entrenched illegal gambling offerings have become in Belgium,” BAGO stated.

“As the legal market grows less visible and harder for consumers to identify, the shift towards unlicensed operators is accelerating.”

Belgium’s tight noose on online gambling 

The warning highlights a core contradiction in Belgium’s regulatory framework, which has rolled out a series of restrictions on licensed operators over the past decade.

In 2020, the government introduced a €200 deposit cap for users gambling via licensed online providers, a temporary COVID-era measure that was later written into Belgian law as a permanent requirement.

Additionally, Justice Minister Vincent Van Quickenborne brought in a full ban on all gambling incentives, including sign-up offers, free bets and all marketing-related perks.

In 2022/2023, the government also approved the Royal Advertising Decree, which prohibits all forms of gambling advertising across traditional media channels such as television, radio and printed publications.

This was followed by a complete ban on gambling sponsorships for Belgian sports, with the regulator further stipulating that all online gambling campaigns must be restricted to audiences aged 25 and above; all campaigns also require prior approval from the Belgian Gaming Commission (BGC).

After the advertising prohibition came into force, the De Croo government raised the legal gambling age to 21 years old in September 2024.

Visibility a privilege for the black market

While policymakers have introduced stricter limitations for licensed operators, particularly around advertising, legal providers are losing visibility and becoming harder for consumers to distinguish. As a result, users are increasingly exposed to unlicensed alternatives that operate outside Belgium’s consumer protective framework.

“In a strictly regulated market, visibility is not just a matter of brand communication,” BAGO explained. “It is the mechanism that allows consumers to identify authorised, supervised gambling offerings. When that visibility drops, the line between legal and illegal operators becomes blurred.”

BAGO further noted that nearly “two-thirds of online gambling traffic in Belgium is now routed to illegal websites”.

According to member firms, this trend is not driven by consumer choice, but is a structural consequence of limits on licensed operators’ ability to engage with players. In this landscape, the boundary between legal and illegal gambling offerings becomes increasingly hard to maintain.

A key concern raised by BAGO is the erosion of “channelisation” – the principle that regulated markets should steer players towards licensed operators where consumer protections can be enforced.

Belgium’s regulatory framework has long been built on this concept, combining strict licensing controls with responsible gambling measures such as deposit limits, age verification and the EPIS self-exclusion system.

“Channelisation sits at the core of Belgian gambling policy,” BAGO noted. “But it can only function if players are able to clearly recognise legal offerings. If that distinction disappears, players will inevitably drift towards unregulated environments.”

This position has been supported by a number of recent legal developments. In its December 2025 ruling, Belgium’s Constitutional Court confirmed that national gambling policy must not only protect players, but also channel them towards licensed operators as a way to combat illegal supply.

The Court stressed that authorised operators require an adequate level of visibility and public recognition to deliver on this objective.

BAGO said: “It is only within a licensed ecosystem that effective player protection can be guaranteed. As soon as players move to illegal sites, there are no safeguards, no monitoring and no formal intervention structures in place.”

The migration to the black market is particularly noticeable among younger demographics. BAGO data indicates that up to 65% of men aged between 18 and 21 have used illegal gambling websites, underscoring the exposure of vulnerable groups to unregulated operators.

While Belgium’s tightening regulatory approach is designed to strengthen consumer protection, industry stakeholders argue that the stricter regulatory environment has inadvertently created conditions that favour illegal competitors.

The near-total ban on gambling advertising, paired with restrictions on promotional tools and customer engagement, has reduced licensed operators’ ability to compete for visibility in the crowded digital marketplace.

At the same time, illegal operators continue to reach Belgian consumers through offshore marketing channels, often using aggressive, unregulated messaging.

System rethink

As Belgium continues its review of national gambling laws, BAGO is calling on policymakers to reassess the balance between restriction and channelisation.

“As long as unlicensed operators can flood the market with illegal marketing and target vulnerable audiences, further restrictions on licensed operators will deliver the opposite of the intended effect,” the association warned.

BAGO is urging the government to step up enforcement against illegal operators, including faster site blocking measures and tighter oversight of payment channels and digital platforms that grant access to unlicensed sites.

At the same time, it has advocated for a regulatory framework that allows licensed operators to maintain sufficient visibility to fulfil their role in the market.

“An effective gambling policy does not protect players by marginalising legal offerings,” BAGO concluded.

“It protects them by reinforcing channelisation towards a strictly regulated and fully accountable framework.”