The government and regulatory bodies of Belgium have been warned that ‘the visibility of a legal online gambling market is in critical decline’, and that an increasing number of black market operators are exploiting this trend.
The warning comes from the Belgian Association of Gaming Operators (BAGO), the trade body made up of Belgium’s five largest operators: Ardent Group (operator of Casino de Spa and Circus brands), Napoleon Sports & Casino (Super), Golden Palace Group, Kindred Group (FDJ United) and Betsson AB.
New data taken from BAGO members has indicated that unlicensed operators account for 23% of total gambling spend in Belgium, a figure that is likely to increase in 2026.
Members have noted that the growing visibility of illegal brands is having a ‘disproportionate impact on vulnerable groups being targeted’, with reports from BAGO showing that 47% of individuals registered in the Belgium EPIS self-exclusion system continue to gamble via illegal operators.
“With these figures, we can see how firmly the illegal offer has become embedded in Belgium,” BAGO stated.
“At a time when the legal market is becoming less visible and less identifiable, the shift towards unlicensed operators is accelerating.”
Belgium’s tight noose on online gambling
The warning highlights a central contradiction in Belgium’s regulatory framework, which has imposed a number of restrictions on licensed operators during the last decade.
In 2020, the government imposed a €200 deposit limit for those gambling via online gambling licensees, a COVID measure that then became a permanent fixture within Belgian law.
Furthermore, Justice Minister Vincent Van Quickenborne introduced a ban on all gambling incentives, including sign-up offers, free bets and marketing incentives.
In 2022/2023, the government also approved the Royal Advertising Decree, which bans all forms of gambling advertising in traditional media such as TV, radio and print.
This was compounded by a full prohibition of gambling sponsorships within Belgian sports, with the regulator adding that any online campaigns must be restricted to audiences aged over 25 years old; in addition, any campaign must be signed off by the Belgian Gaming Commission (BGC).
The advertising prohibition was followed in September 2024 by the De Croo government raising the age of gambling to 21 years old.
Visibility a privilege for the black market
Whilst policymakers have introduced stricter limitations on licensed operators, particularly in advertising, legal operators lose visibility and become harder to distinguish. As a result, consumers are increasingly exposed to unlicensed alternatives that fall outside Belgium’s protective framework.
“In a strictly regulated market, visibility is not simply a matter of communication,” BAGO explained. “It is what enables consumers to identify authorised and supervised offers. When that visibility declines, the distinction between legal and illegal becomes blurred.”
BAGO further noted that nearly” two-thirds of online gambling traffic in Belgium is now directed towards illegal websites”.
According to members, the trend is not driven by consumer choice, but is also a structural consequence of limiting licensed operators’ ability to engage with players. In such an environment, the boundary between legal and illegal offerings becomes increasingly difficult to maintain.
A key concern raised by BAGO is the erosion of “channelisation” – the principle that regulated markets should direct players towards licensed operators where consumer protections can be enforced.
Belgium’s 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 lies at the core of Belgian gambling policy,” BAGO noted. “But it can only work if players clearly recognise the legal offer. If that distinction disappears, players will inevitably drift towards unregulated environments.”
This position has been reinforced by a number of 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 means of combating illegal supply.
The Court emphasised that authorised operators require a sufficient level of visibility and public recognition to achieve this objective.
BAGO said: “It is only within a licensed environment that effective player protection can be guaranteed. As soon as players move to illegal sites, there are no limits, no monitoring and no structured intervention.”
The migration to the black market is particularly pronounced among younger demographics. BAGO data has indicated that up to 65% of men aged between 18 and 21 have used illegal gambling websites, highlighting the exposure of vulnerable groups to unregulated operators.
While Belgium’s tightening regulatory approach is aimed at strengthening consumer protection, industry stakeholders have argued that a stricter regulatory environment has inadvertently created conditions that favour illegal competition.
The near-total ban on gambling advertising, combined with restrictions on promotional tools and customer engagement, has reduced licensed operators’ ability to compete for visibility in a crowded digital marketplace.
Meanwhile, illegal operators continue to reach Belgian consumers through offshore marketing channels, often using aggressive and unregulated messaging.
System rethink
As Belgium continues to evaluate its 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 have the opposite of the intended effect,” the association warned.
BAGO is urging the government to strengthen enforcement against illegal operators, including faster blocking measures and tighter oversight of payment channels and digital platforms that provide 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 within the market.
“An effective gambling policy does not protect players by marginalising the legal offer,” BAGO concluded.
“It protects them by reinforcing channelisation towards a strictly regulated and controllable framework.”
