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The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.

The DOCV, another trade body representing licensed online casino operators in Germany, also expressed support for the prosecutorial efforts. However, it emphasised that the raid exposed regulatory gaps which had allowed organised crime to flourish.

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%.

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The Loterij suggested around 200,000 Dutch citizens already engage with unauthorised platforms.

Earlier this summer, the Dutch Online Gaming Providers (VNLOK) trade body initiated legal action against Meta and lodged a formal complaint with the European Commission, accusing the social media giant of failing to prevent the widespread display of illegal online gambling advertisements targeting Dutch users on Facebook and Instagram. 

According to VNLOK, the illegal online gambling market in the Netherlands now matches the size of the regulated sector, with estimated annual revenues in excess of €1 billion ($1.1 billion).