Study finds black market gambling data holds too many weak assumptions
European and Nordic authorities require an expanded capacity and greater regulatory coordination to understand the black market on online gambling, an academic review claims.
This advice leads the findings of a ‘scoping review’ published in PLOS One, noting that current efforts to measure the size and scope of offshore gambling markets across Nordic jurisdictions are marred by data gaps, unclear methodologies that can lead to political fallouts.
Conducted by researchers from universities and public health institutes in Finland, Denmark, Sweden, and Norway, the review covered 32 studies between 2010 and 2024.
As independent researchers, the team found that “there is no gold standard or one reliable method to conclusively measure offshore gambling.”
Instead, the authors conclude that “methodological choices, data resources that have been used, and political interests can have an effect on the kinds of estimates that are produced.”
The report observes that most estimates, whether reported by governments, regulators, or industry groups, are derived from a single source.
This source is H2 Gambling Capital, a private data provider widely cited by the regulated industry, but which the Nordic academics believe has limited transparency.
“A significant part of studies included in this review made use of data from H2 gambling capital,” the authors write, “even regulators are not fully aware of metrics and assumptions based on which these estimates are made.”
The study’s authors — Virve Marionneau (University of Helsinki), Søren Kristiansen (Aalborg University), Tomi Roukka (Finnish Institute for Health and Welfare), and Håkan Wall (Karolinska Institute) — observe that offshore gambling is “a politically sensitive topic wrought with uncertainties.”
Academics question offshore argument
The problem is not merely academic. The study observed that “offshore estimates are likely to be political tools.”
The authors highlight how the gambling industry, in particular, has “actively attempted to control the narrative over channelling rates within the Nordic countries,” often by releasing their own studies showing rising offshore participation to resist tighter regulation.
One Swedish report included in the review assumed that users of unlicensed websites spend 10–20 times more than those on legal platforms — a bold figure for which the researchers found “no empirical basis nor conclusive descriptions on how these were determined.”
Such assumptions, the authors suggest, can significantly skew perceptions of the so-called black market, inflating its threat.
“Industry-produced estimates of offshore gambling may be higher than government-produced figures,” the authors write.
They note that “these estimates diverged from governmental estimates” due in part to differing methodologies, and caution against letting such figures shape policy uncritically.
“Evidence-based policy should not be based on methodologically ambiguous evidence or estimates that lack transparency.”
The researchers also warn against viewing offshore and onshore markets as entirely distinct. “Offshore gambling is therefore not a separate market segment from onshore gambling,” the report explains.
A large portion of users participate in both. In Finland, for instance, “98% of individuals reporting offshore gambling also gamble within the regulated market,” with around 37% of their total gambling spending still occurring onshore.
Product types also matter. “Offshore consumption typically consists of the most harmful gambling products, including fast-paced online casino products and betting (including live betting),” the authors write, adding that these activities are overrepresented in gambling harm statistics.
More light needed on black market
The academics note that the mere presence of the fast-paced products discussed above on black market platforms has frequently been used to justify their availability within regulated systems — despite the risks being the same.
In terms of solutions, the research team makes several modest but clear recommendations. Chief among them is the need for “a transparent and scientifically validated measurement tool” to improve the evidence base.
They urge a “multi-method analysis,” combining population surveys, transaction data, and other indicators, including help-seeking statistics. Bank data, while legally sensitive, “could provide additional insight,” the report says, and could be technically feasible given the existing role of banks in payment blocking systems.
Ultimately, the report delivers a sober message: the offshore gambling debate is currently shaped more by assumptions than evidence.
“Despite the political importance of channeling,” the authors note, “it is surprisingly unclear how and if we can measure developments in the unregulated market.”
Until that changes, European regulators may continue to base major decisions on data that is partial, outdated—or simply invented.