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In an era where sustainability is king and politics is hostile, European gambling’s top execs are wise to advertise their ESG credentials, but say they fear an emboldened black market is undoing their good work.

This month, the European Gambling and Betting Association (EGBA) published its , which promotes the socially-driven good works of several of the largest global gambling companies.

In a letter published alongside the report and signed by the CEOs of gambling giants like Flutter, bet365, Entain and evoke, the industry leaders say their sustainability efforts are being undermined by regulations that play into the hands of the black market.

“While we continue to invest significantly in responsible play and compliance, unregulated, untaxed black market operators, based outside Europe, are thriving across the continent,” they said.

“These operators target vulnerable players with unlimited access and significant bonuses, offer no customer protections or support for struggling players, and don’t contribute to public finances or European sports.”

The CEOs specifically called out the Netherlands and its recently introduced affordability regime as an example of lawmakers overstepping the mark.

Evidence suggests that revenues for online casino operators suffered a serious decline after the new rules were introduced, which set hard deposit limits that can only be lifted if an operator investigates a player’s spending power.

The CEO letter called the policy “well-intentioned” but said it was driving at-risk gamblers to the black market.

The Dutch regulator, the KSA, said it is happy with its affordability regime so far, having seen a decrease in deposits with licensed operators since its introduction.

The group of high-powered gambling executives said they are not calling for less regulation, but smarter policies instead that are “evidence-based and behaviourally informed to channel players toward the safer, regulated environment — not away from it”.

In a message to their supplier partners, the operator CEOs also called for industry stakeholders to only work with and promote licensed gambling companies.

The members of the trade group said they paid €3.8bn in taxes to European economies last year and sent 100m safer gambling messages to their players, an increase of 48 percent over 2023.

These communications are having an effect, the EGBA said, with 42-46 percent of high-risk customers taking positive steps to rein in their gambling after receiving them.

“Our data shows that in the overwhelming majority of cases where a customer receives an intervention, the intervention is received positively and the customer amends their behaviour accordingly,” said Sheila Preston, chief regulatory officer at bet365.

The EGBA’s members - which also include Betsson, FDJ United, Superbet and MGM-owned LeoVegas - said they donated €156.8m

The report comes as the EU is increasing its demands on companies to prove their sustainability credentials.

The Corporate Sustainability Reporting Directive is now in force and this financial year sees a host of gambling companies required to report on their ESG activities or face fines.

The number of companies in scope and the range of company activities that need to be reported on are set to increase over the next few years.

The industry’s warnings about the black market also come at a time when gambling’s political fortunes are at a low ebb across the continent.

In the Netherlands, where the CEOs highlighted what they see as egregious regulations, there is vanishingly little political support for anything other than ramping up restrictions on the licensed sector.

And in markets from the UK to Romania, there are calls to raise gambling taxes as governments grapple with post-COVID budget shortfalls and a chaotic trade environment driven by US tariffs.

On safer gambling, the EGBA hopes to drive at least part of the conversation next year, as the European project to create a unified set of markers of harm continues.

Initiated at the behest of the trade group, the European Committee for Standardisation has been working on a standardised list of triggers which gambling companies can use to identify gamblers at risk of harm.

It is hoped that regulators across the continent, and potentially beyond, will unify some areas of their regulations once the standards are released.

The EGBA said it expects the project will be completed in early 2026.