Finland’s transition to a licensed online gambling regime could accelerate black market growth unless regulators take an active role in enforcement and consumer guidance, Regulus Partners has warned.
Legislation regulating online gambling in Finland was passed in December, with the market opening to licensed operators in July 2027, bringing an end to one of Europe’s last major monopoly markets.
While much of the legislative and fiscal framework is already defined, Regulus said in a note released today (19 January) that “many regulatory questions remain open, potentially leaving the back door as well as the front door open to black market revenue”.
Regulus and advisory firm EGARA estimate the Finnish online gambling market was worth around €1.1bn in 2025, making it one of the largest in Europe on a per-capita basis.
Online spend per head was estimated at €185, compared with €132 in Sweden, €118 in Denmark and €127 in the UK (all figures excluding lottery and black market activity).
Gaming accounted for 76% of online GGR, compared with 55% in Sweden, 70% in Denmark and 66% in the UK.
Finland’s historically limited black market and cultural factors such as colder, darker winters driving digital activity were cited as reasons for the higher spend.
Regulus said there were “two clear channelling positives” within the proposed framework: no explicit restrictions on the number of operators that will join the market in 2027 and a 22% GGR tax rate.
“While GGR taxes are far less efficient than net revenue taxes because they tax non-cash bonuses, a rate of 22% has been shown to be only marginally distortive in plenty of markets,” the firm noted.
However, two legislated measures were flagged as major concerns. The first was the ban on welcome bonuses, with incentives limited to loyalty rewards.
Regulus stated this “is the opposite to what Finnish gamblers have come to expect over 30 years of exposure”, warning that the policy may benefit “the black market rather than tier-one operators and high-quality challengers”.
The higher propensity of gaming players is also significant here as these customers “tend to seek out more bonuses, expect more varied content, deposit more and use more accounts than betting-led customers”.
The second concern surrounded the “highly restrictive” advertising regime, including a complete ban on affiliate marketing.
Taken together, Regulus argued these restrictions meant “the back door is left open for the black market to recruit Finnish customers at will in a tried and tested way”.
The analysts stressed the need for “visible and strict enforcement against unlicensed operators and the supply chain which provides platforms, payments, content and visibility”.
“If third-party acquisition channels are restricted, then the state and regulator must play a much more active role in guiding consumers,” Regulus wrote.
“It would be relevant to create both a public register of licensed operators and black market register of anyone detected to target the market and take traffic without a local licence and consumer-facing education material supporting player education of gambling with licensed providers.”
The analyst firm also warned against secondary legislation that introduces additional friction, calling for rules that avoid “counterproductive” measures such as restrictive game mechanics, slow onboarding and blanket affordability limits.
Citing lessons from the German market, Regulus noted that when high-value gaming customers face multiple frictions, many “simply migrate to higher-risk offshore alternatives that offer familiar products with fewer obstacles”.
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Analysts suggest ban on welcome bonuses and affiliate marketing risks pushing consumers to unlicensed operators
The post Finnish framework “leaves back door open” for black market firms, says Regulus first appeared on EGR Intel.