At first glance, the latest figures published by the Belgian Gaming Commission may appear reassuring. In 2025, Belgium’s licensed gambling market remained virtually stable, recording a slight decline of 0.07% to €1.62bn in gross gaming revenue (GGR).
It might therefore be tempting to conclude the market has reached a ceiling. But that would probably be premature. Behind this apparent stability lies a much deeper shift in the behaviour of Belgian players. Gambling is not disappearing. It is moving elsewhere.
The licensed land-based market declined by more than 7% in 2025, while the licensed online market grew by a further 5.4%. Online activity now accounts for almost 60% of Belgium’s regulated market.
In my role, at the intersection of product, technology and operations, I find this development particularly revealing. Digitalisation does not simply change the channel used by players. It transforms how they discover, access and compare offerings, and how they move from one platform to another.
Licensed and illegal offerings now coexist within the same digital environment. For players, the distinction is not always immediately apparent, while the distance between a licensed platform and an illegal site may be no more than a search or a few clicks.
More concerningly, legislative developments in recent years have significantly reduced the visibility and attractiveness of licensed operators through the near-total disappearance of advertising, the separation of websites according to product categories, and restrictions on bonuses. Illegal operators, by definition, comply with none of these constraints.
This asymmetry is critical. In a digital market, visibility, accessibility and a frictionless player journey directly influence channelisation. Any restriction applied solely to the regulated journey may therefore affect the market’s ability to keep players within a protected environment.
Scale of the issue
According to a study by the Belgian Gaming Commission, 28% of the young adults aged between 18 and 30 said they had already gambled on an illegal site. Other studies published in Belgium estimate that almost a quarter of online gambling expenditure may now fall outside the licensed market.
More concerning still, a significant proportion of players registered with EPIS (Belgium’s self-exclusion scheme), and therefore theoretically excluded from licensed venues and websites, reportedly continue to gamble with illegal operators.
This is probably where the main challenge for Belgian gambling policy will lie in the years ahead. Regulation can only genuinely protect players while they remain within the regulated system. A licensed site knows the identity and age of its customers. It must apply EPIS, comply with the limits imposed by law and meet the requirements of the Belgian Gaming Commission. An illegal site does none of these things.
For product and technology professionals, the consequence is very tangible. Identification tools, behavioural analysis, detection mechanisms and player protection interventions can only work while players remain within the regulated ecosystem. As soon as a player leaves it, that ability to understand and intervene disappears.
We must therefore avoid a paradox: building one of Europe’s strictest regulatory environments while progressively allowing some players to migrate to platforms over which the Belgian authorities have no control.
The number of sites involved shows that this is no longer a marginal issue. In 2025, the Belgian Gaming Commission asked Meta to remove more than 8,500 advertisements from illegal operators that were misusing the names or visual identities of licensed Belgian operators. Since the beginning of that same year, 370 new sites have been added to its blacklist.
Faced with this acceleration, the regulator’s current resources appear insufficient to absorb the volume of work. Its secretariat had 42 employees at the end of 2025, compared with 57 positions provided for in its staffing plan. The report also highlights the difficulties involved in collecting fines when illegal operators are based abroad or conceal their identities.
This question of capacity is central. No matter how demanding a regulatory framework may be, it can only fully achieve its objectives if the authority responsible for enforcing it has the resources, expertise and tools required to keep pace with the digital market.
The debate should therefore no longer focus exclusively on whether licensed operators should be subject to more or less regulation. The real question has become: how do we keep players within the regulated market?
This will clearly require much more effective action against illegal operators, including website blocking, restrictions on their payment channels, and cooperation with banks, social media platforms, search engines and internet service providers. But it also requires preserving a licensed offering that is sufficiently attractive and visible to provide a genuine alternative.
This is not about choosing between protection and attractiveness. In a regulated market, the two are inseparable: an offering can only protect players if it remains identifiable, accessible and capable of meeting their expectations. Channelisation is therefore not a secondary commercial objective. It is a prerequisite for an effective player protection policy.
Every player who leaves the licensed market is not necessarily a player who stops gambling. They may simply become a player we can no longer see. And that is probably the greatest risk today: mistaking a decline in the market we can measure for a genuine decline in gambling activity in Belgium. What we can no longer measure has not necessarily disappeared. It may simply have moved beyond our control.
Jean-Christophe Choffray is chief vision and product officer at GAMING1, a Belgian gaming and technology group active in regulated European markets. Since 2005, he has contributed to the evolution of Belgium’s legal and regulatory framework for gaming and betting, advising both public and private organisations. His experience combines product vision, technology, operations and regulation across several European markets, with a strong focus on responsible gaming and sustainable business models.
The post GAMING1: What the apparent stability of Belgium’s channelisation fails to reveal first appeared on EGR Intel.
Chief vision and product officer Jean-Christophe Choffray examines the gradual migration of players towards the illegal market and why every player who leaves the licensed arena has not necessarily stopped gambling
The post GAMING1: What the apparent stability of Belgium’s channelisation fails to reveal first appeared on EGR Intel.