Poland Needs a More Effective Model to Fight Illegal Online Gambling

LAWPoland Needs a More Effective Model to Fight Illegal Online Gambling

The illegal online gambling market in Poland may pose a greater threat to citizens than some of the country’s most widely discussed financial scandals, warned participants of a debate held during the European Economic Congress in Katowice.

“Today, the whole of Poland is focused on the scandal involving a certain cryptocurrency exchange. Everyone is concerned that Poles may not recover funds worth more than PLN 1 billion. Here, however, we are talking about PLN 15 billion paid last year to illegal gambling operators. We are simply waiting for the moment when that scandal turns out to be relatively small compared with what could happen on the online gambling market,” said Marek Skrzyński, President of the Bukmacherzy Razem Association.

A systemic problem

Panel participants agreed that the grey market is no longer a marginal phenomenon and has become a systemic issue.

“For every legal online casino in Poland, there are more than 6,000 illegal websites. These are real figures as of today. More than 3 million people use such services every year, including several hundred thousand teenagers. The grey market generates enormous risks: addiction, loss of money, lack of player protection, and the fact that our data is transferred outside Poland and used unlawfully,” said Zdzisław Kostrubała, President of the Graj Legalnie Association.

The state is losing control

The effectiveness of state action was one of the recurring themes of the debate.

“Today we have a situation in which the state has accepted a reality where the grey market accounts for around 20% of betting and around 40% of online casinos. Whenever we ask what is being done about it, the answer is always the same: nothing. The ministry is not working on any solutions, and that is truly frightening,” Skrzyński stressed.

According to him, the lack of response may eventually lead to legal operators losing the market entirely.

Monopoly and market reality

Experts also pointed to the limitations of the current regulatory model.

“From the perspective of competition theory, a state monopoly is not the best solution. It was introduced for specific reasons: consumer protection and the public interest. But looking at what is happening today, it is clear that these goals are not being fully achieved. In 2016, the state promised that funds would be allocated to fighting the grey market and protecting players. Today we can see that reality has diverged from those assumptions,” said Professor Aleksander Werner from the SGH Warsaw School of Economics.

Professor Artur Nowak-Far also drew attention to the legal framework.

“European Union law allows a monopoly, but only if specific objectives are pursued. The key goals are protecting players from addiction and from criminal activity. Any regulatory changes must be justified by raising the standard of protection, not solely by fiscal considerations,” he said.

Denmark: from monopoly to effective regulation

One of the key points of reference in the debate was the experience of Denmark, which moved from a monopoly model to a licensing system.

Birgitte Sand, former head of the Danish gambling regulator, stressed that the decision to change the system was a response to the growing scale of the illegal market.

“We had a very similar situation. There was a monopoly, but at the same time we saw growing activity from illegal operators targeting our citizens. The problem was that we did not give those companies a chance to operate legally. They wanted to be licensed, but they had no such option, so they operated outside the system,” she explained.

According to Sand, the breakthrough came with the opening of the market.

“The most important step was that we opened online casinos under a licensing system. Before the change, the level of channelisation was very low. Just one year after the new regulations were introduced, it increased significantly because companies began applying for licences and operating legally. Today we have a much higher level of control over the market than before,” she said.

Sand also emphasised the importance of cooperation between the state and the market.

“Operators that choose a licence, pay taxes and comply with regulations can be our strongest tool in the fight against the grey market. We cannot do this alone as an administration; we have to work with the entire ecosystem,” she said.

She also pointed to the changing technological environment.

“The world has changed. We have cryptocurrencies, social media and new technologies. We cannot regulate the market in the same way as 10 or 20 years ago,” Sand added.

H2 Gambling Capital report: hard data

The conclusions from the debate were supported by data presented at the congress in a report by H2 Gambling Capital, one of the global leaders in gambling market analysis.

According to the report, the turnover of Poland’s online gambling grey market reaches around PLN 74 billion annually, while the illegal market generated nearly PLN 3 billion in gross revenue in 2025.

“The results of the report leave no room for doubt: the scale of the online gambling grey market in Poland has reached a level that can no longer be downplayed. We are talking about tens of billions of zlotys outside the system, outside taxation, outside state supervision and outside player protection mechanisms,” said Adam Lamentowicz, President of the Polish Chamber of Commerce of the Entertainment and Bookmaking Industry.

As he stressed, this is not only a sectoral issue.

“This is not an industry problem. It is an economic, fiscal and social problem. Every zloty spent on an illegal service is a loss for the state budget, honest entrepreneurs and the entire system,” Lamentowicz said.

Ed Birkin of H2 Gambling Capital pointed to the structural nature of the problem.

“Our analysis shows that a significant part of consumer activity still takes place outside the licensing system. This means that the current regulatory mechanisms are not fully effective in directing players to the legal market. International comparisons clearly show that the highest effectiveness is achieved by systems based on a competitive licensing model and properly designed regulations,” he said.

“Without significant regulatory changes, it will be difficult for Poland to reach the levels of market legalisation seen in the most effective European jurisdictions,” Birkin added.

Check out our other content
Related Articles
The Latest Articles