Seven Regulators, One Goal – The 2025 Memorandum of Understanding

For years, offshore gambling operators exploited a fundamental weakness in European regulation: national boundaries. A casino blocked in the UK could continue operating freely in Italy. An operator blacklisted in the Netherlands faced no consequences in Spain. Each regulator fought its own isolated battle against a market that, by definition, recognises no borders. In late 2025, seven regulators decided that was no longer acceptable.

The Memorandum of Understanding signed by the UKGC, Italy’s ADM, Germany’s GGL, the Netherlands’ KSA, France’s ANJ, Spain’s DGOJ, and Portugal’s SRIJ represents the most significant cross-border enforcement coordination the European gambling sector has ever seen. I’ve tracked regulatory cooperation agreements for years, and most amount to little more than diplomatic gestures – handshakes at conferences that produce no operational change. This one is different, because the participants have both the motivation and the mechanisms to make it operational.

UKGC, ADM, GGL, KSA, ANJ, DGOJ, SRIJ – Who’s in the Coalition

The seven signatories aren’t random. They represent the largest and most developed regulated gambling markets in Europe, and each has been fighting the offshore problem independently with varying degrees of success.

The UKGC brings the most developed enforcement infrastructure: URL delisting programmes, cease-and-desist operations, and the Illegal Gambling Taskforce. It tracks more than 1,000 illegal operators and has sent 327,964 URLs to search engines for removal in a single nine-month period. Italy’s ADM manages one of Europe’s strictest ISP-blocking regimes, maintaining a blacklist of thousands of offshore gambling domains that Italian ISPs are required to block. Germany’s GGL, the newest major regulator following the 2021 Interstate Treaty, is still building its enforcement capacity but represents the largest single-country gambling market in continental Europe.

The Dutch KSA has been aggressive in pursuing offshore operators targeting Netherlands-based players, issuing substantial fines and working with payment processors to disrupt transactions. France’s ANJ oversees a market that is heavily restricted – only sports betting and horse racing are legally permitted online, making any casino operation targeting French players inherently illegal. Spain’s DGOJ and Portugal’s SRIJ round out the group, each managing regulated markets with significant offshore exposure.

Together, these seven jurisdictions cover the vast majority of Europe’s online gambling consumer base. An offshore operator that targets any one of these markets now faces the prospect of coordinated action from all seven.

Information Sharing and Joint Enforcement Actions

The practical value of the MoU lies in three areas: intelligence sharing, coordinated enforcement, and regulatory standardisation.

Intelligence sharing is the most immediate benefit. When the UKGC identifies an illegal operator targeting UK players, it can share that intelligence with the other six regulators. If the same operator also targets Italian, Dutch, or German players – which many do, since offshore casinos typically serve multiple markets – the partner regulators can initiate their own enforcement actions simultaneously. An operator that previously faced one regulator at a time now faces the prospect of being targeted across seven jurisdictions in parallel.

Coordinated enforcement multiplies the impact of individual actions. A URL takedown in the UK is useful. The same URL takedown combined with ISP blocking in Italy, payment processor disruption in the Netherlands, and domain seizure coordination across all seven jurisdictions is transformative. The operator’s cost of re-establishing its presence after a coordinated action is dramatically higher than after a single-country intervention.

Regulatory standardisation is a longer-term ambition. Different countries use different definitions of illegal gambling, different thresholds for enforcement action, and different mechanisms for cooperation with payment processors and ISPs. Harmonising these approaches – even partially – makes cross-border enforcement more efficient and reduces the gaps that operators exploit.

The UKGC’s own enforcement data illustrates why coordination matters. Of the 327,964 URLs it flagged between April and December 2025, only 203,571 were actually removed – a 62% success rate. The gap exists partly because search engines and hosting providers operate globally and respond to requests on their own timelines. A coordinated request from seven national regulators carries more weight than one from a single authority, both in terms of political pressure and in terms of the legal frameworks available to compel compliance.

Will the Coalition Reduce Access to Non-GamStop Casinos?

This is the question that matters for anyone who uses or considers using offshore casinos, and the honest answer is: gradually, not immediately.

The MoU creates the framework for coordinated action, but it doesn’t create a single European enforcement agency with binding authority. Each regulator still operates within its own national legal system, with its own powers, limitations, and political pressures. The coalition is a force multiplier, not a replacement for the individual regulators’ capacity.

In the short term – the next 12 to 18 months – the most visible impact will likely be in URL takedowns and payment disruption. Offshore operators whose domains, payment processors, or advertising networks are simultaneously targeted across multiple countries will face higher operational costs and more frequent disruption. Some marginal operators may exit the European market entirely, judging the enforcement risk not worth the revenue.

In the medium term, the coalition could influence how offshore licensing jurisdictions behave. Curaçao, under its new CGA framework, is already tightening standards – rejecting 38% of direct licence applications. If the coalition begins systematically sharing information about operators that hold Curaçao licences while targeting European markets illegally, the CGA faces pressure to revoke or decline those licences. Similar dynamics apply to any jurisdiction whose licensees are repeatedly flagged by the coalition’s members.

The longer-term question is whether coordinated enforcement can actually shrink the offshore market or merely displace it. H2 Gambling Capital’s projection that offshore activity could grow by roughly 110% following the UK’s tax increase reflects economic forces that regulatory coordination alone may not overcome. If the demand side keeps growing – driven by tax-induced cost increases, regulatory friction, and self-excluded players seeking alternatives – the supply side will adapt. Operators will find new jurisdictions, new payment methods, new discovery channels. The coalition makes each adaptation more expensive, but the economic incentive to serve European consumers from offshore remains powerful. The Curaçao LOK reform adds another dimension to this picture, reshaping one of the coalition’s primary targets from the inside.