Balkan Gaming Federation exclusive: Healthy legal market and consumer protection are not competing objectives

In March, industry associations from across the Balkans united to launch the Balkan Gaming Federation (BGF), signing a Memorandum of Cooperation at a ceremony in Belgrade. The initiative comes at a time when the industry across the region is facing increasingly restrictive legislation, rising levels of illegal activity and a lack of coordinated responses to key regulatory challenges. 

The BGF has since confirmed Croatia as its official headquarters. Preparations are underway for a regional roundtable on illegal gambling, which will bring together the BGF, European Gaming and Amusement Federation, industry stakeholders, experts and regulators. 

Global Gaming Insider caught up with BGF representative Miloš Lalević to discuss the goals of the new federation and its plans to tackle illegal gambling in the region. 

As illegal gambling is a central focus for the association, how do you assess the current scale of the illegal gambling market across the Balkans and where are the most significant pressure points?  

For several years now, many Balkan countries have been pursuing increasingly stringent and complex regulatory approaches to gambling. While the intention is often to enhance oversight and player protection, the cumulative effect of these measures has, in many cases, made the legal market significantly more challenging to operate in. As a result, the region is now facing a situation where an overly demanding regulatory environment has contributed to the expansion of illegal gambling. 

When compliance costs rise, operational flexibility decreases and legal operators face growing administrative burdens, unlicensed operators are quick to exploit the resulting market gaps. It is important to emphasise that virtually every country in the Balkans, without exception, is facing this challenge to a greater or lesser extent.  Estimates and industry assessments indicate that the share of the black market can range from approximately 20% to as much as 40% of total gambling activity in certain Balkan jurisdictions.  

The key policy challenge is therefore to strike the right balance between robust regulation and a sustainable legal market. Without that balance, the illegal sector will continue to expand, undermining consumer protection and reducing public revenues. 

How reliable is current data on illegal gambling in the region? 

The reliability of data on illegal gambling has improved dramatically in recent years. A decade ago, most estimates were based largely on surveys, enforcement records and fragmented market intelligence. Today, the industry has access to significantly more sophisticated tools that enable much more accurate monitoring and analysis. 

Modern detection systems increasingly rely on artificial intelligence, machine learning, automated web crawling, network analysis, payment intelligence and digital advertising monitoring. These technologies make it possible to identify illegal operators, track their activity across multiple channels and estimate their market presence with a level of precision previously impossible. Machine learning models can also identify previously unknown entities based on similarities in infrastructure, payment processing, content distribution and marketing behaviour. 

While no methodology can claim 100% accuracy when analysing an inherently hidden market, the level of confidence in modern market estimates is significantly higher than it was only a few years ago. The conversation has moved beyond guesswork. For policymakers and regulators, this represents an important shift. Decisions can increasingly be based on measurable evidence rather than assumptions. The challenge is no longer the absence of data, it is ensuring that regulators, governments and industry stakeholders make effective use of the information that is now available. 

The industry argues that legal operators are under increasing regulatory and financial pressure. Do you believe policymakers fully understand the impact of current policies on both market health and channelisation?  

That concern is certainly valid. Across much of the region, regulatory and financial obligations imposed on licensed operators have been increasing continuously, often without sufficiently comprehensive impact assessments of how these measures affect the sustainability and competitiveness of the legal market. 

I fully understand the position of governments and their legitimate interest in ensuring strong regulatory oversight and generating public revenue from the gambling sector. However, regulation can only be effective when it strikes the right balance between the state's objectives and the economic realities faced by licensed operators. 

In my view, that balance is not always being achieved. For channelisation to be successful, policymakers must recognise that a strong and competitive legal market is not in conflict with public policy objectives, it is a prerequisite for achieving them.   

Do you expect any tangible policy recommendations or enforcement initiatives to emerge from the planned regional roundtable on illegal gambling? 

One of our primary objectives is to raise public and institutional awareness of the challenges currently facing licensed operators across the region. Too often, discussions around gambling regulation focus exclusively on restrictions and fiscal measures, while insufficient attention is given to the sustainability of the regulated market and its role in protecting consumers from illegal operators. 

I see the regional roundtable as an important platform for bringing together industry representatives, regulators, policymakers and enforcement authorities to openly discuss these issues and clearly articulate the key priorities that require attention. It is an opportunity to present evidence-based recommendations and demonstrate why a strong, competitive, and well-regulated legal market is the most effective tool in combating illegal gambling. 

Our ambition is for the event to be much more than a formal gathering. We want it to produce concrete conclusions, actionable policy recommendations and a clear roadmap for future cooperation. Equally important, we intend to establish mechanisms for monitoring the implementation of those conclusions. A dedicated team within the BGF will be tasked with following up on agreed initiatives, engaging with relevant stakeholders and tracking progress to ensure that the outcomes of the roundtable translate into tangible results rather than remaining merely a matter of discussion. 

How feasible do you think it is to achieve effective coordinated enforcement across Balkan jurisdictions in practice? 

I believe it is both feasible and necessary. Illegal gambling operators do not recognise national borders, which means that isolated enforcement efforts are often insufficient.  

While regulatory frameworks may differ across Balkan jurisdictions, our experience shows that the vast majority of challenges are shared. This common ground creates a strong foundation for effective regional cooperation and makes coordinated action much more achievable. 

I also see this initiative as an opportunity to help reshape the broader perception of the gambling industry in the Balkans. By promoting constructive dialogue, responsible regulation and a shared commitment to combating illegal gambling, we can demonstrate that a well-regulated legal market is not part of the problem, but an essential part of the solution.  

What role will  European Gaming and Amusement Federation (Euromat) play in supporting the federation’s regional initiatives?  

Euromat brings decades of experience in representing the regulated gaming sector before European institutions and engaging with policymakers. One area where Euromat can provide substantial support is knowledge sharing. Across Europe, there are already successful examples of payment blocking, advertising enforcement, digital monitoring and cooperation between regulators and industry stakeholders. The Federation will be able to draw upon these experiences rather than starting from scratch. 

Particular importance will be placed on emerging digital legislation, including the European Union’s Digital Services Act (DSA). The DSA creates new opportunities to tackle illegal gambling through faster content removal mechanisms, enhanced cooperation with online platforms and the potential use of trusted flagger frameworks. Euromat's experience in these discussions can help the Federation and its members better understand and utilise these tools in practice.  

Finally, Euromat can help ensure that the voice of the Balkan regionis heard within wider European debates. It provides an established platform for communicating concerns to European stakeholders and institutions. 

Beyond the planned roundtable and efforts to combat illegal gambling, what other initiatives can the industry expect from the BGF in the coming years?  

One of our key messages will be that every state should strive to create an attractive and sustainable legal gambling market.  Creating the conditions for licensed operators to operate sustainably is essential because the legal market is the state's natural partner in addressing many of the challenges associated with gambling, including consumer protection, responsible gambling, anti-money laundering measures and the prevention of underage gambling.  

In practical terms, this means developing balanced regulatory frameworks, conducting thorough impact assessments before introducing new obligations, ensuring proportionate taxation and fostering regular dialogue between regulators and the industry. It also means investing in modern monitoring tools, cross-border cooperation and public awareness initiatives that encourage consumers to choose licensed operators. 

Our position is simple: a healthy legal market and strong consumer protection are not competing objectives - they are mutually reinforcing.  

Are there any additional messages you would like to get across to our readers? 

I would like to emphasise one final point: the gambling industry should not be viewed solely through the lens of regulation and taxation. When properly regulated, it is an industry that creates jobs, drives investment and contributes significant public revenues. 

The future of the sector in the Balkans will depend on our ability to move beyond fragmented national approaches and build a culture of cooperation, dialogue and evidence-based policymaking. The challenges we face are largely the same across the region, and so are the opportunities. 

The BGF was established with the belief that our industry is strongest when it speaks with a united voice. We are committed to being a constructive partner to regulators and policymakers.