What began years ago as a system based primarily on domain blacklists has evolved into a multi-layered enforcement strategy targeting not only offshore operators, but also payment institutions, social-media influencers and even the legislative grey zones surrounding digital products such as loot boxes. 

A growing market and a persistent shadow 

The timing is not accidental. Poland’s regulated gambling sector is expanding rapidly. In 2024, sports betting gross gaming revenue (GGR) reached approximately €900m ($1.06bn), with growth of around 25% year-on-year and a channelisation rate of roughly 75-80%. At the same time, the online casino segment remains structurally constrained by the state monopoly held by 

Totalizator Sportowy. 

Despite significant investment in its Total Casino platform, channelisation in the online casino vertical is estimated at only around 60%. Approximately 1.2 million Polish players continue to use offshore sites, and the annual turnover of illegal online gambling has been estimated at PLN 65bn – a figure that nearly matches the legal market. 
Against this backdrop, enforcement has become not only a matter of consumer protection, but also of economic necessity. 

Payments: Cutting off the oxygen 

One of the most consequential shifts has occurred in the financial layer of the ecosystem. Payment service providers (PSPs) are under increasing pressure to treat gambling-related flows to unlicensed operators as high-risk transactions under AML and CTF rules. 

The Polish Financial Supervision 

Authority (UKNF) recently issued sector-wide communications urging PSPs to verify and block payment flows to offshore casinos. The practical impact was immediate. Popular payment methods, including BLIK used by approximately 80% of customers of licensed operators began disappearing from illegal sites. 

This development is operationally significant. Offshore casinos can rotate domains within hours, but rebuilding disrupted payment infrastructure is far more complex. By shifting enforcement from static domain blocking to dynamic financial supervision, Poland has targeted the grey market’s most sensitive pressure point.
 
The monopoly defends its territory 

The political narrative accompanying these measures is increasingly explicit. Public statements by government representatives and interviews with executives of Totalizator Sportowy have emphasised the need to preserve the state monopoly on online casino as a tool to “protect society” and to ensure tax integrity. 

At the same time, Totalizator has openly sought broader promotional powers and a stronger institutional position in order to compete more effectively with offshore brands. The argument is straightforward: without advertising flexibility and robust enforcement against illegal operators, the monopoly cannot achieve higher channelisation. 

Yet this is also a fight for market share. With approximately 40% of the online casino segment still outside the regulated offer, enforcement improvements directly translate into revenue gains for the monopoly. The current offensive therefore serves a dual purpose: combating illegal gambling and reinforcing the commercial viability of the state operator. Whether this strategy will ultimately succeed remains uncertain. Grey-market operators are adaptive, technologically agile and well-funded. The battle is ongoing and its outcome is far from predetermined. 

Influencers: From affiliate to defendant 

Perhaps the most visible escalation has been directed at influencers promoting illegal casinos. Coordinated early-morning arrests and searches of high-profile streamers marked the first enforcement wave of this scale against the social-media layer of the grey market. The authorities have clearly signalled that influencer marketing is no longer peripheral and it is now treated as part of the illegal gambling infrastructure. 

This reflects broader global trends. Studies on influencer marketing in gambling indicate that younger audiences are particularly responsive to live-streamed casino content, and affiliate-driven acquisition models are increasingly shaped by creator personalities rather than traditional advertising channels. 

At the EU level, organisations such as EGBA have begun developing responsible influencer marketing standards. Meanwhile, industry analyses show that influencers are reshaping the affiliate sector, often operating in legal grey zones that blur the distinction between entertainment and commercial promotion. 

Poland’s response has been punitive. Proposed amendments to the Criminal Code would explicitly criminalise the presentation or promotion of gambling games conducted in breach of the Gambling Act. The legislative intent is to extend liability beyond operators to those amplifying them. 

Hire them instead of arresting them 

There is no doubt that so-called “patostreamers” promoting illegal gambling can cause real harm. But an exclusively punitive strategy may not be the most effective long-term response. 

The influencer landscape is not homogeneous. Some creators knowingly and repeatedly violate the law. Others operate in legal grey areas without a clear understanding of regulatory boundaries. Treating both groups identically risks missing an opportunity. Strong criminal enforcement should be reserved for persistent and fully aware offenders. In parallel, there is room for a structured educational approach aimed at those who lack legal awareness rather than intent. 

A targeted information campaign, developed with the participation of influencers themselves, could prove far more effective than relying solely on high-profile arrests. The state tend to focus their messaging on mainstream celebrities and professional athletes. Meanwhile, a vast segment of the internet ecosystem remains largely invisible to traditional media. Creators active on YouTube, TikTok and Instagram often command enormous reach among younger audiences, precisely the demographic most likely to engage with online gambling content. 

If responsible gambling messaging is to be credible and effective, it must reach these audiences where they actually consume content. That means explaining clearly what is legal and what is not, what consumer protections exist in the regulated market, and what risks accompany offshore platforms. In a digital environment where authenticity drives engagement, influencers who understand the rules and communicate them transparently could become part of the solution rather than remaining permanently framed as part of the problem. 

Legislative activism with gaps 

Parallel to enforcement, Poland is witnessing an intense wave of legislative initiatives. Draft amendments address issues ranging from loot boxes to criminal liability for illegal gambling promotion. The Ministry of Finance has created a dedicated Department for Gambling Market Regulation and an Inter-Ministerial Team for Countering the Grey Zone. These developments indicate institutional maturity and seriousness of purpose. 

However, there is growing concern within the industry that several proposals are being advanced without sufficiently broad expert consultation. Some draft provisions contain vague definitions, especially regarding digital content and promotional activity. Legal imprecision may create compliance uncertainty not only for illegal actors, but also for legitimate operators and media platforms. 

Overly broad criminal provisions can produce chilling effects, while failing to address the structural economic drivers of the grey market. Without aligning regulatory design with market realities, enforcement alone may not achieve sustainable channelisation gains. 

A war still in progress 

Poland’s strategy is ambitious and increasingly coordinated. Financial supervision, criminal enforcement, institutional reform and legislative activism are now aligned around shrinking the grey market and strengthening the regulated sector, particularly the state monopoly in online casino. 

Yet this is not a settled victory. Offshore operators continue to adapt. Political polarisation complicates major structural reform, including long-discussed changes to the 12% turnover tax on betting and the future of the monopoly model. 

The current offensive represents a decisive chapter, but not the end of the story. It is, in essence, a struggle over who controls Poland’s €900m+ online gambling economy and the tens of billions of PLN still circulating outside the regulated framework. Whether the monopoly can defend its position in the long run or whether structural reform will eventually become unavoidable remains one of the most consequential questions for the Polish market in the coming years.