The scale of the illegal gambling market is difficult to overstate. A report from Gaming Compliance International (GCI) published in May 2026 estimated that unregulated online gambling reached $5.9trn in global wagering value in 2025 – a figure the firm likened to the world’s third-largest economy. 

While that number reflects total handle rather than gross gaming revenue, the underlying picture is stark: unregulated operators seemingly account for about 78% of global online gaming GGR, with licensed platforms making up just 22%. In the EU specifically, research commissioned by the European Casino Association found that illegal operators generated approximately €80.6bn in revenue in 2024 alone, representing 71% of total EU gambling market turnover.

But the black market, historically, has created an even bigger battle for the industry to fight in Asia. For licensed operators and regulators, the implications are significant – not only in terms of lost tax revenue and market share, but in the very real consumer protection failures that illegal platforms represent. Unlicensed sites operate without the safeguards that regulated markets mandate: no age verification, no responsible gambling tools, no AML oversight and no recourse for players in the event of a dispute.

It is against this backdrop that a new question has begun to surface: should suppliers – the game developers, platform providers and technology companies that power the online gambling ecosystem – bear greater responsibility for ensuring their products do not end up in illegal hands?

The catalyst: Evolution and the Gambling Commission

The debate was crystallised in late 2024, when the Gambling Commission (GC) opened a formal review of Evolution’s UK operating licence after identifying that the supplier’s games were accessible to British consumers via operators that did not hold a GC licence. It was, by most accounts, the first time a B2B supplier had been formally placed under review by a major regulator for the downstream activities of its clients.

The review prompted Evolution’s CEO, Martin Carlesund, to state publicly that the company was “committed to support the licensed UK market as well as preventing unlicensed traffic” and that it was taking “forceful action using all technical tools available” to ensure its games were only accessible through licensed operators in Great Britain. Crucially, Evolution also moved swiftly to remove its content from the flagged unlicensed platforms. The matter, at least in the immediate term, appeared to demonstrate that suppliers can act decisively when the regulatory pressure is sufficient.

The GC’s own position had been building throughout the year. Speaking at the Commission’s annual CEO briefing in November 2024, (now departed) CEO Andrew Rhodes told licensed operators to conduct due diligence on their supplier partners, stating that the Commission’s strategy on combating illegal gambling was to “cause as much upstream disruption as we can – which is why we have focused on ISPs, payment providers, search engines, software suppliers and more.” The message was unambiguous: the regulator was extending its line of sight further up the supply chain. Last month, the Evolution case was concluded, as the supplier agreed a £4.75m ($6.4m) settlement with the UK regulator.

Greater supplier responsibility

The argument for holding suppliers to a higher standard rests on several interconnected points. The first and most straightforward is commercial proximity. Suppliers are not passive bystanders in the gambling ecosystem; they are active participants whose technology and content make online gambling possible. 

When an unlicensed operator runs a live casino or slots product built on a licensed supplier’s IP, that supplier is – whether by design or negligence – enabling an activity that undermines the very regulatory framework it ostensibly operates within. As Rhodes put it plainly: “I do not understand why anyone in the licensed industry would want to be in business with a company that is supporting illegal competition – it makes no sense to me at all.”

The second argument is technical capability. Unlike regulators, who must work through slow-moving legal and enforcement processes, suppliers have direct contractual and technical relationships with operators. As the Evolution case demonstrated, a supplier can, in principle, remotely disable its products on unlicensed platforms relatively quickly. That technical leverage is something regulators simply do not have – which makes suppliers unusually powerful actors in the enforcement chain.

The third is competitive integrity. Illegal operators carry none of the costs of the licensed market – no taxes, no licensing fees, no compliance overhead – allowing them to offer better odds and promotions than legitimate rivals. Suppliers that enable those operators are, in effect, subsidising the competition of their own clients. 

In fact, the Betting and Gaming Council (BGC), whose membership includes supplier companies, has made clear that its members are committed to avoiding partnerships with entities linked to unlicensed operations. The commercial logic, the BGC implies, should align with the regulatory one. A growing number of regulators are now enshrining these expectations in formal frameworks. 

The GC, for example, has introduced a ‘Jurisdiction Explanation Document’ requiring B2B licence applicants to disclose their due diligence criteria for selecting third-party partners, the contractual restrictions they place on resellers around territorial access, and the technological safeguards they deploy to prevent unlicensed gambling. Michigan’s Gaming Control Board now requires content providers to disclose any supply of games to unlicensed operators as part of their licensing application. Meanwhile, Sweden requires licensed game suppliers to work exclusively with regulated operators, and Denmark introduced mandatory supplier licensing from 2025. 

In other words, the direction of travel is consistent.

A complicated reality

Despite the logic above, it would be reductive to cast suppliers as reluctant actors on a straightforward obligation. The reality of how the B2B gambling supply chain works presents genuine complexity that regulators and commentators do not always fully acknowledge. A major studio does not necessarily sell directly to every operator that ultimately carries its content. The iGaming supply chain frequently runs through aggregators, sub-aggregators, white-label platforms and resellers – layers of intermediaries through which a single game title may pass before reaching an end operator. 

In fact, in many cases, the original supplier has no direct contractual relationship with the entity actually serving players. Thus, as legal commentators have noted, if a software developer supplies games to both licensed and unlicensed operators through an aggregator, the developer may have no practical visibility into what is happening further down the chain.

This is not a theoretical concern. It is the structural reality of how content reaches global markets at scale. Trade bodies have made the same point. Swedish trade body BOS secretary general Gustaf Hoffstedt argued that compliance enforcement is fundamentally the role of the lawmaker and regulator – and that the gambling sector’s substantial tax contributions across Europe entitle it to expect governments to do that job. Germany’s Deutscher Online Casino Verband VP Simon Priglinger-Simader was similarly direct: “It shouldn’t be up to licensed operators to check all their suppliers’ activity – it should be on the regulator.” 

Both noted, however, that expanding B2B licensing requirements across more jurisdictions would be a practical step in the right direction, creating clearer lines of accountability. There is also a jurisdictional dimension that complicates the picture considerably. Suppliers operate in a global market, and the definition of “illegal” varies significantly by territory – once again, especially in Asia where there can be far less regulatory certainty in certain jurisdictions.

A supplier licensed in multiple jurisdictions therefore faces an enormously complex compliance map when trying to assess whether any given operator – particularly one distributed through intermediaries – is or is not compliant in each of the markets it serves. Expecting real-time visibility across that entire landscape sets an extremely high bar, even for well-resourced compliance teams. 

A shared responsibility

What this debate ultimately makes clear is that the question is not “either/or.” Responsibility for tackling illegal gambling is systemic; it does not sit neatly with any single actor, and any serious response will need to reflect that.

What is changing, however, is the expectation of what “responsible” looks like for a B2B supplier. Regulators are increasingly signalling that a supplier’s obligations do not end at the point of its direct contractual relationships – and that the multi-layered aggregator model can no longer function as a reliable shield against downstream accountability.

That does not mean the burden should fall on suppliers alone. There is a strong case for expanding direct B2B licensing obligations across more markets, creating clearer lines of accountability rather than leaving suppliers to operate under the indirect shadow of operator licences. Clearer rules here could benefit everyone – including the suppliers expected to follow them.

But the Evolution case has already changed the conversation – and the industry knows it. Regulators have demonstrated that supplier licences are not immune from scrutiny based on downstream activity. Suppliers, in turn, are reviewing their distribution frameworks and asking harder questions about who their content ultimately serves.

The supply chain is only as clean as its weakest link – and it is no longer enough to simply not know where that link is.