Study Suggests Nordic Regulators Still in the Dark Over Online Gambling Black Market
A peer‑reviewed scoping review warns that regulators across the Nordic region do not yet have robust tools to quantify offshore online gambling.
LISTEN TO THIS ARTICLE:Researchers from institutions in Finland, Denmark, Sweden and Norway say attempts to measure the size and nature of the online gambling black market are hampered by sparse data and inconsistent methods. The review, published in PLOS One, assessed 32 studies carried out between 2010 and 2024 and concluded there is “no gold standard or one reliable method to conclusively measure offshore gambling”.
The paper’s authors – Virve Marionneau of the University of Helsinki, Søren Kristiansen of Aalborg University, Tomi Roukka of the Finnish Institute for Health and Welfare (THL) and Håkan Wall of the Karolinska Institute – describe offshore play as “a politically sensitive topic wrought with uncertainties” .They say many published estimates rely on a small set of commercial data providers and inconsistent survey techniques, producing figures that are difficult to verify.
“Even regulators are not fully aware of the metrics and assumptions on which these estimates are based”, Marionneau said. “When channeling rates are used to justify major policy changes, the absence of transparent, validated methods risks steering decisions by incomplete or speculative evidence.”
The review highlights that a large share of headline estimates about unlicensed gambling in the Nordics trace back to a single market intelligence firm, H2 Gambling Capital. While frequently cited by governments, industry groups and media, the paper argues the firm’s methodology is not sufficiently transparent for independent evaluation – a shortcoming the authors say weakens the evidential footing of policy debates in Sweden, Denmark, Norway and Finland.
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Estimates, Politics and a Path Forward
The researchers also note that offshore figures are sometimes deployed as political instruments. “Methodological choices, data resources and political interests can shape the kinds of estimates produced”, Søren Kristiansen said. “That means numbers presented as factual can mask selective assumptions or gaps in evidence.”
As an example, the review critiques a Swedish study that claimed unlicensed players spend 10-20 times more than those on regulated platforms; the authors found no transparent empirical basis for that multiplier. The team’s synthesis further shows offshore gamblers are often active in the regulated market as well. In Finland, for instance, 98% of those reporting offshore gambling also used licensed services, even though much of the risky spending – such as fast online casino games and live betting – occurred offshore.
To strengthen measurement, the paper recommends a multi‑method approach combining representative surveys, anonymized transaction data, help‑seeking and treatment statistics, and other administrative sources. The authors argue that bank transaction data – while sensitive and subject to legal constraints – could meaningfully improve estimates when used under strict privacy safeguards and in conjunction with payment‑blocking systems already operated by regulators.
“We need transparent, scientifically validated tools that regulators can use and scrutinize”, Håkan Wall said. “Without that, regulatory strategies aimed at channeling play into licensed markets risk being based on shaky foundations.”
The review comes as Nordic regulators such as Sweden’s Spelinspektionen, Denmark’s Spillemyndigheden and Norway’s Lotteritilsynet continue to refine oversight of online operators and payment controls. The authors call for closer collaboration between national authorities, independent researchers and statistical agencies to develop standardized metrics and to reduce reliance on a single commercial data supplier.
For policymakers, the paper underscores a practical dilemma: action is required to protect consumers from unlicensed operators, but policy should be informed by measurement systems that are open to verification. The authors warn that until better methods are in widespread use, estimates of the offshore market should be treated with caution when cited to justify regulatory change or industry policy positions.
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