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“When it comes to prediction markets, none of that exists,” he said. “Everyone that’s building in the prediction market space mostly starts from ground zero.”

Platforms were generally constructed for one person operating one account, rather than trading organisations requiring separate permissions and controls. According to Gonzalez, some teams still share a single login.

“Whether it’s a 10-person or 100-person fund, they log in through the same Google email and share the same login credentials, which makes no sense,” he said.

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Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.

The trade body has long been critical over the discrepancy between channelisation estimates made by the regulator, and other independent reviewers.

The DOCV reinforced its calls for a unified federal licensing regime for online casino games and stronger enforcement mechanisms against illegal operators. 

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“There are valid arguments to be made in relation to raising the barriers to licensing, but this may come at a cost of diminishing competition and entrepreneurship,” he says.

In any event, successive regulatory tightening and tax increases have already created a “reasonably effective deterrent” to market entry.

There is a second complication. The relentless flow of Commission statements may eventually make enforcement less damaging rather than more.