The African iGaming Alliance welcomes the publication of Gaming Compliance International's (GCI) latest report, Online Gaming 2024–2025: Africa. The report provides one of the most comprehensive assessments to date of the scale of unregulated online gambling across the continent and rightly places this issue at the centre of Africa's regulatory agenda.

Its findings should concern every policymaker, regulator, revenue authority and licensed operator.

According to GCI's Online Gaming 2024–2025: Africa report, Africa's online gambling market generated an estimated USD23 billion in Gross Gaming Revenue (GGR) during 2025. Yet only USD5.2 billion (23%) was generated through licensed and regulated operators, while an estimated USD17.8 billion (77%) flowed through unregulated operators. The report further estimates that more than 4,100 unregulated operators are actively targeting African consumers and that approximately 215 million Africans engaged with online gambling during the year.

These figures illustrate that illegal gambling is no longer simply an enforcement challenge. It is one of the most significant public policy challenges facing the African gambling sector.

The Alliance agrees with GCI's central conclusion that governments must pay greater attention to the entire gambling marketplace rather than focusing exclusively on licensed operators. As GCI observes, consumers experience one marketplace, not two. Every consumer who migrates to an unregulated operator is a consumer who falls outside local regulatory oversight, responsible gambling protections, dispute resolution mechanisms and tax systems.

However, while we agree with the report's diagnosis of the problem, we believe the long-term solution requires an additional policy focus.
 

There is broad agreement that governments should strengthen enforcement against illegal operators.

Website blocking, payment disruption, action against illegal affiliates, advertising controls, cooperation with app stores and technology providers, and stronger regulatory intelligence all have an important role to play.

The Alliance fully supports proportionate and effective enforcement.
However, enforcement alone will not solve Africa's illegal gambling challenge.

Technology evolves faster than regulation. Consumers increasingly have access to VPNs, mirror sites, cryptocurrency, alternative payment methods and other digital tools that enable them to bypass restrictions. Illegal operators continually adapt their methods of acquiring and retaining customers.

No jurisdiction can realistically build a regulatory fortress capable of completely preventing consumers from accessing offshore gambling services.
 

The more important question is therefore not simply:

"How do we stop consumers accessing illegal operators?"

It is:

"Why are consumers choosing illegal operators in the first place?"

That question deserves equal attention.

The objective of gambling regulation should not simply be licensing operators.

The objective should be channelisation - maximising the proportion of gambling activity that takes place within the licensed and regulated market.
Consumers should choose licensed operators because they provide the safest, most attractive and most competitive products available.

When regulated markets become less competitive, consumers inevitably migrate elsewhere.

GCI identifies four policy areas that directly influence the competitiveness of regulated markets:
 

• Customer taxation;
• Operator taxation;
• Payment systems; and
• Product availability.
   

These are not simply commercial considerations.

They are public policy considerations.

Governments understandably seek to maximise tax revenue and strengthen consumer protection. Yet if taxation, payment costs, licensing complexity or product restrictions become disproportionate, they may unintentionally encourage consumers to migrate to operators that contribute nothing to the local economy.

Consumers generally do not distinguish between regulated and unregulated markets in the way policymakers do.

They respond to value, convenience, accessibility, product availability and user experience.

Public policy must recognise this reality.
 

One of GCI's most valuable contributions is its Monitor, Police, Enforce and Optimise (MPEO) framework. The Alliance agrees that effective regulation requires all four components.

However, optimisation deserves equal prominence.

Optimisation means ensuring that licensed operators are able to compete successfully within an appropriately regulated environment.

That includes:

1.  Proportionate and predictable taxation;
2.  Transparent licensing processes;
3. Efficient payment systems;
4. Access to products consumers demand;
5. Strong but practical responsible gambling measures;
6.  Effective enforcement against illegal operators; and
7. Constructive engagement between governments, regulators and licensed industry.

These measures should not be viewed as concessions to industry.

They are essential tools for achieving better public policy outcomes.

When consumers remain within the regulated market:

• Governments collect more sustainable tax revenue;
• Regulators retain oversight;
• Responsible gambling measures are effective;
• Consumers receive legal protections;
• Investment and employment increase; and
• Criminal participation declines.

These are precisely the outcomes regulators seek to achieve.

GCI estimates that 89% of gambling-related audience exposure across Africa is associated with unregulated operators, while governments may be losing an estimated USD4.45 billion annually in forgone tax revenue.

These figures should prompt an important shift in thinking.
Regulatory success should not be measured solely by the number of licences issued, compliance inspections conducted or enforcement actions taken.

It should be measured by outcomes.

• Are more consumers choosing licensed operators?
• Is participation in the illegal market declining?
• Are governments collecting more sustainable tax revenue?
• Are consumers better protected?
• Are regulated businesses investing, employing people and contributing to national economies?

Those are the indicators that ultimately matter.
 

Africa's gambling sector has enormous potential to contribute to economic growth, technological innovation, employment and public revenue.

The challenge is not creating consumer demand.

That demand already exists.

The challenge is ensuring that demand is channelled into safe, licensed and regulated markets.

Achieving that objective requires partnership between governments, regulators, revenue authorities, licensed operators, technology providers and industry associations.

GCI has performed an important service by quantifying the scale of Africa's illegal gambling economy and providing policymakers with valuable evidence upon which to build future reforms.

The next step is ensuring that policy responses address not only how illegal operators are challenged, but also how regulated markets are strengthened.

Africa cannot enforce its way out of the illegal gambling challenge.