Poland and France have taken a new step against unlicensed gambling by agreeing to share information on the grey market, focusing on illegal operators and the revenue streams that sustain them. The cooperation arrangement, reported by iGaming Express and confirmed by officials in Warsaw, sits alongside a broader security and cooperation treaty signed by Prime Minister Donald Tusk and President Emmanuel Macron in Nancy in May 2025.
Although the full text of the gambling addendum has not been published, both sides have signaled that the goal is clear: make it harder for offshore operators to target French and Polish players while bypassing local rules, tax obligations and consumer protections.
Offshore casinos dominate both markets despite strict regulations
France and Poland face different regulatory landscapes, but a similar problem. Both have large, persistent grey markets that sit alongside tightly controlled legal markets.
In France, online casino games remain illegal. The regulated sector covers online sports betting, horse-race betting via Pari Mutuel Urbain, and online poker, all under the supervision of the regulator Autorité Nationale des Jeux. Studies commissioned by the ANJ and PwC estimate that three to four million people in France used illegal gambling websites in 2023, with online casinos identified as the main driver of that activity.
The illegal market is now large enough to challenge the licensed market. ANJ and other industry groups have warned that offshore sites, often based in Curaçao or other lenient jurisdictions, offer higher returns, unrestricted bonuses and banned products such as roulette and slots, drawing players away from the regulated system and undermining the country’s effort to enforce better consumer protection.
Poland’s situation is different in law but similar in practice. Online sports betting is licensed, but there is only one legal online casino, Total Casino, operated by state-owned Totalizator Sportowy. Market research and an EY study commissioned by Polish industry groups have shown that illegal online casinos generated close to PLN 26 billion in turnover and more than PLN 1 billion in revenue for unlicensed operators in 2023.
By 2024, estimates from H2 Gambling Capital suggested that illegal gambling in Poland was approaching parity with the legal sector in terms of revenue, highlighting the scale of the problem and the limits of national enforcement when offshore sites can still reach Polish players.
What the new data-sharing pact is expected to include
From what we know, the Poland-France agreement will concentrate on the mutual exchange of information specifically about grey-market activity, including data on illegal operators, cross-border financial transactions and other indicators of unlicensed gambling. The cooperation agreement is framed as a response to the increased activity “outside the regulated market,” with a particular focus on offshore providers that target players in both jurisdictions.
In practice, this is likely to involve closer coordination between regulators and financial-intelligence units, supported by structured channels for sharing suspicious-transaction data, payment-routing patterns and lists of domains or brands that repeatedly breach national rules. While neither government has confirmed operational details, the emphasis on financial flows suggests that payment blocking and pressure on intermediaries will be some of the first measures taken.
The agreement is also expected to make it easier to trace operators that move between markets. Offshore brands commonly rebrand, switch domains or move processing to new jurisdictions when they come under pressure in a single country. A joint view of those movements should make it harder for them to stay hidden in one market while being sanctioned in another.
Two regulatory models, one shared enforcement goal
The cooperation highlights a paradox facing both regulators. In France, the continued prohibition on online casino games has not eliminated demand. Instead, it has helped create a large offshore ecosystem that offers the very products the legal market forbids. ANJ’s own campaigns now warn players that many of the most visible casino sites are illegal and offer no protection if things go wrong.
In Poland, the monopoly model for online casinos has delivered a controlled legal offer, but has also left room for international brands to capture players who want more variety or less restrictive gameplay. Even consumers who actively intend to play legally can drift into the grey market, because unlicensed sites often use Polish language, local payment methods and familiar marketing tactics.
Both countries have expanded their enforcement toolkits in recent years through website blocking orders, blacklists and tax measures, but the figures on illegal play suggest that national action on its own is not enough. Offshore operators are used to operating across borders, shifting infrastructure and payments to whichever jurisdiction gives them the most flexibility.
A gambling agreement tied to wider security cooperation
The gambling information-exchange agreement does not stand alone. It plays only a small part of a broader Treaty on Enhanced Cooperation and Friendship signed by Donald Tusk and Emmanuel Macron, which includes mutual security guarantees, closer defense-industry ties, and commitments on cyber security and combating threats to democratic institutions.
Illegal gambling fits into that wider picture because it intersects with money laundering, tax evasion and, in some cases, match-fixing and other forms of sporting fraud. French investigators, for example, recently concluded a major inquiry into tennis match-fixing linked to betting markets, which involved cross-border revenue streams and criminal networks operating across several European countries.
How coordinated action could reshape the European market
For licensed operators in Poland and France, stronger cooperation against illegal competitors is likely to be viewed as positive. Regulated brands in both countries have argued that they face an uneven playing field when offshore sites can offer untaxed products, higher returns and unrestricted promotions.
If the new agreement leads to more effective payment disruption, faster identification of repeat offenders and more coordinated sanctions, it could gradually reduce the visibility and accessibility of unlicensed sites. That in turn would support channelization into the legal market, which has been the number one priority for European gambling regulators over the past decade.
There are still open questions. Neither country has outlined how the success of this agreement will be measured, how frequently data will be exchanged or whether other EU states will be invited to join similar arrangements. But as grey-market estimates in both countries climb into the tens of billions of euros, the political incentive is growing to funnel players from the grey markets to the regulated markets.
For now, the Poland-France agreement is one of the first bilateral deals in Europe framed explicitly around information sharing on gambling’s grey market. Its impact will depend on how quickly it moves from principle to practice, and whether it becomes a model for wider regional cooperation against unlicensed gambling.
References
- Government of Poland: Overview of the Treaty on Enhanced Cooperation and Friendship with France – https://www.gov.pl/web/premier/treaty-on-enhanced-cooperation-and-friendship-between-the-republic-of-poland-and-the-french-republic
- iGaming Express: Report on Poland and France signing a grey-market gambling information-exchange agreement (8 Dec 2025) – https://igamingexpress.com/poland-and-france-sign-information-exchange-agreement-grey-market/
- ANJ & PwC: Study on illegal online gambling in France and ANJ’s “100% Winner?” public-awareness campaign (2023–2024) – https://anj.fr/en/news/illegal-online-gambling-study-anj-pwc
- EY Poland: Report on illegal online casino turnover for Play Legally (Oct 2024) – https://www.ey.com/en_pl/press-releases/2024/10/illegal-online-gambling-market-in-poland-worth-pln-26-billion
- H2 Gambling Capital / GCAuthority: Analysis of Poland’s grey-market size and revenue share (Apr 2025) – https://europeangaming.eu/portal/latest-news/2024/05/09/160764/polands-illegal-gambling-sector-approaches-legal-market/
