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According to Done, such a tax rise would lead Betfred to close 495 of its shops within a year, resulting in the loss of 2,575 jobs and roughly £67 million in foregone tax revenue for the Exchequer.

Betfred has already shuttered 132 outlets this year, following last year’s RGD increase.

“We have tried hard to protect all our sites and the colleagues who work in them, but the combined impact of higher employer National Insurance contributions, wage inflation, increases in gambling taxes and wider economic uncertainty has left us with no choice,” said Chief Executive Jo Whittaker in a statement to iGB at the time the closures were announced.

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The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.

The DOCV, another trade body representing licensed online casino operators in Germany, also expressed support for the prosecutorial efforts. However, it emphasised that the raid exposed regulatory gaps which had allowed organised crime to flourish.

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%.

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In this context, the regulations developed to protect players begin to function as a means of legitimisation, with illegal operators even using the term “authorised” in their communication and the “.bet” extension in their domain, which is intended only for licensed operators.

According to the governance policies of Meta, the owner of Instagram, gambling platforms can use programmatic advertising services and branded content, provided they receive authorisation from the platform. They cannot target content to individuals under 18 or territories where gambling is not regulated.

To obtain Meta’s approval, the company needs to fill out a form and attach documents proving its operating licence. This same form includes a contract, in the form of an “I accept the terms and conditions” button. In it, the advertiser releases Meta from liability for any violations of the content, including legal or administrative proceedings.