Gambling Operator Blacklists and Domain Blocking in the EU: Enforcement Mechanisms, Technical Blocking Methods, and Consumer Implications

Understanding Gambling Operator Blacklists

Gambling operator blacklists are official registers maintained by national regulatory authorities that identify online gambling operators offering services illegally in their jurisdiction. These blacklists serve as the foundation for enforcement actions, enabling technical blocking measures that prevent or discourage citizens from accessing unlicensed gambling services.

The rationale for blacklisting extends beyond mere protectionism. According to the European Commission's gambling policy framework, member states may restrict cross-border gambling services to protect consumers from operators that do not meet local licensing standards. Unlicensed operators may not comply with responsible gambling requirements, player fund protection rules, or anti-money laundering obligations that licensed operators must satisfy.

This guide examines how EU countries implement blacklisting systems, the technical methods used to block access, and the implications for both players and operators. For related information on enforcement actions, see our guide to gambling license revocation and enforcement in the EU.

Types of Technical Blocking Methods

EU countries employ several technical methods to enforce gambling blacklists. Each method has different effectiveness levels, implementation costs, and circumvention possibilities.

DNS Blocking

DNS (Domain Name System) blocking is the most common method used across the EU. When a domain is added to a blacklist, internet service providers are required to configure their DNS servers to refuse resolution requests for that domain.

• How it works: When users type a blocked domain into their browser, the ISP's DNS server returns an error or redirects to a government warning page instead of the website's IP address
• Implementation: Regulators provide updated blacklists to ISPs, who must update their DNS configurations within specified timeframes
• Effectiveness: Blocks casual users but can be circumvented by using alternative DNS providers (Google DNS, Cloudflare) or VPNs
• Countries using DNS blocking: Italy, Poland, Belgium, Lithuania, Portugal, Romania, Greece

IP Address Blocking

IP blocking requires ISPs to prevent access to specific IP addresses associated with blacklisted operators. This method is more technically demanding but harder to circumvent than DNS blocking alone.

• How it works: Network-level filters prevent all traffic to specified IP addresses, regardless of which domain is used
• Challenges: Operators can quickly change IP addresses, use content delivery networks (CDNs), or share IP addresses with legitimate services (collateral blocking risk)
• Effectiveness: More robust than DNS blocking but requires continuous monitoring and updating
• Countries using IP blocking: Less common as primary method; sometimes used in combination with DNS blocking in Italy and Poland

Payment Blocking

Payment blocking targets the financial infrastructure that unlicensed operators depend on. This method is often considered the most effective because it directly impacts operator revenues.

• How it works: Payment service providers, banks, and card networks are required to block transactions to blacklisted gambling operators based on merchant category codes (MCCs), domain lists, or account identifiers
• Implementation: Regulators maintain lists of prohibited merchant accounts, and PSPs must screen transactions against these lists
• Effectiveness: Highly effective because operators cannot process deposits or withdrawals, making their services unusable
• Countries using payment blocking: Germany (primary enforcement method), Netherlands, Sweden, Denmark, Spain

For detailed information on how payment blocking relates to AML compliance, see our guide to payment blocking and AML in EU gambling.

Deep Packet Inspection (DPI)

Some countries employ more sophisticated network inspection techniques, though these raise privacy concerns and are more resource-intensive.

• How it works: Network equipment analyzes the content of internet traffic to identify gambling-related communications, regardless of IP address or domain
• Challenges: Encrypted traffic (HTTPS) limits effectiveness; raises significant privacy concerns
• Usage: Limited use in EU gambling enforcement due to cost, privacy implications, and diminishing effectiveness against encryption

Country-by-Country Blacklist Systems

Italy: ADM Blacklist System

Italy operates one of the most comprehensive gambling blacklist systems in the EU. The Agenzia delle Dogane e dei Monopoli (ADM) maintains an extensive blocklist that ISPs must implement.

• Blacklist size: Over 10,000 domains blocked as of 2025
• Update frequency: Regular updates, with new domains added as they are identified
• Blocking method: Mandatory DNS blocking by all Italian ISPs; users see ADM warning page when accessing blocked sites
• Public access: The blacklist is publicly accessible on the ADM website
• Penalty for operators: Operators on the blacklist face significant fines and potential criminal prosecution if they continue targeting Italian players

For detailed Italian regulatory information, see our Italy gambling regulations page.

Poland: Register of Prohibited Domains

Poland maintains one of the largest gambling blacklists in Europe through the Ministry of Finance's Register of Prohibited Domains (Rejestr Domen Służących do Oferowania Gier Hazardowych).

• Blacklist size: Over 40,000 domain entries (including variations and redirects)
• Legal basis: 2017 Gambling Act amendments mandating ISP and payment blocking
• Blocking methods: DNS blocking mandatory for ISPs; payment blocking by Polish banks and PSPs
• Player liability: Polish law technically prohibits players from using unlicensed operators, though enforcement against individuals is rare
• Update process: Tax Chamber adds domains based on reports and monitoring; operators can appeal additions

Germany: GGL Warning and Blocking System

The Gemeinsame Glücksspielbehörde der Länder (GGL) takes a multi-pronged approach to enforcement against unlicensed operators.

• Public warnings: GGL publishes warnings about specific unlicensed operators on its website
• Payment blocking focus: Germany prioritizes payment blocking over DNS blocking, viewing it as more effective
• PSP requirements: Payment providers must implement controls to prevent transactions to operators on the warning list
• ISP cooperation: GGL can request ISPs to block specific domains, though this is used selectively
• Enforcement actions: Formal proceedings against unlicensed operators, with potential fines up to €500,000 per violation

For comprehensive German regulatory information, see our Germany gambling regulations page.

Netherlands: KSA Enforcement Approach

The Kansspelautoriteit (KSA) publishes warnings about unlicensed operators and can take enforcement action.

• Warning list: KSA maintains a public list of operators warned or fined for illegal activities
• Enforcement priorities: Focus on operators actively targeting Dutch players through Dutch-language marketing or payment methods
• Payment blocking: KSA works with payment providers to restrict transactions to unlicensed operators
• Fines: Substantial fines for unlicensed operators—up to 10% of annual turnover or €900,000 per violation
• DNS blocking: Not systematically implemented; enforcement focuses on operator-level action

For detailed Dutch regulatory information, see our Netherlands gambling regulations page.

Belgium: Gaming Commission Blocking

The Belgian Gaming Commission (Commission des Jeux de Hasard) operates an active blocking program.

• Blacklist: Commission maintains list of unlicensed gambling sites
• DNS blocking: Belgian ISPs required to implement DNS-level blocks
• Warning page: Blocked sites redirect to a Gaming Commission warning page
• Payment restrictions: Banks cooperate in blocking transactions to blacklisted operators
• Advertising ban: Strict enforcement against advertising by unlicensed operators, including fines for media outlets

Lithuania: Gaming Control Authority Blacklist

Lithuania's Gaming Control Authority maintains one of the most transparent blacklist systems in the EU.

• Public blacklist: Freely accessible list of blocked gambling domains
• ISP requirements: Mandatory DNS blocking for all Lithuanian ISPs
• Payment blocking: Banks and PSPs must block transactions to blacklisted operators
• Comprehensive advertising ban: From July 2025, comprehensive gambling advertising restrictions
• Regular updates: Blacklist updated as new unlicensed operators are identified

Comparison Table: EU Blacklist Systems

Legal Framework for Blocking

EU Law and Blocking Legitimacy

The legitimacy of gambling domain blocking under EU law has been addressed by the Court of Justice of the European Union (CJEU) in numerous cases. According to EUR-Lex case law, member states may restrict gambling services to protect consumers, maintain public order, and prevent gambling-related harm, provided restrictions are:

• Non-discriminatory: Applied equally to domestic and foreign operators
• Proportionate: Not exceeding what is necessary to achieve the stated objective
• Justified: Based on legitimate public interest objectives such as consumer protection or combating crime
• Consistent: Applied as part of a coherent regulatory framework

National Legal Bases

Each EU country that implements blocking has specific legal provisions authorizing the practice:

• Italy: 2006 Budget Law and subsequent gambling regulations authorize ADM to order ISP blocking
• Poland: 2017 amendments to the Gambling Act explicitly authorize the Register of Prohibited Domains and ISP/payment blocking
• Germany: Interstate Treaty on Gambling (GlüStV 2021) authorizes enforcement measures including blocking orders
• Belgium: 2011 Gambling Act as amended authorizes the Gaming Commission to order blocking

Operator Due Process

Most EU jurisdictions provide some form of due process for operators added to blacklists:

• Notification: Operators are typically notified before or shortly after being added to a blacklist
• Appeal rights: Operators can challenge their inclusion through administrative or judicial processes
• Removal conditions: Operators can apply for license and request removal from blacklists upon compliance
• Timeframes: Appeal and removal processes vary significantly by jurisdiction

Effectiveness of Blocking Measures

Evidence of Effectiveness

Research and regulatory data on blocking effectiveness presents a mixed picture. According to the European Gaming and Betting Association (EGBA) and academic studies:

• Channeling effect: Countries with effective enforcement see higher channeling rates to licensed operators—Sweden reports 86%+ channeling, compared to 60-70% in markets with weaker enforcement
• Reduced access: DNS blocking prevents casual users from accessing unlicensed sites, particularly those unfamiliar with circumvention techniques
• Payment blocking impact: This is considered the most effective method; operators unable to process payments cannot sustain operations
• Deterrent effect: The threat of blacklisting encourages some operators to seek licenses rather than operate illegally

Circumvention and Limitations

Despite their protective intent, blocking measures face inherent limitations:

• VPN usage: Players can use Virtual Private Networks to bypass both DNS and IP blocking
• Alternative DNS: Changing to non-ISP DNS servers (Google: 8.8.8.8, Cloudflare: 1.1.1.1) bypasses DNS blocking
• Mirror domains: Operators create multiple domains, requiring constant blacklist updates
• Cryptocurrency: Crypto payments can bypass traditional payment blocking, though conversion to fiat remains challenging
• Cross-border enforcement: Operators based outside the EU are difficult to compel through legal processes

Technical Arms Race

Blocking enforcement creates an ongoing technical challenge:

• Domain proliferation: Blocked operators register multiple new domains, requiring constant monitoring
• CDN usage: Content delivery networks complicate IP blocking due to shared infrastructure
• Encrypted traffic: HTTPS makes deep packet inspection less effective
• Decentralized finance: Emerging DeFi payment methods may challenge payment blocking

Consumer Implications

Risks of Using Blacklisted Operators

Players who access blacklisted operators face significant risks that licensed gambling does not present:

• No player fund protection: Unlicensed operators are not required to segregate player funds, meaning deposits may be at risk if the operator fails
• No guaranteed fair play: Games may not be independently tested or certified for fairness
• No dispute resolution: Players have no access to regulatory complaint processes or ADR schemes
• No responsible gambling tools: Self-exclusion, deposit limits, and reality checks may not be available
• Account closure risk: If an operator is blocked, players may lose access to accounts and funds
• Legal exposure: In some jurisdictions, players may face legal consequences for gambling with unlicensed operators

For information on how to resolve disputes with operators, see our guide to online gambling dispute resolution in the EU.

How to Verify Operator Licensing

Players should verify operator licensing before registering:

• Check regulator websites: Most regulators publish lists of licensed operators (KSA, GGL, DGOJ, ADM, MGA)
• Website footer: Licensed operators display license numbers and regulator logos—but verify these on the regulator's site
• License verification tools: Some regulators offer online license verification tools
• Blacklist checks: Review public blacklists before registering with unfamiliar operators

What Happens When a Site Is Blocked

When a gambling site is blocked while players have active accounts:

• Access disruption: Players can no longer access the site through normal means
• Withdrawal difficulties: Pending withdrawals may become inaccessible
• Communication challenges: Contacting customer support may become difficult
• Fund recovery: In most cases, regulators cannot assist in recovering funds from unlicensed operators
• Limited recourse: Players may need to pursue civil legal action in the operator's jurisdiction—often impractical

Operator Implications

Consequences of Blacklisting

For operators, being added to a national blacklist carries significant business consequences:

• Revenue loss: Blocked players means lost revenue from that market
• Payment disruption: Payment blocking prevents processing of deposits and withdrawals
• Reputational damage: Blacklisting signals to affiliates and players that the operator is non-compliant
• Affiliate restrictions: Licensed affiliates cannot promote blacklisted operators
• Future licensing: Blacklist history may affect applications for licenses in other jurisdictions
• Financial penalties: Fines for operating without license can be substantial

For information on licensing requirements, see our guide to B2B gambling licensing in the EU.

Path to Compliance

Blacklisted operators seeking to operate legally have options:

• License application: Apply for a license in the target jurisdiction
• Market exit: Geo-block players from restricted jurisdictions
• Corporate restructuring: Some operators create new corporate entities to apply for licenses
• Compliance remediation: Address the specific issues that led to blacklisting

The Role of ISPs and Payment Providers

ISP Obligations

Internet service providers play a crucial role in implementing blocking measures:

• Mandatory cooperation: In jurisdictions with blocking laws, ISPs must implement blocking orders
• Technical implementation: ISPs must configure DNS servers, firewalls, or other systems to block listed domains/IPs
• Timing requirements: Many jurisdictions specify timeframes for implementing blocks (e.g., within 24-48 hours)
• Liability protection: ISPs typically have legal protection when acting on valid blocking orders
• Reporting: Some regulators require ISPs to report blocking implementation statistics

Payment Provider Obligations

Payment service providers face increasing pressure to prevent gambling transactions to unlicensed operators:

• Transaction monitoring: PSPs must screen transactions against blacklisted merchant lists
• Merchant category codes: Gambling MCCs (7995) trigger enhanced scrutiny
• Bank identification: Some regulators provide bank account lists for blocked operators
• Proactive blocking: Major card networks have their own gambling restrictions beyond regulatory requirements
• Penalties for non-compliance: PSPs facilitating transactions to blacklisted operators face regulatory action

For detailed information on PSP requirements, see our guide to payment service providers and gambling in the EU.

Cross-Border Coordination

Regulatory Cooperation

EU gambling regulators increasingly cooperate on enforcement matters:

• GREF: The Gaming Regulators European Forum facilitates information sharing between regulators
• Bilateral agreements: Some regulators have formal information-sharing agreements
• Blacklist sharing: While not formalized, regulators often monitor each other's blacklists
• Joint warnings: Regulators occasionally issue coordinated warnings about particularly problematic operators

Challenges in Cross-Border Enforcement

Despite cooperation, cross-border enforcement faces challenges:

• Jurisdictional limits: Regulators can only compel action within their territory
• Operator location: Operators based in non-EU jurisdictions are difficult to sanction
• Different standards: What is illegal in one EU country may be legal in another
• Resource constraints: Enforcement requires significant regulatory resources

Future Developments

Enhanced Blocking Technologies

Technical blocking capabilities continue to evolve:

• Real-time blacklist updates: Automated systems for faster domain addition and ISP synchronization
• AI-powered detection: Machine learning to identify unlicensed gambling sites proactively
• Improved payment monitoring: Enhanced transaction analysis to detect disguised gambling payments
• Certificate-level blocking: Potential for SSL certificate revocation for illegal gambling sites

EU-Level Coordination

There is ongoing discussion about enhanced EU-level coordination:

• Shared blacklists: Proposals for EU-wide or regional blacklist sharing mechanisms
• Common standards: Harmonized criteria for blacklisting across member states
• Payment blocking cooperation: Coordinated approaches to payment blocking at EU level
• Digital Services Act: DSA provisions may affect how platforms handle gambling content

Cryptocurrency and DeFi Challenges

Emerging payment technologies present new enforcement challenges:

• Crypto-only casinos: Operators accepting only cryptocurrency can bypass traditional payment blocking
• Decentralized exchanges: Players may convert fiat to crypto through DEXs beyond regulatory reach
• Regulatory response: Some jurisdictions are developing crypto-specific gambling enforcement frameworks

For information on cryptocurrency in EU gambling, see our guide to cryptocurrency and Bitcoin gambling in the EU.

Conclusion

Gambling operator blacklists and domain blocking represent a key enforcement tool for EU gambling regulators seeking to protect their markets from unlicensed operators. While technical blocking measures have limitations and can be circumvented, they remain effective at reducing casual access to illegal gambling sites and channeling players toward regulated operators.

For players, the message is clear: using blacklisted operators carries significant risks including potential loss of funds, no access to dispute resolution, and in some jurisdictions, legal exposure. Verifying operator licensing through official regulator sources before registering is essential for player protection.

For operators, the enforcement landscape continues to evolve. The combination of DNS blocking, payment blocking, and substantial financial penalties makes operating without a license increasingly difficult in major EU markets. Seeking proper licensing remains the sustainable path to operating in European gambling markets.

As technology and regulatory frameworks continue to develop, both blocking effectiveness and circumvention capabilities will evolve. However, the fundamental principle—that regulators will take action to protect their markets—is likely to remain constant across the EU.

Last Updated: January 2026