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All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.

It requires operators to describe in detail how they will responsibly wind down their operations should their licence not be renewed or be revoked. Or if they decide to leave the market midway through the five years between renewals.

The regulator noted that several operators received “additional points for attention”, indicating that while these applicants met minimum legal thresholds, the KSA expected continuous improvements in compliance practices.

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Other estimates are considerably higher, illustrating how difficult the market is to measure. As an example, separate research from Gaming Compliance International put the value of unregulated online gambling at $5.9 trillion in wagering value in 2025, while estimating that unregulated operators accounted for 78% of global online gaming GGR.

Another report, commisisoned by Euromat, estimates that Europe’s black market has sustained a compound annual growth rate of 18% between 2019 and 2026, and will be worth up to €13 billion by the end of the year.

For enforcement authorities, however, the challenge is not simply estimating its size. It is keeping track of an ecosystem that can continually change domains, infrastructure and acquisition channels. That is where Madsen sees Trace2Trace fitting in.

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What the president didn’t address is the tax revenue from betting.

In 2025, Brazil collected almost BRL10 billion ($1.97 billion) in tax revenue from the licensed sector. In the first seven months of this year alone, BRL8.7 billion generated by the activity was delivered to public coffers. The Federal Revenue Service itself estimates that the sector should reach BRL16 billion in revenue during 2026.

Besides revenue collection, another concern is legal and economic. Companies have paid over BRL2.5 billion for licences since the sector’s regulation. Certainly, the end of the activity would lead to litigation to recover the amounts paid and compensation for investments made. Furthermore, the revenue from betting is already included in the Annual Budget Law and the Budget Guidelines Law, which define the priorities for federal government spending.