EU REGULATION
logic, support automated monitoring systems. National standardization bodies have already voted in favour of EGBA-proposed initiative. Once widely adopted, these markers will function as a de facto pan-European technical standard for detecting risk. According to EGBA, “The finalisation process is expected to be complete by early 2026. Once published, the standard will be available for voluntary adoption by gambling regulators and operators across Europe.” While these are not formal EU standards, the protocols being developed establish de facto templates for how complaints, notices, and enforcement actions should be formatted and transmitted. However, such cooperation is still fragmented and decentralized 13 . Nevertheless, regulators in multiple EU Member States are already participating in bilateral and multilateral data exchanges on and actions against illegal operators. On 12 November 2025, regulators from Germany, Austria, France, Great Britain, Italy, Portugal, and Spain signed the cooperation arrangement structured into three pillars of collaboration: exchanging information on unlicensed operators, coordinated action urging removal of illegal gambling advertising, and sharing methods for identifying, investigating, and sanctioning operators. All these initiatives pave the way for gradual convergence in the European online gambling market, that may significantly reduce fragmentation in near future. This bottom-up convergence would definitely benefit from active EU participation, particularly in supporting technical standards, coordinating enforcement practices, and ensuring interoperability across national frameworks.
Conclusion: Outlook for the Gambling Industry EU standardization bodies and gambling authorities seem to have already started down the suggested path. Technical harmonization through common standards is already taking root in the online gambling industry. CEN (European Committee for Standardization) has approved standards such as EN 17531 for reporting in support of supervision of online gambling. This standard creates a shared data and reporting architecture, meaning regulators can compare apples to apples across jurisdictions. Over time, de facto harmonization of technical standards is likely to generate product-level convergence across the EU. In practical terms, gambling products themselves may increasingly be structured and presented in a uniform manner across jurisdictions, to a large extent without national deviations in product design, algorithmic logic, or product text. That said, divergent national framework conditions will continue their influence even with existing common standards (for example, Germany’s player limit rules), and technical harmonization alone will not entirely eliminate those structural differences. Further, the European Gaming and Betting Association (“EGBA”) has been actively involved in developing harm markers: standardized indicators of risky or harmful behaviour. While this is not the EU law, the initiative has gained traction among national regulators as a reference model for safer gambling frameworks. These markers aim to define common behavioural risk signals (e.g., escalating deposits, rapid session frequency), enable standardised intervention
DR. WULF HAMBACH Founding Partner, Hambach & Hambach Law Firm For more information contact w.hambach@timelaw.de +49 89 38997572. DR. STEFANIE FUCHS- RAICHER Senior Partner, Hambach & Hambach Law Firm CHRISTINA KIRICHENKO Senior Associate, Hambach & Hambach Law Firm
13 Example: A Consumer Protection Cooperation (CPC) Network under EU consumer law (https://commission.eu- ropa.eu/live-work-travel-eu/consumer-rights-and-complaints/enforcement-consumer-protection/consumer-protec- tion-cooperation-network_en) provides a good example of a centralized cooperation. National authorities exchange standardized requests, alerts, and enforcement actions through a shared system when dealing with cross-border in- fringements. This network demonstrates how templates for complaints, evidence, and enforcement requests become harmonised through practice. Several gambling-related cases involving misleading promotions and illegal offers have been handled through this framework, reinforcing common enforcement formats
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IMGL MAGAZINE | MARCH 2026
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