Player Protection Must Become Infrastructure
The global gambling debate is still framed too narrowly. Governments debate licences, tax rates, advertising restrictions, age limits and enforcement powers. Operators debate compliance. Clubs and sports organisations debate sponsorship. Yet the most important question is more basic: who is responsible for protecting the person on the other side of the screen, not only when that person is inside the regulated system, but also when the market itself is increasingly difficult to distinguish between licensed, unlicensed and legally ambiguous offers?
That question is no longer theoretical.
Gaming Compliance International (GCI) estimates that unregulated online gambling reached $5.9 trillion in wagering value in 2025, up from $5.7 trillion in 2024 and $5.1 trillion in 2023. GCI further estimates that unregulated operators account for 78% of global online gross gaming revenue, while regulated operators account for 22%.[1][2] These are estimates rather than official global statistics, and wagering value should not be confused with revenue or GDP. But the direction of the evidence is difficult to dismiss: the regulatory perimeter covers only part of the market that consumers actually experience.
This is the central failure in the current model. Regulation can govern licensed operators. It cannot automatically protect people from what happens outside that licensed perimeter.
THE PROTECTION GAP
The World Health Organization treats gambling harm as a public-health issue. It estimates that around 1.2% of the world’s adult population has a gambling disorder and notes that people gambling at harmful levels generate around 60% of gambling losses, or industry revenue. WHO also states that there is no global agreement on the regulation of online gambling and that unlicensed, illegal and offshore gambling creates major regulatory challenges for governments.[3]
The problem becomes even clearer when the market is viewed from the consumer’s perspective. GCI describes a three-sector marketplace: regulated, unregulated and “unacknowledged” products that sit outside conventional regulatory classifications. To the average consumer, these sectors may look almost identical. The same smartphone can provide access to all three. The same sports content can lead to all three. The same payment technologies, affiliates, social channels and search behaviour can connect the user to all three.
The distribution system is also changing faster than traditional enforcement. The GCI analysis cited by The iGaming EU found unregulated gambling advertising on more than 80% of illegal sports streams monitored in the United States and United Kingdom during 2024 and 2025.[1] The UK Gambling Commission separately warns that illegal gambling can be promoted through websites, apps, crypto casinos, WhatsApp, Telegram and other digital channels, and that some illegal sites are difficult for consumers to distinguish from licensed ones.[4]
In Europe, the picture is even more uncomfortable. A 2026 GCI analysis for the Campaign for Fairer Gambling estimated that unregulated operators generated €91.6 billion of online GGR in the EU-27 in 2025, equal to 72% of the €128.0 billion online market. The European Casino Association says the same activity deprived EU Member States of an estimated €22.9 billion in tax revenue and involved more than 6,200 illegal operators targeting European consumers.[5][6]
These figures do not prove that every national regulation has failed. That claim would be too broad. In fact, the UK Gambling Commission found no overall increase in engagement with illegal gambling websites in Great Britain between May 2024 and July 2025, although around 1,000 unique illegal sites were accessed during the period.[7] The stronger conclusion is this: even serious regulation cannot guarantee comprehensive protection when the market is cross-border, digital, fragmented and constantly evolving.
That distinction matters. The objective should not be to declare regulation a failure. The objective should be to redesign regulation around the reality regulators now face.
FROM COMPLIANCE TO ACTIVE PROTECTION
Most regulatory systems are built around permission: an operator receives a licence, follows rules and is supervised. This remains necessary, but it is no longer sufficient. A modern protection system must also be built around continuous responsibility.
The principle is simple: protection should begin with behaviour, not with a breach. If unusual or potentially harmful patterns can be identified early, intervention can happen before the damage becomes severe. If a player begins to display rapid changes in frequency, spending, session duration or other risk indicators, the system should not wait for a crisis, a self-exclusion request, a complaint or a regulatory investigation. It should create a pathway for proportionate, human-centred intervention.
This is the first pillar of the DoubleJack.club proposition: Active Monitoring and Early Intervention. The ambition is to monitor relevant user behaviour from the beginning and respond when unusual patterns emerge. For this approach to deserve regulatory trust, however, it must be measurable and independently auditable. Risk models should be transparent enough to evaluate; false positives and false negatives should be tracked; interventions should be proportionate; privacy should be protected; and users should have clear rights regarding automated decisions and the use of their data.
That is precisely why the concept belongs at the level of public policy rather than marketing alone.
PROTECTION FIRST — AND VALUE CREATION BEFORE EXTRACTION
The second pillar is more unconventional: Value Creation, or “Income First.” The idea is to give fans the opportunity to convert participation and community activity into productive economic value before asking them to spend discretionary money on gambling or related products.
This should not be presented as a proven treatment for gambling harm. It is better understood as a design principle: a platform should seek to create value for the participant before extracting value from the participant.
That reversal is strategically important. The dominant digital model is built on attention extraction. The user arrives, is stimulated, spends and is then retained. A protection-first model asks a different question: can the ecosystem create earning, contribution, participation or other tangible value for the fan first, and only then permit tightly controlled discretionary entertainment spending?
The concept deserves rigorous testing because it changes the incentive structure. It moves the conversation away from “how much more can a user spend?” toward “how can the ecosystem improve the user’s position before any optional spend occurs?” For football clubs, leagues, sponsors and governments, this matters because responsibility can become visible. Fan engagement is no longer only about commercial yield. It becomes a measurable commitment to the fan’s wellbeing inside and outside the stadium.
THE MISSING LAYER: PUBLIC–PRIVATE GOVERNANCE
The third pillar is Governance through Public–Private Partnership (PPP).
No single regulator can police a borderless digital market alone. No private platform should be trusted to write its own rules without oversight. The practical answer is therefore not “government or industry.” It is a governed infrastructure in which public authority defines the outcomes and accountability, while technology provides the monitoring, data, speed and implementation capacity.
A credible PPP model could be built around six functions.
First, a shared protection standard. Governments and regulators define minimum requirements for age verification, identity controls, behavioural-risk monitoring, intervention thresholds, self-exclusion, affordability safeguards where legally applicable, complaints, data retention and independent auditing.
Second, real-time or near-real-time risk detection. Approved technology providers operate under the regulatory standard and identify patterns that justify intervention. The objective is not to criminalise ordinary gambling behaviour; it is to detect meaningful changes early enough for protection to matter.
Third, cross-border intelligence. Regulators need structured ways to exchange information about unlicensed operators, mirror domains, payment routes, affiliate networks, advertising channels and emerging products. WHO explicitly notes that effective responses to unlicensed and offshore gambling require intergovernmental cooperation and data sharing.[3]
Fourth, a responsible intervention ladder. Not every signal should trigger the same response. Interventions can range from information and cooling-off prompts to deposit restrictions, human review, temporary suspension, self-exclusion tools and referral to qualified support services. The process must be proportionate and subject to governance.
Fifth, a verified economic and social return. A PPP should measure more than tax collection. It should report reductions in harmful behaviour, intervention outcomes, movement from illegal to regulated environments, consumer complaints, self-exclusion effectiveness, support referrals and the share of value returned to users and communities.
Sixth, exclusion of non-compliant entities. A regulatory system is only credible if entities that refuse minimum safeguards face practical consequences. That can include payment blocking, ISP and domain measures where lawful, advertising restrictions, app-store enforcement, affiliate accountability and coordinated cross-border action. The purpose is not to make a market artificially closed. It is to make participation conditional on protecting the people who make the market possible.
WHY TODAY’S RULES ARE NOT ENOUGH
The most important lesson from the $5.9 trillion estimate is not the size of the number. It is what the number says about regulatory architecture.
Regulation today is mostly jurisdictional. Digital consumption is not.
Regulation often focuses on licensed entities. Consumer exposure does not.
Regulation frequently acts after a violation. Harm can develop before a violation becomes visible.
Regulation can restrict legal advertising. Illegal operators can recruit through illegal streaming, social channels, affiliates, crypto ecosystems and cross-border platforms.
Regulation may create national self-exclusion systems. Consumers can sometimes move to offshore products that do not participate in them.
This is the asymmetry that must be solved. Governments are regulating companies. They also need infrastructure capable of protecting people across the wider market.
That does not mean creating a global super-regulator. It means creating interoperable standards. Financial services already use shared concepts such as KYC, AML, sanctions screening, suspicious-activity monitoring and cross-border information exchange. Online gambling needs an equivalent protection architecture designed around behavioural risk and consumer welfare.
THE BUSINESS CASE FOR RESPONSIBILITY
There is also a commercial reason to act.
For clubs, leagues and sports organisations, gambling has increasingly become a reputational and regulatory risk. Removing a gambling sponsor may reduce one visible exposure, but it does not remove gambling from the fan’s digital environment. If unregulated operators dominate discovery channels, the fan may simply move from a visible licensed sponsor to an invisible offshore operator.
The stronger strategy is to make protection part of the commercial ecosystem itself.
A club should be able to tell its supporters: we do not only monetise your attention; we participate in a system designed to protect you. A sponsor should be able to show that fan activation is connected to measurable safeguards. A government should be able to see whether technology is improving channelisation toward compliant environments. An investor should be able to evaluate not only revenue growth but governance quality and regulatory resilience.
This is where protection becomes a competitive advantage rather than a compliance cost.
DoubleJack.club is built around a purpose that runs against the logic of conventional gaming companies: the objective is not to make people gamble more efficiently, more often or for longer. The objective is to protect fans before harm escalates and to make that protection visible to clubs, governments and regulators. That difference is not theoretical. DoubleJack.club has already taken the model beyond presentations and brought it to the attention of government and regulatory stakeholders in several countries across multiple continents.
We have protected the fans.
Clubs can prove responsibility.
Governments have it on their desks already.
That is where DoubleJack.club’s uniqueness sits. To our knowledge, no other gaming-focused firm combines continuous behavioural monitoring, active intervention, fan-side value creation and a public-private governance model in one architecture built specifically around football communities. More importantly, this is not a claim that exists only on a slide. The protection model has been developed, taken to government-level stakeholders and positioned as a framework that can be embedded in regulation rather than remain a voluntary feature. Clubs can therefore do more than say they care about supporters; they can prove responsibility through a system designed to identify risk and act.
The next step is to measure the effect over time. DoubleJack.club proposes a long-term study of the model: how early intervention changes harmful behaviour, whether protection improves movement toward compliant environments, what outcomes clubs and governments can document, and whether a protection-first model can reduce harm while preserving legitimate entertainment. The purpose of that study is not another white paper. It is to create an evidence base strong enough for policy and long-term regulation.
FROM PURPOSE TO POLICY
Purpose is often reduced to branding. Here it is the opposite: it is the operating model. Conventional gaming businesses ultimately depend on greater participation and greater spend. DoubleJack.club begins from the opposite side of that equation: protect the fan first, intervene before harm becomes severe, and make commercial participation conditional on responsibility.
The purpose is not to make gambling look safer. It is to make the person safer — and to give clubs and governments a way to prove that protection exists in practice.
That means monitoring risk early, acting when harmful patterns emerge, creating value before extracting it, connecting users to support, giving governments auditable oversight and building public–private structures that can extend protection beyond the boundaries of a single club, operator or jurisdiction. DoubleJack.club has already taken this proposition to public-sector stakeholders on more than one continent. The strategic objective now is to turn that engagement into pilots, evidence and eventually regulation.
The scale of the unregulated market shows why this matters. A system in which the majority of global online GGR is estimated to occur outside the regulated perimeter cannot rely only on the perimeter itself.[1][2] The future of regulation must therefore combine law with technology, enforcement with prevention, and national authority with cross-border cooperation.
The question for regulators is no longer simply: who has a licence? The question for clubs is no longer simply: who is our sponsor?
The question for technology companies is no longer simply: how much engagement can we create?
The question for all three should be: can we prove that the people creating the value are being actively protected?
That is the shift from compliance to responsibility. From purpose to infrastructure. And, ultimately, from fragmented regulation to a protection model capable of operating at the same scale as the market it is supposed to govern.
doublejack connects clubs and fans. Choose your side.
REFERENCES & EVIDENCE
[1] The iGaming EU, “Unregulated online gambling hits $5.9tn in 2025, GCI reports,” 19 May 2026.
https://theigaming.eu/2026/05/19/unregulated-online-gambling-hits-5-9tn-in-2025-gci-reports/
[2] Gaming Compliance International press release, “The Trillion Dollar Problem: Unregulated Online Gambling Reaches $5.9 Trillion in Global Wagering Value,” 18 May 2026.
[3] World Health Organization, “Gambling,” 2 December 2024.
https://www.who.int/news-room/fact-sheets/detail/gambling
[4] UK Gambling Commission, “Illegal online gambling: Consumer engagement and trends — Introduction,” published 25 September 2025.
[5] European Casino Association, “EU Member States miss out on €22.9 billion in tax revenue due to illegal online gambling,” 2026.
[6] Campaign for Fairer Gambling / GCI, “Europe’s €91.6 Billion Unregulated Gambling Economy,” 23 September 2026.
[7] UK Gambling Commission, “Illegal online gambling: Consumer engagement and trends — Executive summary,” published 25 September 2025.
